Last Updated: March 15, 2024 

VKTR is a Delaware company incorporated as VKTR, Inc. (hereinafter, “VKTR,” “we,” or “us”), and this Privacy Policy sets forth the terms and conditions with respect to how we process personal information about you (hereinafter “you” or “your”) and other third parties. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information. This Privacy Policy applies to the personal information you provide us when you visit any of our websites (collectively, the “Site“), purchase or receive products, goods, or services from VKTR, apply for a job with VKTR, or otherwise contact or engage with us. For purposes of this Privacy Policy, the Site and all products, goods and services furnished by VKTR shall be referred to collectively as the “Services.”  

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND THE VKTR TERMS OF SERVICE, CONSUMER HEALTH DATA PRIVACY POLICY, AND COOKIE POLICY, EACH BEING INCORPORATED INTO, AND FORMING AN INTEGRAL PART OF, THIS PRIVACY POLICY.  

1. Scope

This Privacy Policy applies to personal information that VKTR receives during its business operations. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and is not otherwise subject to a data protection law, statute, or regulation. VKTR may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and VKTR may use such data for any purpose.  

2. The Types and Categories of Personal Information We Collect

VKTR collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to VKTR, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:  

Personal Information
Category	Description/Examples
Personal Identifiers	Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer identification number.
Registration Data	Information provided when you register for an account to use the Site, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below)	Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Commercial Information	Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.
Business Contact Data	Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Marketing and Communications Data	Information with respect to your marketing preferences and your subscriptions to our publications and alerts.
Internet and Electronic Network Data	Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites.
Your Feedback	Information you provide about our Services, which may include data gathered from any VKTR surveys or reviews submitted by you.
Geolocation Data	Information about the general city, state, or region in which a user of the Site is located.
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)	If you apply for a job with VKTR, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.
Inferences	Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.

3. Technical Data

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:  

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.  

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. From time to time, we may use on our Site certain third-party cookies and pixels provided by our marketing partners, including social media companies. To the extent we use such third-party cookies and pixels, you hereby agree to the terms and conditions set forth by those third parties, which may include Meta, X (formerly Twitter), TikTok, and LinkedIn, among others. For more information, see our Cookie Policy 

Site Monitoring. Please be aware that we use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording.  

Non-Cookie Technologies. We may deploy on our Site certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs.  These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device. For more information, see https://thenai.org/wp-content/uploads/2021/07/NAI_BeyondCookies_NL.pdf.  

4. Sources of Information

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:  

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., account registration, completing purchases, signing-up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.  

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).  

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.  

5. How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our Services, (ii) enable you to access and use our Services, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Services, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests (e.g., marketing), (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities, and (x) personalize our Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, VKTR may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that VKTR may contact you via any means, including SMS/text message and email, to furnish you information regarding a product order, shipping status, warranty-related information, and similar data and information pertaining to a commercial transaction.  

Mobile Messaging Program. In the event you opt-in to our Mobile Messaging, we will collect and use your mobile telephone number to maintain and administer our Mobile Messaging Program. With your permission, we may send text messages about our store, new products, and other updates, including “Checkout Reminders” and we use webhooks to trigger the Checkout Reminders messaging system. Please review the VKTR Terms of Service for more information about the Mobile Messaging Program, including information on how to unsubscribe or update your personal information therein and your responsibilities and liabilities related thereto.  

6. Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.  

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, and performing analyses to improve the quality of our Services. In certain circumstances, our parent company, The Proctor & Gamble Company, performs technological and other business support functions on our behalf like a traditional service provider and we have executed the appropriate agreements and policies to limit how your personal information may be used and processed in this context.  

Payment Card Transactions. All payments for purchases made through the Site are completed using a third-party vendor’s online payment system. VKTR does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information. VKTR currently uses Stripe as our payment card processor. If you have any questions about payments or would like to dispute a charge, you can contact us at l[email protected].  

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.  

Business Restructuring. Circumstances may arise where for strategic or other business reasons VKTR decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of VKTR’s assets.  

Disclosure for Other Reasons. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, VKTR may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.  

In the event that you facilitate a transaction with VKTR, or request information from or otherwise engage with us, and such activities require VKTR to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct VKTR to intentionally disclose your personal information to the service provider or third party, provided VKTR has determined, in its reasonable judgment, that either (i) the service provider or third party will not sell the personal information or (ii) disclosing the personal information is required or permitted by law.  

