Vincent Labs, Inc. and its affiliates and subsidiaries (collectively, “Vincent”, “we”, “our” or“us”) are committed to protecting your privacy. Vincent may collect information relating to you as an individual including certain sensitive personal information, where permitted by law (your “personal information”). This privacy policy (the “Privacy Policy”) describes the ways in which we collect information from you, including specifically when you use our website (“Website”), and what we may use it for. This Privacy Policy also applies to our collection and use of information in the normal course of business. This Privacy Policy is at all times subject to any applicable requirements of local law and regulation.
This Privacy Policy describes:
We may collect personal informationfrom you in the course of our business, including through your use of our Website,by our useof cookies, and when you contact or request information from us. Much of that data comprises business information, but some of that data may inevitably comprise your personal information. The personal information we may collect and use includes:
We collect information or data from you in various ways, including:
We collect and use data collected from you (however collected), including any personal information, for the following legitimate business purposes of Vincent:
You may use the Website without providing us with your personal information. However, some features on the Website allow you to provide us voluntarily with personal information. If the provision of your personal information is mandatory for a specified purpose, we will let you know that this is the case and inform you of the consequences of failure to provide such personal information.
In order to subscribe to a newsletter or attend events hosted by us, such as webcasts, the following information maybe required: first name; last name; email address; company name, title, city and country. If the required data is not supplied, the newsletter or events will not be made available to you.
We will collect and process personal information about you in relation to your attendance at an event or seminar organized by Vincent or its business partners. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organizing or hosting the relevant event.
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our users. We will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, repetitional and financial checks.We may also process personal information provided to us by you or on your behalf for the purposes of providing our products or services to you. The information may be disclosed to third parties to the extent we think it is reasonably necessary in connection with provision of our products or service. Please also see “Who we share your personal information with” and “Which countries we transfer your personal information to” below.
If you have already signed up or subscribed to receive materials from us, we may use your personal information in order to send you electronic materials relating to Vincent or alternative investments, our newsletters and other products and services and to update records held by us. If you are not already signed up or subscribed to receive information or materials from us and wish to do so, or if you wish to subscribe to additional publications, please sign up here using this link.
You may withdraw your consent to the receipt of materials or newsletters at any time and free of charge by clicking on the “unsubscribe” link in the email, or by sending an e-mail to help@withvincent.com.
Vincent may in the future re-organize or transfer all or part of its business which may result in the transfer of your personal information to new entities (which will be subsidiaries or affiliates of Vincent) or third parties through which the whole or part of the business of Vincent will be carried out. If Vincent ceases to trade, or becomes insolvent, enters into receivership or any similar or equivalent event occurs, those acting on behalf of Vincent may sell the business or partsof it to a third party, in fulfillment of legal or business requirements. This may result in the transfer of your personal information to a third party through which the business or parts of it will be carried out.
We use your personal information on the following bases:
Vincent endeavors to ensure that personal information is kept up-to-date and that irrelevant, excessive orout-of-date personal information is updated or deleted. To determine the appropriate retention period for your personal information, we will 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 the personal information and whether we can achieve such purposes through other means, the applicable legal and regulatory requirements (including requirements to retain the personal information for a minimum period), limitation periods for taking legal action, good practice and Vincent’s business purposes.
Personal information may be shared with other non-affiliated third parties, including:
Vincent may use social media sites such as Facebook, LinkedIn and X (formerly known as Twitter). If you use these services, you should review their privacy policies for more information on how they deal with your personal information.
We may share or otherwise make personal information available to our affiliates and subsidiaries for commercial use in their business activities and operations.
We will not sell, rent, distribute otherwise make personal information commercially available to any third party except with your prior permission.
We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
The Internet is a global environment and Vincent’s principal place of business is in the United States of America.In certain circumstances, we may need to transfer personal information to locations outside the local jurisdiction in which you are viewing the Website and process personal information outside that jurisdiction for the purposes set out in this Privacy Policy.
