GoVyrl, Inc. Privacy Policy.

Effective September 10, 2018

GoVyrl, Inc. takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Members (Section 2), Contacts (Section 3), and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.

  1. The Basics.
    1. About Us.

      GoVyrl, Inc. is headquartered in the State of California in the United States ("we," "us," "our," and "GoVyrl") and operates a variety of Websites and online marketing services and applications, including the Carro application (the "Services").

      The Services enable our Members to, among other things, identify and communicate with influential customers for marketing purposes. We also provide other related services, such as real-time data analytics. Find out more about our Services at www.vyrl.co and www.getcarro.com.

    2. Key Terms.

      In this privacy policy, these terms have the following meanings:

      "Contact" is a person a Member may contact through our Services. In other words, a Contact is anyone on a Member's Distribution List or about whom a Member has given us information. For example, if you are a Member, a subscriber to your email marketing campaigns, or a purchaser of your products, would be considered a Contact.

      "Distribution List" is a list of Contacts a Member may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).

      "Member" means any person or entity that is registered with us to use the Services.

      "Personal Information" means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

      "Website(s)" means any website(s) we own and operate (such as www.vyrl.co or www.getcarro.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.

      "Visitor" means any person who visits any of our Websites.

      "you" and "your" means, depending on the context, either a Member, a Contact, or a Visitor.

  2. Privacy for Members.

    This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Members and potential Members.

    1. Information We Collect.

      The Personal Information that we may collect broadly falls into the following categories:

      • Information you provide to us.
      • In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with Carro), or communicate with us in any other way.

        By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.

        This information may include:

        • Registration information: You need a GoVyrl account to use the Services as a Member. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, username, password, company name, occupation, location, and phone number (for example, if you are using two-factor authentication).
        • Billing and communications information: If there is a fee in connection with your use of the Service, you may also need to provide us with payment and billing information, such as your credit card details and billing address. GoVyrl will also maintain a record of your billing transactions and purchases, and any communications and responses.
        • Information we process on your behalf: In order to use certain features in your account, you need to upload a Distribution List that provides us information about your Contacts, such as their names and email addresses. We use and process this information to provide the Services in accordance with your instructions.
      • Information we collect automatically.
      • When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information.

        This information may include:

        • Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
        • Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
        • Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services.
      • Information we collect from other sources.
      • From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.

    2. Use of Personal Information.

      We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

      • To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.
      • To send you system alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.
      • To communicate with you about your account and provide customer support.
      • To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.
      • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
      • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
      • To prosecute and defend a court, arbitration, or similar legal proceeding.
      • To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
      • To provide, support and improve the Services. For example, this may include sharing your or your Contacts' information with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we share Personal Information with third parties, we will seek assurances (though we cannot guarantee) that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.
      • For our data analytics projects. Our data analytics projects use data from GoVyrl accounts, including Personal Information of Contacts, to provide and improve the Services. We use information like your sending habits and your Contacts' details and purchase history, so we can make more informed predictions, decisions, and products for our Members.
      • Combined information. We may combine Personal Information with other information we collect or obtain about you or your Contacts (such as information we source from our third-party partners) to deliver a product or service, to improve the Services, or for advertising or targeting purposes in accordance with this privacy policy.
      • Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
    3. Cookies and Tracking Technologies.

      We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in communications we send. These web beacons track certain behavior such as whether the message sent through the Services was delivered and opened and whether links within the message were clicked. They also allow us to collect information such as the recipient's IP address, browser, client type and other similar details. We use this information to measure performance, provide analytics information, and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.

    4. Member Distribution Lists.

      A Distribution List can be created in a number of ways, including by importing Contacts, such as through a CSV or directly from your email client. Your Distribution Lists are stored on a secure GoVyrl server. We do not sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we might then contact that person. You may export (download) your Distribution Lists from GoVyrl at any time.

      If we detect abusive or illegal behavior related to your use of the Distribution List in connection with our Services, we may share your Distribution List or portions of it with affected ISPs or anti-spam organizations to the extent permitted or required by applicable law.

    5. Other Data Protection Rights.

      You and your Contacts may have the following data protection rights:

      • To access, correct, update or request deletion of Personal Information. GoVyrl takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date.
      • In addition, individuals who are residents of the European Economic Area ("EEA") can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information.
      • Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
      • The right to complain to a data protection authority about our collection and use of Personal Information. For more information, please contact your local data protection authority.

      You can exercise these rights by contacting us using the contact details provided in the "Questions and Concerns" section below. If any of your Contacts wishes to exercise any of these rights, they should contact you directly, or contact us as described in the "Privacy for Contacts" section below.

      We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.

  3. Privacy for Contacts.

    This section applies to the information we process in connection with our contact list and Members' Contacts. Our Services are intended for use by our Members. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. GoVyrl is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place. For purposes of this section, "you" and "your" refer to Contacts and individuals on our contact list.

