Privacy Policy

Privacy Policy

Privacy Policy last revised: December 10th, 2022.
For the Terms of Service of the Vintro™ Procurement platform, and for any defined terms herein, see: Terms.

Vintro respects the privacy rights of our users and is strongly committed to protecting your privacy. These Privacy Policy applies to the use of the Vintro™ Procurement platform (“Marketplace”) website, any other Marketplace mobile applications made available or operated by Vintro from time to time, other directly related services offered from time to time by Vintro, any subscription to recurring information or updates in connection therewith, sales, marketing or other events, information collected when you register, submit or reply to Listings or postings, participate in the communication functionalities of Vintro, and any other service or product of Vintro, including other websites, mobile applications, or other digital properties, as expressly indicated by Vintro in connection with the Marketplace such as through a link or other display of this Privacy Policy (collectively, the “Site”). Vintro and Vintro Marketplace are owned and operated by The Krowd Inc. (The Krowd Inc. and its affiliates “we”, “us”, or “Vintro”) This Privacy Policy does not apply to the use of other Vintro website or services such as Deal Flow or leaders introduction and review platforms which are subject to designated privacy policies. “You” or “User” refers to You as a user of the Site or services.

Please read this Privacy Policy and Privacy Statement carefully before you register with the Site, transact with other users or use the Services as it will help you understand what information we collect, what we do with the information we collect and your rights.

Collection And Use Of Your Personal Information

Vintro, or where relevant a service provider designated by Vintro, collects personal information that you choose to provide or we receive from other sources. This may include personal information you provide upon participating in activities on the Site, contacting us, expressing an interest in obtaining information, registering, or otherwise through the Site, on third-party websites and applications when subscribing digitally to Vintro, otherwise through registering for our services and products, through requesting certain Vintro services or products, by submitting the information to enter a contest, or other promotion or otherwise offline.

We and service providers designated by Vintro, may obtain the following types of personal information in connection with the Site:

  • Name, email address, postal address, account names and passwords, or other contact information
  • Signature, online identifier, Internet Protocol address, or other similar identifiers
  • Professional, industry, employment-related, or education information, including, inter alia, job titles and job applications, background or credit checks, purchase history and financial information, past and present associates
  • Internet or other electronic network activity information, including, inter alia, URLs, browsing history, app usage, search history, preferences, and information regarding a user’s interaction (including reading habits) with an internet website, application, advertisement
  • Demographic information
  • Social media login data where you elect to register using social media account details
  • Payment data and billing information, payment instrument details (including, inter alia, credit card number) and security information associated therewith or other financial information
  • Device data such as, inter alia, device ID and hardware specification, operating system, system configuration, application and browser type and identification numbers, internet or mobile service provider, internet protocol (IP) address and proxy servers
  • Geolocation

Personal information is obtained directly from you, from others authorized to provide the information, from any activity on the Site, and from other parties with whom we work, such as, inter alia, service providers, business partners, advertisers, advertising technology providers, advertising servers, data analytics providers, and social networks. If you submit personal information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

If you choose to link social media or other third-party accounts to our services, we may obtain personal information from these sources. You may restrict or disconnect this link at any time by visiting your account page on these third-party platforms or the settings page of your mobile device.

We use this information for carefully considered purposes which also benefit our customers and which include, inter alia, some or all of the following:

  • to provide and facilitate our services and products
  • to operate our services, products, and systems properly and diligently including, inter alia, the management of user accounts
  • to communicate with you and enable and support user-to-user communication
  • to post testimonials
  • to help Vintro and its third party service providers improve, upgrade, or enhance our services and products and develop and communicate new services and products
  • to provide support for our services and products,
  • to maintain the security, quality and safety of services and products, and for internal quality control purpose including debugging to identify and repair errors that impair existing intended functionality or security
  • to provide you with, and administer, offers, promotions and marketing communication about services and products of Vintro or of other parties that may be of interest to you, prize draws or competitions, and personalized content
  • to enhance your experience with the Site, including to save your preferences and login information, providing customized content or contextual advertisements, and providing tailored advertisements
  • to analyze website usage, analyze use of the Site, analyze and measure ad impressions, and to protect the interests, rights, safety, or property of Vintro, users or others, to monitor compliance with and enforce the terms of any agreement with Vintro and keep Vintro and the users free from harm
  • to advertise, promote or market the Vintro Marketplace or the relevant third party service providers or to otherwise market or commercialise such information, data or metadata to or through third parties
  • to monitor to detect security incidents and protect against unethical, malicious, deceptive, fraudulent, or illegal activity, and hold those responsible for that activity to account
  • to investigate and respond to legal requests, prevent harm, enforce our terms and conditions and policies and to comply with legal and regulatory requirements

