Who We Are

This Privacy Policy (“Policy”) describes how Vassa LLC dba VNTNA, along with its representatives, officers, shareholders, subsidiaries, affiliates, parents, employees, and agents (collectively “VNTNA” or “we” or “us” or “our”), uses and collects your personal information (defined below) on our Website and elsewhere. We may amend or change this Policy from time to time as set forth below and changes will be posted to our Website. This Policy is governed by our Terms of Use and capitalized terms not defined in this Policy are defined in the Terms of Use.

We may provide additional or supplemental privacy policies for specific Products that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process such personal information in the context of the specific Product.

Who You Are

We collect personal information from a few different types of people:

• Our customers and Website visitors.
• Vendors and third parties who perform services for us.
• Personnel who work for us.

Categories and Types of Information We Collect and Sources of Information

“Personal information” means any information relating to an identified or identifiable individual. To provide you with Products, including access to our Website, we need to collect and process some of your personal information.

We collect and retrieve your personal information in a number of different ways. Why we collect your information and what we do with it depends on the type of information. Below please find details regarding the categories and specific pieces of information that, alone or in combination, may be personal information.

• Personal and contact information, such as first and last name, alias, postal address, phone number, email address, month, day, photographs or images, gender, and fit and body measurement details for you or anyone else whose information you provide
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us via email, chat sessions, blog postings, phone calls, postal mail, or through any other channel with product questions, support questions, marketing preferences such as opt-in or opt-out choices, or with photographs or images
• User Content, such as information you post, publish, or otherwise provide through or on the Website that in your sole election may directly or indirectly identify you such as your name and photographs.
• Usage and Electronic information, such as information about how you use the Website and interact with us, page visit history, information you provide when you use any interactive features of the Website, IP address, cookie ID, and device type and hardware identifier for the device you used to access the Website, mobile identifiers, browser information and browsing history, IP address-based device geolocation information, and analytics information about your use of the Website
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications
• Social Media Information, such as information you voluntarily provide in support or help interactions with us, such as social media URL, social media alias, photographs and images, and other social media profile data
• Payment and Transaction information, such as billing address, generic payment type, last four of credit card if you opt in to provide such information for convenience during the purchase process, items in your cart, purchases you made, what you purchased, and when you made the purchase
• Mobile information, such as phone number, wireless carrier name, date, time, and content of text messages you send to us, and any other mobile information you provide, and any information that be collected by your wireless carrier in accordance with their terms
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection

Note regarding credit card information. Except as set forth above, we do not collect, receive, or use your credit card information, though a credit card is required to purchase some Products. We utilize vendors to process your credit card information to complete your purchases for Products and your choices regarding use of credit card information are described in the What Are Your Choices section below.

Note regarding fit and measurement details: We collect fit and measurement information for product representations. We may collect fit details you provide when placing an order to ensure that we provide you with Products in the proper size. You can choose to enter your fit details (height, body type, weight, and measurements) in your profile. We might receive your photographs as follows: if you post a photo review, if you email us your photo, if you accepted our request to use your photo from a third-party site (like Instagram), or if the photo is provided to us by a third party (such as a wedding photographer). We will never use your photograph without your express permission or when a third party indicates that it has your express permission to share your photograph with us. You may withdraw this consent at any time by emailing us at support@vntnaco.com or, in the case where we receive your picture through a third party, by contacting the third party and withdrawing your consent, or by changing your privacy settings on the third party website to prohibit us from being able to access the picture. With the exception of fit measurements for specific purchases, your provision of this information is completely optional and we will not use this information without your consent. You may withdraw your consent any time by emailing us at support@vntnaco.com

Information We Receive from Third Parties

In addition to receiving information directly from you or from data analytics services, we receive some personal information about you from third parties, including social media websites, marketing companies, and third-party cookies. We generally use this information to personalize your shopping experience and to provide you with information about our Products.

Recruiting Information

If you choose to apply to work with or for us through our Websites or by otherwise contacting us regarding opportunities to become an agent or contractor for us, we may collect the following:

• Contact Information, such as your first and last name, email and mailing addresses, phone number, professional title and company name
• Resume Information, such as qualifications, skills, employment or education history, or other resume information
• Reference information, such as name and contact details of your references
• Social Media Information, such as if you provide us a link to or other access to a social media account, we may collect or access any information you permit to be shared through or from your social media account and other information depending on the social media platform.

