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Privacy Policy



Vylla Holdings, LLC (“Vylla”) operates the web site at www.vylla.com (“Site”). We respect the privacy of each user of the Site (referred to as “you” or a “user”). This Privacy Policy gives you specific information about how we protect privacy, how we treat information we collect on the Site that identifies an individual user (“Personal Information”), and how we use aggregated information.

Please see our Federal Privacy Opt Out for an explanation of what Vylla does with your personal information and the steps to take to limit the sharing of your information. For California residents, please see our California Privacy Opt Out.

BY REGISTERING FOR OR USING THE SITE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU CANNOT USE THE SITE. We reserve the right to modify this Policy at any time by posting a notice on the Site’s home page. Your use of the Site after the date of the last modification listed at the beginning of this Privacy Policy indicates to us that you agree to the changes.

Location of Servers and Transfer of Information to the United States

The Site is hosted by servers in the United States. If you are located outside of the United States, your Personal Information will be transferred to the United States. By submitting your Personal Information, you consent to its transfer to the United States and to its storage, processing and use there in accordance with this Privacy Policy.

Scope of this Privacy Policy

This Privacy Policy applies to your use of this Site only. We do not own, operate or control the web sites of third parties. Accordingly, this Statement does not apply to such parties’ web sites or their respective collection, use, storage and disclosure of your Personal Information.

1. Collection and Use of Your Personal Information

  • We collect Personal Information from you only when you voluntarily submit it in order to obtain certain information, including without limitation (A) requests to find out more about our programs; (B) requests to contact us; and (C) requests to forward your information to one of our affiliates. Such information may include first and last name, e-mail address, home address, phone numbers, social security number, or other physical and digital identifiers.

  • We honor all “do not track” requests and settings. If you use any signal(s) or other mechanism(s) that provides you the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services, we will not attempt to override such signals or mechanisms, nor will we track your use of any such signal or mechanism. When you use our website, no other parties can collect personally identifiable information about your online activities over time and across different websites. Your choice is indicated by your settings in your web browser. A “do not track” indication sent from your web browser will result in any tracking activity (i.e., tracking cookies) within the website to be programmatically disabled.

  • Contacting Us: If you contact us, we collect Personal Information, which is retained or referred to the appropriate department for research and a response. The information we collect is not used in any other way.

2. Collection of Non-Personal Information

  • Even if you do not send us any Personal Information, we may collect information about how you use our site (“Non-Personal Information”). This information cannot be used to identify you personally and is explained in more detail below under “Non-Personal Information”.

  • Cookies A cookie is a small data file, often including an anonymous unique identifier that is sent from a web site’s computer and stored on your computer’s hard drive. Use of cookies is common on the Internet. A web site can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser permits a web site to access only the cookies it has already sent to you, not the cookies sent to you by other sites. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You can reset your browser to refuse all cookies or indicate when a cookie is being sent. But if you refuse cookies, some parts of the Site may not function properly and may not provide services or information you have requested.

  • Non-Personal Information Like many sites, we obtain Non-Personal Information such as IP (internet protocol) addresses, browser types, the name of your ISP (internet service provider), information about where a user comes from before arriving at our Site, what pages a user visits, the order of those pages, and the amount of time spent on each. A vendor performs this service for us by sending a cookie to gather this information, compile it, and report to us. We use Non-Personal Information to customize the advertising and content you see, improve our services, conduct research, and provide anonymous aggregated reporting for internal audits and third-parties.

  • Opting Out of Third-Party Ad Servers If you want to prevent a third-party ad server from sending and reading cookies on your computer, currently you must visit each ad network’s web site individually and opt out (if they offer this capability).

3. Use of Information

  • We use the Personal Information and the Non-Personal Information we collect on the Site (A) to answer your questions or address your inquiries, and (B) for analytical purposes to help us improve the Site and for our business generally.

  • In order to provide efficient and reliable services and to improve product and service options available to you, one or more of Vylla’s affiliates may be given, or given access to, your Personal Information. When so sharing your Personal Information, we adhere to applicable legal and industry standards regarding the protection of personal information.

  • You should know that neither Vylla nor its affiliates will sell your Personal Information.

4. Sharing Your Information

We do not rent, sell, or share with third parties the Personal Information we collect from you on this Site except (i) to provide information or services that you have requested, (ii) with your permission, or (iii) under the following circumstances:

    • Third party vendors we engage to provide services on our behalf, such as hosting, web-site development, and support, have access to Personal Information, but they have agreed not to disclose the Personal Information or to use it for any purpose other than providing the requested services.

    • There may arise special circumstances where it is necessary for us to disclose and use Personal Information and Non-Personal Information, such as: to enforce this Privacy Policy or any other part of our Terms of Use; to protect our property or rights; to protect the safety of anyone; to investigate, prevent, or take action regarding illegal or improper activities; to carry out a merger or consolidation with another entity, a sale or transfer of some or all of our assets, or any similar transaction; or for other reasons we determine in good faith are necessary, appropriate, or required by law, such as when we respond to subpoenas, court orders, or other legal or administrative process.

This Site contains links to affiliate web sites. When you click on those links, you will go to an affiliate site where you will be subject to that site’s Privacy Policy and we encourage you to read that policy statement. Please be aware that we are not responsible for the privacy practices of those other web sites and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Information by those third parties. We remind you to be aware of when you leave our Site and enter an affiliate web site and again encourage you to read the Privacy Policy on any web site that collects your Personal Information.

5. Security

Our hosting services maintain their systems in accordance with reasonable industry standards to reasonably secure the information of its customers. However, no data transmission over the Internet can be guaranteed to be 100% secure. “Perfect security” does not exist on the Internet, and you use the Site at your own risk.

6. Correction/Updating Personal Information

If your Personal Information changes or if you no longer wish to use the Site, you may correct, delete or update your Personal Information by writing to us at:

Vylla Holdings, LLC
Attention: Compliance
25 Enterprise, 5th Floor
Aliso Viejo, CA 92656
Or e-mail [email protected]

7. Children

This Site is not directed to children under the age of 13 (“Children”), and we do not knowingly collect any information, including Personal Information, from Children.

8. California Privacy Rights

Under California law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail 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 (2) the names and addresses of all such third parties.

To request the above information please contact us by writing to:

Vylla Holdings, LLC
Attention: Compliance
25 Enterprise, 5th Floor
Aliso Viejo, CA 92656
Or e-mail [email protected]

We will respond to such requests within 30 days of receipt. Please note that we are only required to respond to each customer once per calendar year.

9. Comments and Questions

If you have any questions or concerns about this Privacy Policy, please contact us by postal mail at:

Vylla Holdings, LLC
Attention: Compliance
25 Enterprise, 5th Floor
Aliso Viejo, CA 92656
Or e-mail [email protected]

10. International Use, Governing Law and Forum

Vylla makes no claims that materials on the Site are appropriate or may be downloaded for use in locations outside the United States. Access to the Site may not be legal from countries or territories where such access is illegal or prohibited. Those who choose to access the Site outside the United States do so on their own initiative and are responsible for compliance with local laws.

This Privacy Policy and the resolution of any dispute related to this Privacy Policy shall be governed by and construed in accordance with the laws of the State of New York without giving effect to any principles of conflicts of law and the venue for any disputes shall be in New York County, New York.