Vintro or a designated service provider may also take photographs and video at Vintro offices and premises for security and other internal or business purposes.

You may instruct Vintro at any time not to use your personal information covered by this Privacy Policy to provide you with offers and promotions by clicking here or through your account settings. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Depending on the level of opt-out, features or functionalities of the Site or Services may be impaired or no longer available to you. Please also note that this opt-out process may take some time to complete, consistent with applicable law.

Use Of Cookies And Other Electronic Technologies

Vintro and the parties with whom we work (e.g., service providers, business partners, advertisers, ad technology providers and advertising servers) may place, view, and/or use “cookies”, web server logs, web beacons, pixels or other electronic technologies to collect statistical and other information about you and your use of the Site. This information may include, inter alia, information about the IP address of your computer, browser type, language, operating system, your mobile device, device ID, geolocation data, the state or country from which you accessed the Site services, the webpages visited, the date and the time of a visit, the websites you visited immediately before and after visiting the Site, the number of links you click within the Site, the functions you use on the Site, the databases you view and the searches you request on the Site, the types of articles you read, the data you save on or download from the Site and the number of times you view an advertisement.

Vintro and the parties with whom we work may use the information collected for various purposes, either on behalf of Vintro or for the other parties’ own purposes, including research, analysis, to better serve visitors to the Site (such as, inter alia, by enabling log-in, providing access to certain sections of the Site, providing customized content or customized contextual advertisements, or presenting online advertising on the Site or other websites or apps tailored to your interests as described further below), to compile aggregate and anonymous information about usage of the Site and other websites or apps, other statistics, etc. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on the cookie information disabled.

To assist us with the uses described in this Privacy Policy, information collected about you and your use of the Site or other websites may be aggregated, analysed or combined with personal or other information about you from other online or offline sources. If you prefer that we not combine non-personal information that has been collected, through cookies, about your use of the Site or other websites with personal or other information about you, then please delete and disable cookies for each browser, on each device you use to surf the Web or access an app.

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices also allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web or access the Sites, Services or apps. Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. Depending on your jurisdiction, you may be able to utilize additional cookie management tools. However, if you disable certain cookies or refuse to accept a request to place a cookie, it is possible that some parts of the Site, Services or apps, such as, inter alia, the polls, surveys, contests, and product sales, and certain areas of the Site or Services for which you need to log in, will not function properly, and advertising you receive when you visit the Site may not be advertisements tailored to your interests.

To opt out of Google Analytics please click here. To opt out of interest-based advertising by advertisers on our Site and Services, visit http://www.aboutads.info/choices/.

Advertisements

Vintro, its designated service providers, or third-party advertisers or their advertising servers may also place or recognize unique cookies on your device or use other electronic technologies in order to help display advertisements that you see on the Site or on other websites. Information about your visits to, and activity on, the Site and other websites, an IP address, the number of times you have viewed an advertisement, your interests and preferences and other such usage information is used, alone or in combination with other information, to create aggregate groups of users and to display advertisements that may be of particular interest to you or a group of users with similar interests to you. We may use Web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser’s cookie when a browser visits the Site, and to learn which banner ads bring users to the Site. The use and collection of your information by third-party service providers, and third-party advertisers and their advertising servers is not covered by this Privacy Policy. To “opt out” of advertising cookies placed by participating companies in the Self-Regulatory Program for Online Behavioural Advertising, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here for browsers and click here for mobile devices. To opt out of advertising cookies for Your Online Choices if you are based in the EU, please click here.

