Privacy Policy

This Privacy Notice describes how Virtual Alchemy S.R.L (“Virtual Fashion”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our website https://thevirtualfashion.com (the “Site”), and the related content, platform, services, and other functionality offered on or through our online services.

I. What is Personal Information?

When we use the term “Personal Information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

II. Collection and Use of Personal Information

When you use our Services, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. See the list below for more information about what Personal Information we collect and why.

Information That You Provide

We collect Personal Information from you. The categories of information we collect can include:

Account Information

Examples of Personal Information collected: name, email, address, phone number.

Purpose of collection: to provide products or services to you to fulfill our contract, manage your account, to provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

Order Information

Examples of Personal Information collected: name, billing address, shipping address, payment information, email address, and phone number. Note we use third-party payment processors to process your payments. Because we use third-party payment processors, we do not retain any personally identifiable financial information such as credit card numbers. Rather, all such information is provided directly to the third-party processor. The payment processor’s use of your Personal Information is governed by their privacy notice. Please review each processor’s privacy notice to understand how they will manage or otherwise process your Personal Information, including your financial data.

Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

Communications and Customer Support Information

Examples of Personal Information collected: name, billing address, shipping address, email address, phone number, or any other Personal Information you choose to provide us.

Purpose of collection: to provide customer support, to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization. If you register for our newsletters or updates, we may communicate with you by email.

AR Features (Photos and Images)

Examples of Personal Information collected: individual photos which may include backgrounds or other objects by which your general location could be derived.

Purpose of collection: to provide products or services to you to fulfill our contract.

Marketing emails

Examples of Personal Information collected: email and applicable interests and communication preferences.

Purpose of collection: send you regular updates about our products or services, manage our communications with you, and send you information about products and services we think may be of interest to you.

Personal Information Collected from Other Sources and Third Parties

Although we often collect the Personal Information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, as noted below. Please note that our systems may record Personal Information that you type into our websites and other online Service even if you do not choose to submit it.

Account Creation / Single Sign-On. We may use single sign-on (“SSO”) to allow a user to authenticate their account through their work email. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties.

Examples of Personal Information collected: username, password, name, email address, and profile picture.

Purpose of collection: We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Site, technical and security notices).

Social Media: When you interact with our Service through various social media, such as when you click on the social media icon on the Service, follow us on a social media site, or post a comment to one of our pages.

Examples of Personal Information collected: profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. The data we receive complies with your privacy settings with the social media network.

Purpose of collection: We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Information from Other Sources. We may obtain information from other sources, including through third-party information providers, customers, public sources, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined Personal Information. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Personal Information Automatically Collected

As is true of most digital platforms, we and our third-party providers and partners collect certain Personal Information automatically when you visit or interact with our websites and:

Log Data: Including your internet protocol (IP) address, operating system, browser type, browser ID, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our Service and any errors that may occur during your visit to our Service.

Analytics Data: Including the electronic path you take to our Service, through our Service and when exiting our Service, as well as your usage and activity on our Service, such as the links, objects, products and benefits you view, click or otherwise interact with (also known as “Clickstream Data”). This data will allow us to better understand how you are using our Service and help improve your user experience

Location Data: Including your general geographic location based on the Log Data we collect or more precise location when permitted by law.

Application Data: Some of our services offer mobile or browser applications to allow you to take advantage of our service offerings on the go and/or when visiting third-party websites and other online services. Certain of these applications also allow us to access more precise Location Data about you and collect information about your use and interactions with third-party websites and online services (including the products or services you are interested in or purchase) to better serve you. We, and our third-party partners such as Snap (through the use of the SnapCamera Kit to power the features of the AR technology) and Apple (through the use of the TrueDepth camera to improve the quality of the lenses), may also collect metadata included in the photos and images that you upload, such as your device model, camera type, camera settings (e.g. ISO, shutter, focal length, lens, aperture), image information (e.g. format, file size, date and time, resolution) or location data (e.g. geotagging).

For information about our, and our third-party providers and partners’, use of cookies and related technologies to collect information automatically on our online Service, and the choices you may have in relation to those practices, please visit our Cookie Notice.