Referrals

Users of the Websites may have the opportunity to refer friends or other contacts to us or otherwise provide us personal information of others. You may only submit a referral or otherwise provide us personal information of others if you have permission to provide to us the individual’s personal information and by providing such information you represent and warrant that you have the authority to do so and to permit us and our service providers to use such information in accordance with this Policy.

How and Why We Use Your Personal Information

We may use your personal information, including as contained within your User Content, for the following purposes and as otherwise described in this Policy or at the time of collection:

To complete transactions. We use your personal information to process transactions including to help you select, purchase, return, and exchange items, to ship items, to provide support regarding purchases or inquiries regarding our items, to help others select Products based on various factors, and to administer our loyalty program(s)

To operate the Websites. We use your personal information to:

• provide, operate and improve the Websites, including to publish your User Content which will become available to other users of the Websites and the internet in general and otherwise use your User Content in accordance with the Terms of Use
• provide information about our Websites
• communicate with you about the Websites, including by sending you announcements, updates, security alerts, and support and administrative messages
• communicate with you about events or programs in which you participate
• understand your needs and interests, and personalize your experience with the Websites and our communications
• provide support and maintenance for the Websites
• respond to your requests, questions and feedback
• fulfill our obligations and enforce rights contained in agreements between you and us
• display certain of your personal information to other users of the Websites as set forth in this Policy
• allow you to save, organize, recall, and share items you’ve selected

To send you marketing and promotional communications. We may send you marketing communications via different channels as permitted by law, such as through emails and online advertisements which may contain Product recommendations based on items you viewed and Products related to those items. You will have the ability to opt-out of our marketing and promotional communications as described in the What Are Your Choices and Text Message Terms sections below. We may use your personal information to develop our marketing plans and strategies for sending marketing and promotional communications to others.

For research and development. We may analyze use of the Websites to improve them, to develop new websites or Products, and to develop business expansion plans. We may use your User Content for product development purposes such as to create new Products.

To process applications.

We may use your personal information to review and evaluate your applications to work with or for us or otherwise respond to you regarding opportunity inquiries.

To display advertisements. We may work with advertising partners to display advertisements on the Websites or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Websites or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Cookies & browser web storage and targeted online advertising.”

To comply with law. We may use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Websites; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and (d) conduct, complete, or respond to audits or audit results.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by applicable law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We process personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes and as set forth in this Policy.

To conduct training. We may use your information to train our personnel and to help develop their skills.

For other business purposes. Subject to this Policy, we may use your personal information to engage in other legitimate purposes as required or permitted by applicable law.

Information We Share

Except as otherwise set forth in this Policy, we will not provide access to your personal information, including as contained within your User Content, to third parties for any unauthorized purpose.

Service Providers. We work closely with third-party providers (our “vendors”) for a variety of purposes, including assisting us to perform and improve our Websites, to deliver your orders, and to provide advertising and email services. These vendors include hosting companies, payment processors, research companies, marketing providers, customer support providers, and analytics and security providers. These third parties have limited access to your information and may use your information only to perform these tasks on our behalf. We make sure our vendors have contractually agreed to implement technical and organizational measures that are appropriate under this Policy. As a result of how “sale” may be defined in certain laws, our sharing of your personal information with certain advertising-related service providers may be deemed a “sale.” For details, please see the Section below, “Your California and European Privacy Rights.” We may share demographic information about our Website visitors with vendors, but it will be aggregated and de-personalized first.

Business Transfers. Your information will remain subject to the terms of this Policy even if we undergo a business transition. However, we may transfer your information to a successor person or entity upon an acquisition or other corporate reorganization.

Compliance, fraud prevention, and safety. We may also disclose your information if we have a good faith belief that we are required to do so by law or if acting with a good faith belief that such disclosure is reasonably necessary to: (1) comply with legal process; (2) enforce our Terms of Use; (3) respond to legal claims; or (4) protect our, our Websites’, or other individuals’ or the publics’ rights, property or safety.

