This policy was last modified on July 1, 2020.


This privacy policy (this “Privacy Policy”) describes how we collect, use, and share data that we obtain through your use of the Internet sites, applications, and online services (the “Site”) operated by, controlled by, or affiliated with VaynerX, LLC, and certain subsidiaries, affiliates, and entities that it controls, including VaynerMedia, LLC, VaynerCommerce, LLC, VaynerProductions, LLC, VaynerSpeakers, LLC, VaynerTalent, LLC, and Sasha Group, LLC (collectively, “VaynerX,” “we,” “us,” or “our”). If you are a resident of California, please review our [California Privacy Policy] for additional disclosures required by California law. If you are a resident of the European Union, please review our [EU Privacy Policy] for additional information relating to your rights.


By using the Site, you agree to the practices described in this Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this Privacy Policy periodically. Updates will be referenced by the “Last Modified” date shown above.


Table of Contents

1. Collection of Data

2. Use of Collected Data

3. Third-Party Websites 

4. Sharing of Collected Data

5. Transfer of Collected Data

6. Data Security

7. Data Retention

8. Children and Parents

9. Our “Do Not Track” (DNT) Policy

10. Your Data Preferences

11. California Privacy Policy

12. EU Privacy Policy

13. Contact Us


1. Collection of Data


We collect data from you in several different ways on the Site, including personal data and data about your use of the Site which does not identify you personally. Personal data means information, or combination of information, that can reasonably be used to identify you personally (such as your name, phone number, address, and email address).


We collect personal data that you voluntarily provide to us.


We collect personal data that you voluntarily provide to us (such as when you submit an inquiry), including name, email address, and any other data you choose to provide.


We automatically collect data about your use of the Site.


When you access and use the Site, our technology and tools may automatically collect and record certain data about your use of and interaction with the Site that does not identify you personally (such as your IP address, browser type, the make and model of device used to view the Site, unique device identifiers, the referring webpage, pages visited, and search terms).


We also use various tracking technologies (such as cookies and pixel tags) to collect data about your use of and access to the Site. Cookies are small data files stored on your hard drive or in device memory by websites you visit, applications you use, or advertisements you view and help us improve the Site and your experience on the Site. Pixel tags are electronic images that generate a generic notice of a visit to the Site and are used in conjunction with cookies to anonymously track activity on the Site by a particular browser.


Third parties may also automatically collect data about you.


Some content on the Site may be served by third-party content providers and may also use cookies, pixels tags, or other similar tracking technologies to automatically collect data about you, both on the Site and throughout the Internet. We do not control the technologies of those third parties. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.


2. Use of Collected Data


We use the data we collect to assist in the administration and operation of the Site and to provide you an efficient, meaningful, and customized experience. 


We may use data to:


  • Fulfill our obligations with respect to the reason you voluntarily provided the data (such as responding to an inquiry);
  • Allow you to participate in certain features of the Site;
  • Improve the Site or our products, events, and services and for other business or commercial purposes;
  • Optimize your experience on the Site (such as troubleshooting technical programs or storing your preferences);
  • Notify you about changes to the Site (including this Privacy Policy);
  • Carry out any other purpose described to you at the time the data was collected; and
  • Carry out any other purpose with your consent or as permitted by law.


Additionally, we may use data for marketing purposes to:


  • Provide you with additional information regarding products, events, and services from VaynerX via email or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and
  • Develop, improve, and target our promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).


You can learn more about Facebook ads HERE and other types of online advertising HERE.


3. Third-Party Websites


Through your use of the Site, you may access, directly or indirectly, other websites or services, including from our service providers, business partners, and other third parties, in each case, that are not owned or controlled by us. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.


Please note that when you apply for a job with us through our job application portal, the privacy policy of our job applicant processing partner may also apply to the submission of your application information.


4. Sharing of Collected Data


We may share the data we collect as follows:


  • With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
  • With our service providers that perform services for us (such as e-mail and mobile marketing, analytics, and web hosting);
  • With our sponsors or event partners in connection with certain ticketed events; 
  • To comply with a court order or other legal obligation, to enforce the Site terms of use, and to protect the rights, property, or safety of our users and other third parties;
  • With government or law enforcement officials or private parties (including our legal or other professional advisors) as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, laws, regulations, or ordinances, or to prevent or stop illegal, unethical, or actionable activity; 
  • In connection with, or during negotiations of, any merger, acquisition by another company, or sale of all or substantially all of our business or assets; and
  • With your consent or at your direction.


5. Transfer of Collected Data


The Site is operated in the United States. If you are located in another jurisdiction, please be aware that the data we collect will be transferred to, stored, and processed in the United States. By using the Site and/or providing us with any data, you consent to this transfer, processing, and storage of your data in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen such as the European Union. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. We will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards and ensure that your data is treated securely and in accordance with this Privacy Policy.


6. Data Security


We use commercially reasonable technical and organizational measures to help secure and safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.


7. Data Retention


We retain data only as long as necessary in light of the purpose(s) for which it was originally collected. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.


8. Children and Parents


We respect children’s privacy. We do not target or knowingly or intentionally collect personal data from children under the age of 13. By using the Site, you have represented and warranted that you are either at least 18 years of age or using the Site with the supervision of a parent or guardian. If you are under the age of 13, you may not use the Site. If you become aware that your child has provided us with personal data without your consent, please [Contact Us].


9. Our “Do Not Track” (DNT) Policy


Some websites have “do not track” features that allow you to tell a website not to track you. We do not currently respond to those signals or any similar mechanisms transmitted by web browsers. To learn more about DNT and tracking signals, please visit All About DNT.


10. Your Data Preferences


Use of Collected Data


If you no longer want us to use your collected data as described above, please submit a request by completing this [form].


Communications


If you no longer wish to receive communications from VaynerX, please follow the instructions in the emails to opt-out from receiving such messages in the future or submit a request by completing this [form].


Cookies, Pixel Tags, and Other Similar Tracking Technologies


You may remove or reject cookies by adjusting settings on your browser, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data. These tracking technology opt-out tools are device and browser specific so you must repeat the opt-out from each of your devices and browsers. Please note that removing or rejecting cookies could affect the functionality of the Site. 


You may also remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools). 


Advertising Preferences


You may adjust your advertising preferences on various social media websites by adjusting your Settings on the particular platform. For example, you may adjust the types of Facebook ads you receive on Facebook and the types of Google ads you receive on Google.


11. California Privacy Policy


If you are a resident of California, please review our [California Privacy Policy] for additional disclosures required by California law.


12. EU Privacy Policy


If you are a resident of the European Union, please review our [EU Privacy Policy] for additional information about your rights.


13. Contact Us


To submit a request relating to Your Data Preferences, please complete this [form]. Please note that requests submitted through the form are processed more quickly than requests submitted by email or mail.


If you have any questions about this Privacy Policy, please email us at privacy@vaynerx.com or write to us at one of the following addresses: 


VaynerX, LLC

Attention: Legal Department; Privacy Policy Inquiry

10 Hudson Yards, 25th Floor

New York, NY 10001


PRIVACY POLICY

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