    1. Information We Collect.

      The Personal Information that we may collect or receive about you broadly falls into the following categories:

      • Information we receive about Contacts from our Members: A Member may provide Personal Information about you to us through the Services. For example, when a Member uploads their Distribution List or integrates the Services with another website or service (for example, when a Member chooses to connect their e-commerce account with Carro), or when you sign up for a Member's Distribution List through the Carro signup procedure, they may provide us with certain contact information or other Personal Information about you such as your name, email address, address or telephone number. You may have the opportunity to update some of this information by electing to update or manage your preferences directly with the Member.
      • Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily, or to authenticate in through a social media account. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information), or authenticate through a social media account, in order to sign up for a free or paid GoVyrl account, apply for a role with GoVyrl, or otherwise submit inquiries to us. When you authenticate through a social media account, we track activity associated with that account in relation to the Services. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
      • Information we collect automatically: When you interact with a message you receive from a Member or browse or purchase from a Member's connected store, we may collect information about your device (for example, your IP address, your operating system, your browser ID, and other information about your system and connection), interaction with the Services (for example, dates and times you access messages and your browsing activities), and the performance of the Services (for example, metrics related to the deliverability of electronic communications our Members send through the Services). We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below.
      • Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as social media platforms and third-party data providers. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us, and we use this information to provide publicly available social media information about you to Members.
    2. Use of Personal Information.

      We may use the Personal Information we collect or receive about you for our legitimate business interests, including:

      • To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.
      • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
      • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
      • To prosecute and defend a court, arbitration, or similar legal proceeding.
      • To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
      • To provide, support and improve the Services. For example, this may include sharing your information with third parties in order to provide and support our Services or to make certain features of the Services available to our Members. When we share Personal Information with third parties, we will seek assurances (though we cannot guarantee) that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.
      • For our data analytics projects. Our data analytics projects use data from Urchin Tracking Module (UTMs), third party sources, and GoVyrl accounts, including your Personal Information, to provide and improve the Services. We use information, like your details and purchase history, provided to us by Members, so we can make more informed predictions, decisions, and products for our Members.
      • Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to deliver a product or service, to improve the Services, or for advertising or targeting purposes in accordance with this privacy policy.
      • Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes.
    3. Cookies and Tracking Technologies.

      We and our partners may use various technologies to collect and store information when you interact with a Member's messages or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the communications we send on behalf of our Members. When you receive and engage with a Member's campaign, web beacons track certain behavior such as whether the message sent through the Services was delivered and opened and whether links within the message were clicked. They also allow us to collect information such as your IP address, browser, client type, and other similar details. We use this information to measure performance, provide analytics information, and enhance the effectiveness of our Services.

    4. Legal Basis for Processing.

      We process Personal Information about you as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; and ensuring the security of the Services and our Website.

    5. Other Data Protection Rights.

      You may have the following data protection rights:

      • To access, correct, update or request deletion of your Personal Information. GoVyrl takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date.
      • In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
      • Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
      • The right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

      As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by GoVyrl as a processor on behalf of our individual Members, you should contact the relevant Member that is using the GoVyrl Services, and refer to their separate privacy policies.

      If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member's email list or contact the Member directly to update or delete your data. Additionally, you may contact us directly at any time about exercising your data protection rights, by contacting us using the contact details provided in the "Questions and Concerns" section below. We will consider your request in accordance with applicable laws, and may remove or update your information within a reasonable time and after providing notice to the Member of your request. We may ask you to verify your identity in order to help us respond efficiently to your request.

  4. Privacy for Visitors.

    This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our sales and marketing activities, recruitment, and events. In this section "you" and "your" refers to Visitors. If you sign up for a GoVyrl account and use it to communicate with Members, please see also Section 3 regarding Privacy for Contacts, as that will also be applicable.

    1. Information We Collect.
      • Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily, or to authenticate in through a social media account. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information), or authenticate through a social media account, in order to sign up for a free or paid GoVyrl account, apply for a role with GoVyrl, or otherwise submit inquiries to us. When you authenticate through a social media account, we track activity associated with that account in relation to the Services. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
      • Information we collect automatically through the Websites: When you visit our Websites, or interact with a Member website that uses the Services, we may also collect certain information automatically from your device (for example, your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection). In some countries, including countries in the EEA, this information may be considered Personal Information under applicable data protection laws.
    2. Use of Personal Information.