Affiliates. We may share your personal information with corporate affiliates (e.g., sister companies, subsidiaries, joint ventures, or other companies under common control) for purposes consistent with this Policy. This shared information may include email address, phone number, transaction information, and electronic identifiers. As a result of how “sale” may be defined in certain laws, our sharing of your personal information with affiliates may be deemed a “sale.” For details, please see the Section below, “Your California and European Privacy Rights.”

With your consent. We may otherwise share your personal information with your consent or pursuant to your instructions.

With other users. We may share your personal information as part of the Websites’ operation and depending on certain Website features you and other users elect to use.

For other business purposes. We may share your personal information for other legitimate purposes as required or permitted by applicable law.

Your Choices

Choosing not to share your personal information. You may choose not to provide Personal Information, including when creating and providing User Content. If you choose not to provide Personal Information (or ask us to delete it), we may not be able to provide you with our Products. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Updating your personal information. Much of your information is stored in your account profile for as long as your account is active. You may change or correct the information in your account profile by clicking on ACCOUNT on our Website.

Opt out of marketing communications. You may opt out of marketing-related email and text messages by following the opt-out or unsubscribe instructions in the communication, or by contacting us as set forth below, or for text messages, as set forth in the Text Message Terms below. If you opt out of marketing communications, you may continue to receive Service-related and other non-marketing emails.

Cookies & browser web storage and targeted online advertising. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Websites and third-party websites or applications. If business partners collect information about your activities on or through the Websites, they may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. 

Credit Card Information. Our vendors may collect and use your credit card information to complete transactions for Products you purchase. These vendors may save your credit card information for your convenience to ease the purchasing process for subsequent transactions. We do not collect, use, or store your credit card information, except the limited information set forth above. You may be able to configure settings with these vendors to change or remove your saved credit card information in accordance with the terms of those vendors. Please visit their websites for more details.

Personal Information of Children and Minors

The Websites are general audience websites and are not directed to individuals under the age of 18 or who have not reached the age of majority in their jurisdiction (“Minors”), and such individuals are not permitted to use the Websites, and we do not intentionally collect personal information from them.

If we learn that we have collected personal information of a Minor without the consent of their parent or guardian, we will delete it and terminate any applicable user accounts. If you have determined that we have processed such personal information or have any questions related to our processing of personal information of Minors, please contact us as set forth below.

Security, Storage, and Retention

How We Protect Your Information

We are committed to protecting your personal information. We implement technical and organizational measures designed to secure personal information. In assessing the appropriate level of security, we take account of the risks that are presented by processing this information, in particular risks from accidental or unlawful destruction loss, alteration, unauthorized disclosure of, or access to personal information we transmit, store or otherwise process. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Where We Are Located

We are located in the United States and we store your information in the United States. Third parties with whom we may share your information in accordance with the Section “Information We Share” may store your information in other countries. By using our website and/or providing us with information, you are agreeing to transfer and store your data in the United States or other countries.

Retention of Your Information

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of providing you the Websites, completing transactions for Products with you and supporting prior or contemplated transactions with you, satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible, securely store it in accordance with this Policy and cease use of the personal information until deletion is possible. If we deidentify your personal information (so that it can no longer be associated with you), we may retain this information for longer periods.

Third Party Websites

The Websites may contain links to other websites. Other websites we link to include social platforms. We also use third-party plug-ins in certain places on our Website. For example, when you click on an icon on our Website to share our Products on a third party social platform, you are also loading content from that third-party platform. That website may request cookies directly from your browser. These interactions are subject to the privacy policy and terms of service of the third-party site and not ours. We are not responsible for the privacy practices or the content of such services. We do not make any representations regarding the policies or practices of third parties. When you use third-party websites or services, their own terms and privacy policies will govern your use of those websites or services. We encourage you to read the privacy policies of third parties before disclosing personal information to them.

Your California and European Privacy Rights

If you are located in California, the European Economic Area, or the United Kingdom, please see our Regional Privacy Policy Supplement for further information, including how to exercise your applicable rights.

Changes To This Privacy Policy

The Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this webpage. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way if and as required by law (for example via a notice or banner on our Website or via email to you).

Contact

You may contact us regarding this Policy or our processing of your personal information by emailing us at support@vntnaco.com. You may also exercise your rights as set forth in the Regional Privacy Policy Supplement

Last modified: September 28, 2023