7. Social Media/ Platform Data Rights

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, and the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.  

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified.  If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.  

8. Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.  

Video Links. We may include videos on our Site. By clicking on videos on our Sites, it may (i) take you to a third party’s site to play the video, or (2) play the video on our Site and this functionality may be supported by a third party’s site or technology (e.g., YouTube, YouTube API, Vimeo, or another third party site). In any such case, by playing the video you shall become subject to the third party’s terms and conditions, including, but not limited to, its terms of service and policies on privacy and collection and use of your personal information, including the legal terms from YouTube and Vimeo. 

9. Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information for long as needed to provide you with our Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.  

VKTR is based in the United States and the personal information that we collect and process is retained and stored in the United States. VKTR uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby consent to your personal information being transferred to, and stored in, the United States and in other third countries.  

10. Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.  

11. No Data Collected from Children

The Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under sixteen (16) years of age without verified consent from their parents or guardians. If you are under the age of sixteen (16), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information, unless you provide us written and verifiable authorization from your parent or legal guardian permitting you to do so.  

12. Publicly Posted Information; Product Reviews

The Site may provide you with the ability to submit a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”) or provide other information on the Site which may be posted to a publicly available portion of the Site. Any information or content you post in a Product Review will be available to other users of the Site and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part and we recommend you carefully consider the information you choose to make publicly available.  

13. Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to VKTR if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO VKTR, YOU EXPRESSLY REPRESENT AND WARRANT TO VKTR THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE VKTR WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT VKTR’s USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY VKTR FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO VKTR.  

14. Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. You have the ability to update your personal information at “checkout” when you purchase a good or product. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address) and you must do so, when such changes are warranted. If your account does not contain such features, then you must directly notify VKTR of any changes or updates to your personal information in accordance with the “Contact Us” section listed below. 

15. Email Marketing and Your Rights

You have the right to opt-out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify VKTR, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.  

16. SMS/Text Marketing and Your Rights

VKTR offers a Mobile Messaging Program in which we send participants text messages related to our Services, marketing programs, and discounts. By participating in the Mobile Messaging Program, you agree to receive autodialed or prerecorded marketing mobile messages and you understand that you are not required to make any purchase from us to participate in our Mobile Messaging Program. Message and data rates may apply to such communications. For more information about the Mobile Messaging Program, please see the VKTR Terms of Service. You hereby agree to immediately notify VKTR, in writing, in the event you no longer own, license, or use the telephone number to which you used to enroll into our Mobile Message Program.  

17. Australia Privacy Rights

Data Privacy Rights. The personal information collected, stored, used, and/or processed by VKTR, as described in this Privacy Policy, is collected, stored, used and/or processed in accordance with the Australian Privacy Act 1988 (Commonwealth), as amended, and the Australia Privacy Principles (“APPs”). Further information regarding the APPs are set out on the Australian Government website www.oaic.gov.au. If you would like to update or access your personal information held by  VKTR, please contact us in accordance with the “Contact Us” section listed below. If we refuse access, we will provide you with a written notice which sets forth the reasons for the refusal. If your request to access your personal information requires a significant allocation of resources, we may charge a reasonable administration fee to cover costs, unless otherwise prohibited by law. If you believe that the personal information that we hold about you is incorrect, incomplete, or inaccurate, then you may request we amend it and you may submit such a request by contacting us in accordance with the “Contact Us” section listed below. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note or disclaimer to the personal information stating that you disagree with it.  

Complaint Process. Please notify us of any complaint you may have about our handling of your personal information by contacting using any of the following means: (email) lukermaret@gmail.com, (mail)  VKTR, ATTN: Privacy Champion91-1121, Keaunui Dr, Ste 108 PMB 170, Ewa Beach, HI, 96706, US and please set forth the details of your complaint. We will undertake commercially reasonable efforts to reply to your complaint within thirty (30) days and will, where necessary or appropriate, advise you of the general reasons with respect to how we responded to your complaint. Notwithstanding the foregoing, you may submit a complaint at any time to the Office of the Australian Information Commissioner.  