      We may use the information we collect through our Websites for a range of reasons, including:

      • To provide the Websites and the Services.
      • To set up online accounts, process transactions, provide you with information and access to resources or services that you have requested from us, and respond to your online inquiries and requests.
      • To develop, manage, and improve the Websites and the Services.
      • To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us monitor the use of our Website and Services and prevent violations.
      • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
      • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
      • To prosecute and defend a court, arbitration, or similar legal proceeding.
      • To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
      • To provide, support and improve the Services. For example, this may include sharing your information with third parties in order to provide and support our Services or to make certain features of the Services available to our Members. When we share Personal Information with third parties, we will seek assurances (though we cannot guarantee) that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.
      • For our data analytics projects. Our data analytics projects use data from GoVyrl accounts, including your Personal Information, to provide and improve the Services. We use information, like your purchase history and social media account details, provided to us by Members, so we can make more informed predictions, decisions, and products for our Members.
      • Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to deliver a product or service, to improve the Websites and the Services, or for advertising or targeting purposes in accordance with this privacy policy.
      • To send you information for marketing purposes, in accordance with your marketing preferences.
      • For recruitment purposes if you have applied for a role with GoVyrl.
      • To carry out other legitimate business purposes, as well as other lawful purposes.
    3. Cookies and Tracking Technologies.

      We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising.

    4. Other Data Protection Rights.

      You may have the following data protection rights:

      • To access, correct, update, or request deletion of your Personal Information. GoVyrl takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date.
      • In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
      • Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
      • The right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

      You can exercise these rights by contacting us using the contact details provided in the "Questions and Concerns" section below. If any of your Contacts wishes to exercise any of these rights, they should contact you directly, or contact us as described in the "Privacy for Contacts" section below.

      We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

  5. General Information.
    1. How We Share Information.

      We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Members, Contacts, and Visitors unless otherwise indicated):

      • Sometimes we share your information with our third-party service providers, who help us provide, support and improve the Services and other business-related functions. When we share Personal Information with third parties, we will seek assurances (though we cannot guarantee) that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.
      • Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information of Members and Visitors with them for this purpose. We do not sell Members' Distribution Lists.
      • Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
      • A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.
      • Any other person with your consent.
    2. Cookies (and Other Tracking Technologies).

      We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites, the Services, and other sites in order to provide you with targeted advertising based on your browsing activities and interests.

      Cookies. Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information. You can control information collected by cookies. You can delete or decline cookies by changing your browser settings. Click "help" in the toolbar of most browsers for instructions.

      Pixel tags. Pixel tags (also called web beacons or clear GIFs) are embedded on web pages, ads, and messages. These tiny, invisible graphics are used to access cookies and track user activities (such as how many times a page is viewed). We use pixel tags to measure the popularity of our features and services. Ad companies also use pixel tags to measure the number of ads displayed and their performance (such as how many people clicked on an ad).

      Urchin Tracking Module (UTM). UTM parameters are URL parameters used by marketers to track the effectiveness of online marketing campaigns across traffic sources and publishing media. We use these to track effectiveness of marketing campaigns.

      Mobile device IDs. If you're using our Services, we may use mobile device IDs (the unique identifier assigned to a device by the manufacturer), or Advertising IDs, instead of cookies, to recognize you. We do this to store your preferences and track your use of the Websites and Services. Unlike cookies, device IDs cannot be deleted, but Advertising IDs can be reset in "Settings" on your iPhone. Ad companies also use device IDs or Advertising IDs to track your use of the Services, track the number of ads displayed, measure ad performance and display ads that are more relevant to you. Analytics companies use device IDs to track information about usage.

      Do Not Track: Some Internet browsers include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our Websites do not currently process or respond to "DNT" signals. We take privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

    3. Legal Basis for Processing Personal Information (EEA Persons Only).

      If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

      However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.

      If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.

      Where required by law, we will collect Personal Information only where we have your consent to do so.

      If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.

    4. Your Choices and Opt-Outs.

      Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.

      Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and you cannot opt out of these messages unless you cancel your GoVyrl account.

    5. Security.

      We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

      GoVyrl accounts require a username and password, or social media authentication, to log in. Account holders must keep their username and password secure, and never disclose it to a third party.

    6. Public Information and Third-Party Websites.
      • Social media platforms and widgets. Some of our Websites may include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly.Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
      • Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively, "Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details, or authentication through a social media account. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion's rules or law, use the information provided to communicate with you, or other people you select, about our Services, and to improve the Services. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.
      • Note regarding links to third-party websites. Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
    7. International Transfers.

      Our servers and offices are located in the United States, so your information may be transferred to/from, stored, or processed in the United States.

      If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by us from your region to countries, including the United States, which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

    8. Data Retention.

      We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:

      • Whether we have a legal or contractual need to retain the data.
      • Whether the data is necessary to provide our Services.
      • Whether our Members have the ability to access and delete the data within their GoVyrl accounts.
      • Whether our Members would reasonably expect that we would retain the data until they remove it or until their GoVyrl accounts are closed or terminated.

      When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

    9. California Privacy.

      Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties' direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us using the contact details provided in the "Questions and Concerns" section below.

    10. Changes to this Policy.

      We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.

    11. Questions & Concerns.

      If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:

      For EEA Residents:

      GoVyrl's Data Protection Officer can be contacted at privacy@vyrl.co.

      For Non-EEA Residents:

      GoVyrl, Inc.
      Attn. Privacy Officer
      privacy@vyrl.co
      200 Spectrum Center Drive, Suite 1260
      Irvine CA 92618