International transfers to third parties
Some of the third parties to whom we may transfer your personal information for the purposes described above maybe located in countries or territories which are outside your local jurisdiction and specifically outside the EEA and the United Kingdom. The data protection and privacy laws in those jurisdictions may not provide for the same level of protection of your personal information as exists in your home country or in the EEA.
Please note that any electronic communication made between you and us, including via the Website, may not be secure. While we welcome you to contact us, please do not send us any electronic communication that contains any confidential or sensitive personal information or data.
Subject to the provisions of local laws and regulations from time to time, you may be entitled:
You may also have the right to lodge a complaint in relation to Vincent’s processing of your personal information with a local supervisory authority.
Last Updated: November, 2023
This Supplemental Notice of Collection of Personal Information and Privacy Policy (the “CPRA Notice”) applies to the collection of personal information from California residents on and afterJanuary 1, 2023. The CPRA Notice supplements our “Privacy Policy” set forth above to provide California residents with information and rights required by the California Privacy Rights Act (the “CPRA”). The Privacy Policy applies only to individuals residing in the State of California who are considered“consumers” under the CPRA and from whom we collect “personal information” as described in the CPRA.
The CPRA Notice describes the types and categories of personal information we collect, the business purposes for which we collect, use and disclose your personal information and your rights in personal information under the CCPA. We do not share your personal information with third party advertisers for cross context behavioral advertising within the meaning of the CPRA. We do not sell your personal information. We may disclose your personal information, but such disclosures are limited to our service providers and contractors, except where disclosure is required by law, court rules, or applicable rules of professional responsibility to a third party or you provide consent for such disclosure.
For purposes of this CPRA Notice, we refer to personal information according to the following definition given in the CPRA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or household.Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CPRA. By accessing our Website, using our services or submitting personal information to us, you consent to the collection, use and disclosure of such information as set forth in this CPRANotice, as it may be updated from time to time.
We may collect personal information from you in the course of our business, including through your use of our Website, by our use of cookies when you contact or request information from us, when you engage our services or as a result of your relationship with one or more of our staff and customers. Much of that data comprises business information, but some of that data may inevitably comprise your personal information.
The categories of personal information we may collect and use includes:
| Categories | Examples | Retention Period | Sell/Share to Third Parties |
|---|---|---|---|
A. Identifiers | This information may include name and contact details (including addresses, telephone numbers, email addresses, IP address, titles and other identifying information). | For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law. | No |
B. Customer Information under California Civil Code §1798.80(e) | This information comprises any information that identifies, relates to, describes or is capable of being associated with you in our records. Examples include financial, banking and payment-related information, your signature, identification and background information provided by you or collected as part of our business acceptance processes, including identifying numbers, personal information provided to us by or on behalf of our customers or generated by us in the course of providing our services. Some personal information in this category may overlap with other categories | For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law. | No |
C. Protected Characteristics under California or federal law. | Such as race, color, national origin, gender, citizenship, ethnicity, disability, sexual orientation, veteran or military status, religion, or marital status collected in the course of providing our services to you. | For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law. | No |
D. Commercial Information | Information and records concerning the services we provide to you, including billing information. | For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law. | No |
| E. Internet and other electronic history | This category comprises electronic information concerning your use of the Website (https://www.withvincent.com) and dependent pages. We may collect logs of emails and internet use, including your use of the Website, technical information, such as information from your visits to our Website or applications or in relation to materials and communications we send to you electronically. | Generally, for approximately as long as one (1) year | No |
| F. Educational Information | Sign-up and other educational records and related information may be collected in connection with the services we provide to you | For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law. | No |
G. Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes | We may accumulate the information you provide in the normal course of the services we provide to make inferences concerning your preferences, characteristics, behavior, abilities and aptitudes. This may include information you provide to us for attending meetings and events, including access and dietary requirements. Similarly, we may develop and communicate marketing and other informational materials concerning our services based on information you provide (e.g., requests to subscribe to certain blogs). | For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law. | No |
In the past twelve (12) months, depending on the individual circumstances, we may have collected the following categories of personal information: [A-F].