18. United States Privacy

California Privacy Rights  

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents are entitled to certain data privacy rights:   

• Right to Know (Specific Pieces of Personal Information). You have the right to know the specific pieces of your personal information that we have collected about you. 
  • Right to Know (Categories of Personal Information). You have the right to know (i) the categories of personal information we have collected from you; (ii) the categories of sources from which the personal information is collected; (iii) the categories of your personal information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling your personal information. 
  • Right to Delete. You have the right to request that we delete your personal information that we have collected and retain.  
  • Right to Correct. You have the right to request that we correct inaccurate personal information that we have collected and retain.  
  • Nondiscrimination. You have the right not to be subject to discrimination for asserting your rights under the CCPA.  

Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) [email protected] (mail) VKTR, ATTN: Privacy Champion, 91-1121 Keaunui Dr, Ste 108 PMB 170, Ewa Beach, HI, 96706. An authorized agent must be registered with the California Secretary of State to conduct business in California.  

Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information, VKTR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, VKTR will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.  

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).  

Opt-Out Rights / Do Not Share My Personal Information. California residents have the right to opt out of the “sharing” of their personal information. VKTR uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.  

Children. The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore VKTR does not knowingly sell or share the personal information of minors under sixteen (16) years of age.  

Limit Use of Sensitive Personal Information. VKTR does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.  

California “Shine the Light”. Under California Civil Code Section 1798.83 (“Shine the Light”), 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, as defined under Shine the Light, such as name, email address, 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; however, we do not disclose personal data to third parties for their direct marketing purposes.  

Colorado Privacy Rights  

Data Privacy Rights. Pursuant to the Colorado Privacy Act (CPA), Colorado residents are entitled to the following data privacy rights:  

• To confirm whether or not we are processing your personal information and access such personal information, unless such confirmation or access would require us to reveal a trade secret. 
• To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information. 
• To delete personal information provided by, or obtained about, you. 
• To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. 

Submit a Privacy Request. To submit a CPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a CPA privacy request on your behalf.  

Privacy Request Verification Process. If you make any request related to your personal information, VKTR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, VKTR will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Colorado Privacy Act, please see https://coag.gov/resources/colorado-privacy-act/.   

Privacy Requests Appeals Process. If you would like to appeal a decision VKTR has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Colorado Attorney General at: https://coag.gov/file-complaint/.  

Opt-Out Rights / The Sale of Personal Information. Colorado residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).  

Opt-Out Rights / Targeted Advertising. Colorado residents have the right to opt out of having their personal information used for targeted advertising purposes. VKTR uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.   

Opt-Out Rights / Profiling. Colorado residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, VKTR does not engage in such activities.   

Connecticut Privacy Rights  

Data Privacy Rights. Pursuant to the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, also known as the Connecticut Data Privacy Act (CDPA), Connecticut residents are entitled to the following data privacy rights:  

• To confirm whether or not we are processing your personal information and access such personal information, unless such confirmation or access would require us to reveal a trade secret. 
• To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information. 
• To delete personal information provided by, or obtained about, you. 
• To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided we shall not be required to reveal any trade secret. 

Submit a Privacy Request. To submit a CDPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a CDPA privacy request on your behalf.  

Privacy Request Verification Process. If you make any request related to your personal information, VKTR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, VKTR will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Connecticut Data Privacy Act, please see https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy Act.   

Privacy Requests Appeals Process. If you would like to appeal a decision VKTR has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Connecticut Attorney General at: https://portal.ct.gov/DCP/Complaint-Center/Consumers—Complaint-Center.  

Opt-Out Rights / The Sale of Personal Information. Connecticut residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).  

Opt-Out Rights / Targeted Advertising. Connecticut residents have the right to opt out of having their personal information used for targeted advertising purposes. VKTR uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.   

Opt-Out Rights / Profiling. Connecticut residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, VKTR does not engage in such activities.  

Consumer Health Data. Connecticut law regulates how companies may collect, retain, and use “consumer health data,” which is defined as “any personal data that a controller uses to identify a consumer’s physical or mental health condition or diagnosis, and includes, but is not limited to, gender-affirming health data and reproductive or sexual health data.” Please see our Consumer Health Data Privacy Policy for more information on how we may collect, retain, and use consumer health data. The term “consumer health data” is considered “sensitive data” for purposes of the CDPA (and “sensitive data” is subset of “personal data” as the term is so defined within the CDPA). The data privacy rights listed in this section apply to consumer health data. In the event you provide us with consumer health data, you hereby expressly consent to our use and processing of such consumer health data.  