Some third party websites and platforms also allow you to manage the collection and use of your information for advertising purposes. Google Ad Manager, Google Analytics for Display Advertising, and other designated service providers assist Vintro with advertisement display functions and related analytics for the Site. To opt out of tailored advertising from Google tracking technologies, please click here.

Note that even if you exercise choice for targeted advertising, you will still receive online advertising.

Disclosure Of Your Personal Information

Vintro may disclose your personal information to our affiliates (including affiliated websites under common ownership or control) and designated service providers, for the purposes set out in this Privacy Policy and in the Terms of Service. Notably, the purpose of the services of Vintro is to enable its users to cooperate for procurement purposes. Therefore, unless Vintro in its discretion through the user interface or dashboard enables the User to elect anonymity for any stage of the Listing and procurement process, User’s name or identity will be visible to other users or third parties throughout the process. Vintro and its third party service providers may also disclose to third parties, including advertising networks, data analytics providers and social networks, your use of our or other websites, including, inter alia, online identifier, Internet Protocol address, device and internet or other electronic network activity information, and the services provided by us for the purposes set out in this Privacy Policy. Vintro and its third party service providers may disclose your personal information (excluding security photographs or video, if any) to a sponsor or other third party (“Third-Party Provider”) that provides you with offers or promotions that may be of interest to you or otherwise market or commercialise such information or data. You may instruct Vintro at any time not to share your personal information covered by this Privacy Policy with such Third-Party Providers by email to privacy@myvintro.com with your email address and “Do Not Share Personal Information With Select Partners” in the email subject. Please note that (i) this opt-out process may take some time to complete, consistent with applicable law; and (ii) even after such opt-out process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites under common ownership or control) and, to the extent permitted by law, designated service providers.

Vintro may also disclose your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule, or regulation, or in response to a subpoena, court order, or other legal process, subject to Vintro’s Law Enforcement Data Request Statement; (b) protect the interests, rights, safety, or property of Vintro, users or others; (c) monitor compliance with and enforce any terms of service on the Site; (d) provide our Services and products as may be operated from time to time (including allowing a purchaser of Vintro or a Vintro division to continue to serve you); (e) perform other activities related to the Site, Services and products, including, inter alia, billing and collection; (f) provide you with offers, promotions or advertisements from Vintro; or (g) operate the systems that provide the Site, our Services and products properly.

If you participate in certain features of the Site (e.g., posting or replying to Listings or sharing information related thereto), please note that any information you or others voluntarily disclose through use of these features, becomes available to the public and/or other users. If you choose to provide access to designated users or individuals, please be aware that any information you post will be visible to such parties for their use. Vintro is not responsible for information that you or others choose to disclose on the Site, and neither Vintro’s nor others’ use of such information is subject to this Privacy Policy.

The collection, further use, and/or disclosure of your information by Third-Party Providers or by other third parties is not the responsibility of Vintro. Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies.

Accuracy, Security, And Retention Of Your Personal Information

Any personal information you provide to Vintro is kept on secure servers. Vintro uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of the logon ID and password you may have set up in connection with your participation in the Site’s services. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or as permitted or required by applicable laws and regulations. However, despite our safeguards and efforts to keep information secure, no electronic transmission, storage technology or devices connected to the internet can be considered fully secure from the continually evolving threat and effort of hackers, cybercriminals, or other unauthorized third parties to defeat such security measures and improperly collect, access, steal, or modify such information.

When we will not continue to process your personal information, we will either delete or anonymize such information, where this is not possible (e.g., because such information has been stored on backup servers), we will securely store your personal information and isolate it from further processing until deletion is possible.

Rights With Respect To Your Personal Information

Depending on the jurisdiction, you may have the right to access, correct, delete, or restrict use of certain personal information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you exercise such rights this may affect our ability to provide our products and services.

For inquiries about your personal information, please contact us by clicking here. While Vintro will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. Please note that it may take some time to process your request, consistent with applicable law.

If you wish to at any time review or change the information in your account or terminate you’re your account, you can log into your account settings and update your account, subject to this Privacy Policy and the terms of service.