We do not collect sensitive personal information for purposes of inferring characteristics.
Depending on the individual circumstances, we collect and use personal information collected from you(however collected), including any personal information, for the legitimate business purposes of Vincent as set forth above. See the sections: How We UseYour Personal Information, Subscriptions to newsletters, Meetings, events and seminars, Other services, Marketing, Business re-organization, and Use ofCookies.
Vincent collects personal information from the following categories of sources:
We do not “sell” your personal information to, or “share” your personal information with third parties within the meanings of those terms under the CPRA.
In some instances, we may retain other companies and individuals to perform functions on our behalf as “service providers” or “contractors” within the meanings of those terms under the CPRA, including, but not limited to, Information Technology and software providers, website analytics providers and web hosting platforms. Such service providers or contractors may be provided with access to your personal information to perform the functions for which they have been retained.
We will not disclose personal information commercially to any “third party” within the meaning of this term under the CPRA except with your prior permission or where required by law, court rules, or applicable rules of professional responsibility. See the section: Transfers of data to third parties.
In the past twelve (12) months, depending on the individual circumstances, we have not disclosed the categories of personal information collected in Categories [A-F] with outside organizations or entities who are not service providers or contractors providing services on our behalf, except where required by law, court rules or applicable rules of professional responsibility, including but not limited to disclosures that may be permitted or required under rules of civil or criminal procedure. In such circumstances, we have disclosed personal information to the following third parties: courts, regulators, law enforcement and opposing parties among others.
Under the California Privacy RightsAct, you have the following rights in personal information held by us:
You may submit verifiable requests concerning any of your rights by contacting us by e-mail to: legal@withvincent.com or by mail at the address below. We will use reasonable methods for verifying that the person making a request to know, data portability, request to corrector a request to delete is the individual about whom we have collected personal information.
This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you may be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.
We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten (10) business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five [45] calendar days of the request. If we need additional time to respond to your request beyond the forty-five [45] calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five (45) calendar days to respond to your request.
Persons with disabilities who need assistance accessing this CCPA Notice may contact us as provided for above, and depending on your individual needs, Vincent will grant reasonable requests to furnish this policy in an alternative format.
We do not knowingly collect PersonalInformation from children under the age of 13. We do not sell any personal information, including the personal information of minors under 16 years of age.
We do not sell your personal information to third parties, regardless of the state in which you reside. However, we are required to give this notice to Nevada residents: If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at legal@withvincent.comwith the subject line “Nevada Do Not Sell Request” and providing us with your name and email address.
We may collect data that may include your personal information by sending “cookies” to your browser, which will store them in your device (e.g., computer, phone, etc.) in order to facilitate your browsing.
A cookie is a small chunk of information sent by our web server to the web browser software that you are using to access the Website. A cookie enables our web server to collect information from your web browser software.
We collect user permission for our use of cookies through a clear notice in the form of a website banner that appears when users view the Website, giving users the option to accept the use of cookies. You are also able to opt-out of the use of non-essential cookies, through options made available on the Website banner.
All Vincent servers and computer systems are designed to be protected from outside intrusions. As a result, all data that may be collected about users through the use of cookies should be protected from unauthorized access.
The data collected through cookies placed on your device will not be kept for longer than is necessary to fulfil the purposes mentioned above; in particular, cookies that we place automatically expire in accordance with the timeframes described above.
You can also change your cookie settings on your browser to block the recording of cookies on your hard drive, in order to minimize the amount of data that may be collected about your navigating on the Website. The procedure for blocking cookies may vary ford ifferent software products. Please check your Internet browser software or with your software supplier if you wish to block cookies. However, disabling cookies may result in certain features of the Website not working, so for optimal use of the Website, we recommend that you do not disable cookies on your device.