Montana

Data Privacy Rights. Pursuant to the Montana Consumer Data Privacy Act (MCDPA), Montana residents are entitled to the following data privacy rights: 

o To confirm whether we are processing your personal information and access your personal information, unless such confirmation or access would require us to reveal a trade secret. 

o To correct inaccuracies in your personal information, considering the nature of the personal information and the purposes of the processing of your personal information. 

o To delete personal information about you. 

o To obtain a copy of your personal information previously provided by you to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal information to another controller without hindrance when the processing is carried out by automated means, provided we are not required to reveal any trade secret;. 

Submit a Privacy Request. To submit a MCDPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a MCDPA privacy request on your behalf. 

Privacy Request Verification Process. If you make any request related to your personal information, VKTR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. 

Privacy Requests Appeals Process. If you would like to appeal a decision VKTR has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Montana Attorney General at: https://dojmt.gov/consumer/. 

Opt-Out Rights / The Sale of Personal Information. Montana residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities). 

Opt-Out Rights / Targeted Advertising. Montana residents have the right to opt out of having their personal information used for targeted advertising purposes. VKTR uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences. 

Opt-Out Rights / Profiling. Montana residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, VKTR does not engage in such activities. 

Nevada Privacy Rights  

VKTR does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.  

Consumer Health Data. Nevada law regulates how companies may collect, retain, and use “consumer health data,” which is defined as “personally identifiable information that is linked or reasonably capable of being linked to a consumer and that a regulated entity uses to identify the past, present or future health status of the consumer.” Please see our Consumer Health Data Privacy Policy for more information on how we may collect, retain, and use consumer health data. In the event we collect your consumer health data, you have the right that we (i) confirm whether we are collecting, sharing or selling your consumer health data, (ii) provide you with a list of all third parties with whom we have shared or sold your consumer health data, (iii) cease collecting, sharing or selling your consumer health data, and (iv) delete consumer health data concerning the consumer. To exercise these rights, please contact us  in accordance with the “Contact Us” section below. Once you submit such a request, we will authenticate your requests and process it as required by law.  Please allow up to 45 days for a response.  If we deny your privacy rights request, you may appeal that denial by undertaking the following, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may also file a complaint the Nevada Attorney General at https://ag.nv.gov/Complaints/File_Complaint/. 

Oregon 

Data Privacy Rights. Pursuant to the Oregon Consumer Data Privacy Act (OCDPA), Oregon residents are entitled to the following: 

• To obtain from us confirmation as to whether we are processing or have processed your personal information and the categories of personal information we are processing or have processed.
• To obtain from us, at our option, a list of specific third parties, other than natural persons, to which we have disclosed (i) your personal information; or (ii) any personal information.
• To obtain from us a copy of all of your personal information that we have processed or we are processing.
• To require us to correct inaccuracies in personal information about you, taking into account the nature of the personal information and our purpose for processing the personal information.
• To require us to delete your personal information, including personal information you provided to us, personal information we obtained from another source, and derived data.

Submit a Privacy Request. To submit a OCDPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a OCDPA privacy request on your behalf. Please note that notwithstanding your privacy rights, we are not required to disclose our trade secrets, as defined in O.R.S. 646.461. 

Privacy Request Verification Process. If you make any request related to your personal information, VKTR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. 

Privacy Requests Appeals Process. If you would like to appeal a decision VKTR has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Oregon Attorney General at: https://www.doj.state.or.us/consumer-protection/contact-us/  

Opt-Out Rights / The Sale of Personal Information. Oregon residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities). 

Opt-Out Rights / Targeted Advertising. Oregon residents have the right to opt out of having their personal information used for targeted advertising purposes. VKTR uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences. 

Opt-Out Rights / Profiling. Oregon residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, VKTR does not engage in such activities. 

Texas Privacy Rights 

Data Privacy Rights. Pursuant to the Texas Data Privacy and Security Act (TDPSA), Texas residents are entitled to the following data privacy rights: 

• To confirm whether we are processing your personal information and to access the personal information.
• To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
• To delete personal information provided by or obtained about you.
• If your personal information is available in a digital format, to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another party without hindrance.

Submit a Privacy Request. To submit a TDPSA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a TDPSA privacy request on your behalf. Please note that notwithstanding your privacy rights, we are not required to disclose our trade secrets. 

Privacy Request Verification Process. If you make any request related to your personal information, VKTR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. 