Your European Economic Area (“EEA”), Switzerland, and United Kingdom (“UK”) Privacy Rights

In addition, if you are a resident in the EEA or in the UK accessing the Site and Services lawfully and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:

EEA: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

UK: Data protection – GOV.UK (www.gov.uk).

In addition, if you are a resident in Switzerland accessing the Site and Services lawfully the contact details for your data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

Your California Privacy Rights

In addition, if you are a California resident, you may have the right, consistent with this Privacy Policy and applicable laws to request:

  • certain information about our collection, use, sale, or disclosure of your personal information
  • deletion of your personal information collected or maintained by us
  • to opt-out of the sale of your personal information

You also have the right to not receive discriminatory treatment for exercising these rights.

If you choose to exercise these rights, we ask you to provide sufficient information, including the products and services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, additional information may be requested.

You may use an authorized agent to submit a request on your behalf related to your personal information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.

To exercise a right related to your personal information, please contact us by clicking here. Vintro may share personal information related to tailored advertising, including online identifier, Internet Protocol address, device and Internet or other electronic network activity information, with third parties in ways that may constitute a “sale” under the California Consumer Privacy Act of 2018, as amended (the “CCPA”), to the extent the CCPA is applicable, for the purposes set out in this Privacy Policy. To opt-out of the re-sale (as defined under the CCPA) of your personal information by downstream participants who are signatories to the IAB Privacy, LLC’s Limited Service Provider Agreement (LSPA), please click here and opt-out on the listed digital property of the downstream participant.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Vintro to its affiliates and/or third parties for their direct marketing purposes.

To make such a request, please send an email with your first name, last name, mailing address, email address and telephone number to privacy@myvintro.com. Please include “California Privacy Rights” in the Subject line of your email.

You may also make such a request by writing to us at:

The Krowd Inc., dba Vintro
Attn. DPO
420 N Wabash Ave, 5th Floor
Chicago, IL 60611, USA

Transfer Of Your Personal Information To Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country which levels may well be less comprehensive that those in your country. By using our Site, services and products, you acknowledge and agree to such transfers and processing, including, inter alia, within, to and from the United States. Our primary servers are currently located in the United States; however, we may at any time without notification or consent change the location of our primary servers and backup servers and our affiliates, services providers or other third parties provided for in this Privacy Policy or in the terms of service may not be located in, operate in or may not operate servers or personnel located in the United States.

We implement appropriate safeguards, which may include, inter alia, European Commission standard data protection measures, to protect your personal information that is transferred between our group companies and between us and our third party providers. Vintro’s Intra-Group Personal Data Protection Statement provides additional information about the transfer (if any) of personal information from the EU, EEA and Switzerland (collectively, “EU”), or the United Kingdom, in accordance with the EU General Data Protection Regulation (“GDPR”) and UK GDPR, to the United States.

Links To Third-Party Services

Vintro may provide links or access to third-party websites or other digital properties, including social networking websites. Since we do not control third-party digital properties and are not responsible for any information you may provide while on such digital properties, we encourage you to read the privacy policies on those websites before providing any of your information on such digital properties.

Questions Regarding This Privacy Policy

If you have questions regarding this Privacy Policy, or wish to contact our Data Protection Officer (“DPO”) please contact us at privacy@myvintro.com. Please include “Privacy” or “Privacy DPO” (as the case may be) in the Subject line of your inquiry. If you have complaints about Vintro’s processing of your personal information, you may have the right to contact the applicable supervisory authority.

You can also contact us by post to:

The Krowd Inc., dba Vintro
Attn. DPO
420 N Wabash Ave, 5th Floor
Chicago, IL 60611, USA

Modifications To This Privacy Policy

Vintro reserves the right to update or change this Privacy Policy at any time. The updated version will be marked by a “Last Updated” date at the top of the Privacy Policy. Such changes will be effective upon posting without further consent or notice. We encourage you to review this Privacy Policy frequently. If we make material changes to this Privacy Policy we may in addition notify you by either posting a notice of such changes on the Site or by directly sending you a notification, such notices, for the avoidance of doubt, however, are effective irrespective of such notice being made, if any.