Other Uses of Personal Information

In addition to the uses described above, we may collect and use Personal Information for the following purposes:

For our business activities, including to operate the Service and to provide you with the features and functionality of the Service;

To communicate with you and respond to your requests, such as to respond to your questions, contact you about changes to the Service, and communicate about account related matters;

For marketing and advertising purposes, such as to market to you or offer you with information and updates on our products or services we think that you may be interested in. While we may use your Personal Information in this manner, please note that we do not use User Content to serve you ads, and we will never share User Content with any third parties for marketing or advertising purposes, unless you have explicitly submitted it to us for that purpose;

For analytics and research purposes;

To enforce our Terms and Conditions to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;

To comply with contractual and legal obligations and requirements;

To fulfill any other purpose for which you provide Personal Information; and

For any other lawful purpose, or other purpose that you consent to.

III. How We Share Personal Information

We may also share, transmit, disclose, grant access to, make available, and provide your Personal Information with service providers and business partners to help us provide our services and fulfill our contracts with you, as described above. For example:

We use WordPress to power our online store. You can read more about how WordPress uses your Personal Information here: https://wordpress.org/about/privacy/

AR Providers. As part of the Service, we use augmented reality (AR) to enhance your photos and images and integrate The Virtual Fashion products. As described in the Collection and Use of Personal Information section, we use business partners such as Snap and Apple. Any information shared with Snap, Apple, or any of our third party business partners is subject to their privacy policy.

Service Providers. We share Personal Information with third party contractors and service providers who perform services on our behalf, which are subject to reasonable confidentiality terms, and which may include processing payments, shipping partners, AR features and technology, providing web hosting services, technology support providers, email communications providers, analytics providers, data storage providers, and web and video hosting providers and developers.

Online Advertising Partners. We also share Personal Information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please see our Cookie Notice.

Legal Requirements. We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights, including enforcing our Terms of Service or other agreements, or protect the security or integrity of the services.

Corporate Transaction. We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Notice.

Consent: We may disclose Personal Information about you to certain other third parties with your consent.

Aggregated and Anonymized Information: We may share your Personal Information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

IV. Control Over Your Information.

Email Communications. From time to time, we may send you emails regarding updates to our Site, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through the [“profile,” “account,” “settings,” or “preferences”] options provided on the Site. If you would like to request access to, or correction or deletion of Personal Information, you may send your request to us at the email provided below. We will review your request and may require you to provide additional information to identify yourself, but we do not promise that we will be able to satisfy your request.

SMS Text Communications. You may opt-out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional SMS text messages will not prevent you from receiving SMS texts from The Virtual Fashion directly relating to purchase or service communications such as account verification information. To unsubscribe from promotional SMS texts, email hello@thevirtualfashion.com and provide your phone number and opt-out preference or reply STOP to one of our commercial text messages. For more information, see our Terms and Conditions.

V. Children’s Personal Information

Our Service is not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If you are under the age of 13, please do not use our Site or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information.

VI. Third-Party Websites

Our Site may include links to or redirect you to third-party websites, plug-ins and applications, including social media services where you may connect with us. Third-party websites may also reference or link to our websites and online service. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online service or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy notices or policies

VII. Updates to this Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Service, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

VIII. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to contact@thevirtualfashion.com

VIRTUAL ALCHEMY

J23/5373/2021

CUI: 44833959

Adress: Str. INT. REZERVELOR, Nr. 6, județ ILFOV

Phone: +40 728 234 732

Romania

PRIVACY DISCLOSURES FOR THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM AND SWITZERLAND

Personal Data: When we use the term “personal data” in this section, we mean information relating to an identified or identifiable natural person.

1. PERSONAL DATA WE COLLECT FROM YOU WHEN YOU USE THE VIRTUAL FASHION, AND HOW WE USE IT

We collect the categories of personal data that you voluntarily submit directly to us when you use the European Services, as set forth in our Privacy Notice under the section entitled Collection and Use of Personal Information. The table at Annex 1 sets out in detail the categories of personal data we collect about you and how we use that information when you use the European Services, as well as the legal basis which we rely on to process the Personal Information and recipients of that Personal Information.

2. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY

We also automatically collect Personal Information indirectly about how you access and use the European Services, and information about the device you use to access the European Services. For example, we may collect:

information about the features you use and the pages you view on the European Services;

information about your device (such as your IP address, device identifier, device type, model and manufacturer); and

information about your usage patterns (such as how often you use the The Virtual Fashion European Services and your language settings).

We use this information to provide you the features and functionality of the European Services, to monitor and improve the European Services and to develop new services.

We may link or combine the Personal Information we collect about you and the information we collect automatically.

3. HOW LONG WILL WE STORE YOUR PERSONAL INFORMATION

We will usually store the Personal Information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2, in accordance with our legal obligations and legitimate business interests.

The criteria used to determine the period for which Personal Information about you will be retained varies depending on the legal basis under which we process the Personal Information:

(a) Legitimate Interests. Where we are processing Personal Information based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.

(b) Where we are processing Personal Information based on your consent, we generally will retain the information until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that Personal Information.

(c) Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.

(d) Legal Obligation. Where we are processing Personal Information based on a legal obligation, we generally will retain the information for the period of time necessary to fulfil the legal obligation.

(e) Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the Personal Information, as well as the potential risk of harm from unauthorised use or disclosure of your Personal Information.

4. RECIPIENTS OF PERSONAL INFORMATION

(a) Service providers and advisors: we may share your Personal Information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.

(b) Affiliates. Other companies owned by or under common ownership as The Virtual Fashion, including our subsidiaries (i.e., any organisation we own or control) and our ultimate holding company (i.e., any organisation that owns or controls us) and any subsidiaries it owns. These companies will use your Personal Information in the same way as we can under these Privacy Disclosures.

(c) Purchasers and third parties in connection with a business transaction: your Personal Information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(d) Law enforcement, regulators and other parties for legal reasons: we may share your Personal Information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms; and/or (iii) exercise or protect the rights, property, or personal safety of The Virtual Fashion, its users or others.

5. MARKETING AND ADVERTISING

From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services. Most marketing messages we send will be by email. For some marketing messages, we may use Personal Information we collect about you to help us determine the most relevant marketing information to share with you.

Where we rely on consent to send you marketing communications, we will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences via your account on the Site.

6. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

Security. We implement appropriate technical and organisational measures to protect your Personal Information against accidental or unlawful destruction, loss, change or damage. All Personal Information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card information or national identification numbers.

International Transfers of your Personal Information. The Personal Information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. Your Personal Information may be processed outside your region, including in Romania.

In the event of such a transfer, we ensure that: (i) the Personal Information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.

If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of these Privacy Disclosures.

7. PROFILING

We may analyze personal data we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively send product updates. We may also use personal data about you to detect and reduce fraud. and credit risk.

8. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law, you have the following rights in respect of your Personal Information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your Personal Information;

(ii) information about the categories of Personal Information we are processing, the purposes for which we process your Personal Information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your Personal Information; and

(iv) a copy of the Personal Information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.

(f) Right to withdraw consent. There are certain circumstances where we require your consent to process your Personal Information. In these instances, and if you have provided consent, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your Personal Information before your withdrawal.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

9. COOKIES AND SIMILAR TECHNOLOGIES

Our European Services uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies“) to distinguish you from other users of our European Services. This helps us to provide you with a good experience when you browse our European Services and also allows us to monitor and analyse how you use and interact with our European Services so that we can continue to improve our European Services. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.

Cookies are pieces of code that allow for personalisation of our European Services experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.

We use the following types of cookies:

(a) Strictly necessary cookies. These are cookies that are required for the operation of our European Services. They include, for example, cookies that enable you to log into secure areas of our European Services.

(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our European Services when they are using it. This helps us to improve the way our European Services works, for example, by ensuring that users are finding what they are looking for easily.

(c) Functionality cookies. These are used to recognise you when you return to our European Services. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(d) Targeting cookies. These cookies record your visit to our European Services, the pages you have visited and the links you have followed. We will use this information to make our European Services and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide services to us for this purpose.

(e) Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our European Services. These third parties are responsible for setting out their own cookie and privacy policies.

Other than strictly necessary cookies, which are required for the operation of our European Services, we will only place cookies on your device if you give us your consent to do so. We will ask you to tell us which cookies you agree to receive when you first access our European Services.

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