Privacy Requests Appeals Process. If you would like to appeal a decision VKTR has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Texas Attorney General at: https://www.texasattorneygeneral.gov/consumer-protection

Opt-Out Rights / The Sale of Personal Information. Texas residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities). 

Opt-Out Rights / Targeted Advertising. Texas residents have the right to opt out of having their personal information used for targeted advertising purposes. VKTR uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences. 

Opt-Out Rights / Profiling. Texas residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, VKTR does not engage in such activities. 

Utah Privacy Rights 

Data Privacy Rights. Pursuant to the Utah Consumer Privacy Act (UCPA), Utah residents are entitled to the following data privacy rights: 

• To confirm whether or not we are processing your personal information and to access such personal information.
• To delete personal information provided by you to us.
• To obtain a copy of your personal data that you previously provided to us in a format, that to the extent technically feasible is portable, to the extent practicable is readily usable, and allows you  to transmit the data to another entity without impediment, where the processing is carried out by automated means.

Submit a Privacy Request. To submit a UCPA privacy request, please contact us in accordance with the “Contact Us” section below. 

Privacy Request Verification Process. If you make any request related to your personal information, VKTR will ascertain your identity  to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, or erasing, specific pieces or categories of personal information or otherwise responding to your request, VKTR will, to the extent required or permitted by law, (i) require you to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Utah Consumer Privacy Act, please see https://le.utah.gov/~2022/bills/static/SB0227.html. 

Opt-Out Rights / The Sale of Personal Information. Utah residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for monetary consideration,  and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities). 

Opt-Out Rights / Targeted Advertising. Utah residents have the right to opt out of having their personal information used for targeted advertising purposes. VKTR uses third-party analytical and targeted advertising features on our Sites and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences. You may also contact us in accordance with the “Contact Us” section listed below. 

Virginia Privacy Rights  

Data Privacy Rights. Pursuant to the Virginia Consumer Data Protection Act, Virginia residents are entitled to certain data privacy rights:  

• To confirm whether or not VKTR is processing your personal information, and to access such personal information. 
  • To request VKTR correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. 
  • To request VKTR delete your personal information.  
  • To obtain a copy of the personal information that you previously provided VKTR in a portable and, to the extent technically feasible, readily usable format that allows it to be transmitted to another entity without hindrance, where the processing is carried out by automated means.  

Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) L[email protected], (mail) VKTR, ATTN: Privacy Champion, 201 California Street, Suite 450, San Francisco CA 94111. or please use our interactive webform.  

Privacy Request Verification Process. If you make any request related to your personal information, VKTR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, VKTR will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. None of Virginia’s privacy rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the Virginia Consumer Protection Act, please see: https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.  

Privacy Requests Appeals Process, Complaints. If you would like to appeal a decision VKTR has made with respect to your privacy request, please email l[email protected]  with the subject line “PRIVACY REQUEST: APPEALS” and describe the nature of your request, and the reason for requesting an appellate review. Virginia residents may file privacy complaints with the Virginia Attorney General (https://www.oag.state.va.us/contact-us/contact-info).  

Opt-Out Rights / The Sale of Personal Information. Virginia residents have the right to opt out of the “sale” of their personal information. However, VKTR does not sell your personal information to third parties for or monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).  

Opt-Out Rights / Targeted Advertising. Virginia residents have the right to opt out of having their personal information used for targeted advertising purposes. VKTR uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences.  

Opt-Out Rights / Profiling. Virginia residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, VKTR does not engage in such activities.  

19. Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.  

20. Persons with Disabilities

VKTR strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternate format, and we will seek to meet your needs.  

21. Rewards Programs and Financial Incentives

We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. VKTR may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy.  

California Rewards Program Rights. Pursuant to the CCPA, you may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of the value of your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personally information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good-faith effort often involving (i) the categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value described herein is not intended to waive, nor should it be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.  

22. Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and, information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.  

23. Events and Video Teleconferencing

VKTR hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.  

24. Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.  

25. Contact Us

We have appointed a Privacy Champion to oversee compliance with this Privacy Policy. If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact our Privacy Champion at the following: (email) l[email protected], (mail) VKTR, ATTN: Privacy Champion, 91-1121 Keaunui Dr, Suite Ste 108 Keaunui Dr Ste 108 PMB 170, Ewa Beach, HI, 96706.