Who is Responsible for Processing Your Personal Information?
Privacy Policy
Effective Date: Aug 25, 2020
Villar Trade LLC, (the “Company,” “we,” “us,” or “our”) is committed to protecting your privacy. This
Privacy Policy (“Policy”) describes the types of Personal Information that we may collect from you or that you may provide when you visit our website at https://www.ledxperienceusa.com/, use our service, or otherwise interact with us (collectively, the “Services”). This Policy also describes our practices for using, maintaining, protecting, and disclosing that Personal Information. Please read this Policy carefully as it will help you make informed decisions about sharing your Personal Information with us. This Policy does not apply to our data collection practices or notices with respect to employees, applicants, and contractors.
Who is Responsible for Processing Your Personal Information?
The data controller for purposes of processing personal data in the context of our Services is Villar Trade LLC, located at:
Villar Trade LLC
2001 Ramrod Ave Apt 1511
Henderson, NV 89014
Comments, questions, and requests regarding our Policy may be addressed to us at contact.ledx@ledxperienceusa.com
1.Personal Information We Collect About In this Privacy Policy, we use the term “Personal Information” to refer information that can identify you.
When you seek to connect to our Services, sign up for mailing lists, complete an online form, contact us, or otherwise interact with us, we may collect a variety of Personal Information. What we collect depends on your relationship with us and how you interact with our Services, and it generally falls into one or more of the following categories:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers)
Payment Information, including, but not limited to, credit card information.
Professional or employment-related information, including employment candidacy information, including contact, resume, and salary information as part of submissions for employment opportunities
Internet or other electronic network activity information (e.g., browsing history, search history, and
information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Geolocation data
Audio information (e.g., recordings of sales calls and customer service calls)
Inferences drawn from any of the information identified above to create a profile about a consumer
reflecting the consumer’s purchasing preferences and purchasing behavior
How Your Personal Information is Collected.
We may collect Personal Information when you: Interact with our Services; Make a purchase using our Services;
Request information about our Services;
Sign up for e-mails or other communications or notification from us; Provide us with comments, suggestions, or other input.
We may also collect information:
From a third party with your consent (e.g., your bank, financing partners, etc.); Directly from a third party (e.g., our vendors and service providers)
From cookies or other online tracking tools on our Services; and From publicly accessible sources (e.g., government databases).
- Information We Collect Through Automatic Data Collection As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, operating system, and browser type.
The information we collect automatically is statistical data that does not contain Personal Information. Information we collect automatically helps us to improve our Services and to deliver a better service.
The technologies we use for this automatic data collection may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
We may use third party analytics, including Google Analytics. You can opt out from the use of Google Analytics by following the instructed provided at https://tools.google.com/dlpage/gaoptoutt.
- Links to Other Our Website may contain links to the websites of third parties whose privacy practices may differ from ours. If you submit Personal Information to any of these third-party sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or link to from our Website.
- How and Why We Use Your Personal We may use personal information for the following purposes:
a)To Provide You Our Services
We will use your personal information to provide information or perform Services that you request. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. Your information may be available or provided to third-party service providers and contractors (such as the Site webmaster) that are contractually obligated to protect your information as disclosed in this Policy.
b)For Internal Use
We will use your personal information for the purposes of furthering our business, including analyzing your information and other uses. We may monitor how our users use our Site including without limitation search terms entered, pages visited, and documents viewed. This information may be stored with an IP address. This information is used solely for purposes of enabling us to provide you with a personalized Site experience. Aggregated forms of this data may also be used for research purposes in order to develop new products and identify future features and functions to develop for the Site.
c)To Provide You with Service-Related Communications
We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.
d)To Provide Customer Support or Respond to You
We collect any information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
e)To Enforce Compliance with Our Terms and Agreements or Policies
When you access or use our Services, you are bound to our Terms and this Privacy Policy. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We also process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties and business partners; and, as applicable, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.
f)To Ensure the Security of the Services
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
g)To Maintain Legal and Regulatory Compliance
Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
h)To Engage in Marketing Activities
Marketing lets us grow our community and update you about new products and services. We process your contact information or information about your interactions on our Services to: send you marketing communications and keep you updated about our products and services; provide you with information about events, training sessions or other materials; and deliver targeted marketing to you. See Cookies and Other Tracking Technologies section of this Privacy Policy for more information about tracking techniques we use for our marketing campaigns).
SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We may share personal information in the following circumstances:
a)Service Providers
Unless prohibited by applicable law, we may share personal information with our third-party service providers that help us operate our business, such as for website hosting, professional services, analytics, customer service, e-mail delivery and auditing. Such service providers must process the personal information we share with them only on our behalf and for the same purposes for which the personal information was collected. We only share personal information with third party providers to provide the services described in this Privacy Policy.
b)Industry Partners or Sponsors
When you register or enter a promotion, sweepstakes, or contest through our Services, we may share the information you provide with authorized third-party providers (as described above in 4 a, participating sponsors, and advertising partners). Further, by entering any promotion, you are agreeing to the official rules that govern that promotion, which may require you to take certain actions, including, except where prohibited by law, allowing LEDxperience and/or the sponsor(s) of the promotion to use the information in advertising or marketing associated with the promotion. Please review the relevant promotion, sweepstakes or contest rules for more information.
c)Corporation Transaction
Unless prohibited by applicable law, we may share, transfer or delete your personal information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by LEDxperience or any affiliated company (in each case, whether in whole or in part). If required by applicable law, any such sharing of personal information will be reported to regulators in accordance with the applicable law.
d)Other Lawful Disclosures
We may also share personal information: (i) if we determine that disclosure is necessary to comply with any law or legal process applicable to us or a request from law enforcement or other regulatory agency;
(ii) to protect the rights, privacy, property, interests or safety of our company or our affiliates, customers, business partners, suppliers, employees or the general public; (iii) to pursue available remedies or limit damages; (iv) to enforce our Terms of Use; (v) to respond to an emergency; and (vi) as otherwise permitted by applicable law.
THIRD-PARTY WEBSITES AND SERVICES
Our Services and other materials may include links or references to third-party websites and services that we do not operate. A link or reference to a third-party service does not mean that we endorse it or the quality or accuracy of information presented. If you visit a third-party website or otherwise interact with that third-party, you are subject to that third party’s privacy practices and policies, and we do not accept any responsibility or liability in this regard. This Privacy Policy does not apply to any personal information that you provide to these other websites and services.
SECURITY PRECAUTIONS
We implement appropriate technical and organizational measures designed to ensure your personal information in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit access of your personal information to authorized parties, periodically inspect, assess, and evaluate the effectiveness of our technical and organizational measures designed to ensure the security of our processing, and limit our collection and use of your personal information to the extent necessary to provide you with our services.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of personal information. Any transmission is at your own risk and we request that you use appropriate security measures to protect your personal information. If you believe that personal information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
RETENTION OF PERSONAL INFORMATION
We will keep your personal information or sensitive information for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of 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, whether we can achieve those purposes through other means, and all applicable legal requirements.
YOUR RIGHTS AND CHOICES
Marketing Information: If you do not wish to receive marketing-related emails from us or prefer us not to process your personal information for marketing purposes, please be sure that any relevant boxes on forms we use to collect your personal information are unchecked, click the unsubscribe link in one of our marketing emails, or contact us using the information in the section “How To Contact Us” at the end of this Privacy Policy. Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law. Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.
Correction: We must ensure that your personal information is accurate and up to date. Please advise us
of any changes to your personal information by contact using the information in the “How To Contact Us” section below.
Rights of individuals in Australia: If you are located within Australia, you have the right to access personal information about you that we hold, and you may ask us to correct such personal information to ensure that it is accurate, up-to-date and complete. There is no charge to submit a request or to correct information, however we may apply an administrative charge for providing access to your personal information on request.
Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services we offer.
If you wish to exercise any of your rights above, please contact us using the information in the “Contact Us” section at the end of this Privacy Policy. We may charge you a reasonable fee in case you request additional copies of your Personal Information or make other requests that are manifestly unfounded or excessive.
Individuals located the European Economic Area, the United Kingdom or Switzerland (collectively “EEA”)
at the time, please see Section 12, below for more information about your rights.
International Transfers
While this is uncommon, when you access or use our Services, we may transfer your personal information to countries in the world where LEDxperience conducts business. Such countries may be located outside of the country or jurisdiction where you are located and may have data protection laws
that are less protective than the laws of the jurisdiction in which you reside. In such countries, we will still handle your personal information in the manner describe herein. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
Individuals located in the European Economic Area (“EEA”), the United Kingdom or Switzerland at the
time they access our Services, please see Section 12, below.
CHILDREN’S PRIVACY
Our Services are not directed to or intended for use by minors. If we learn that we have received any personal information directly from a child under age 16, or such other age as set by the laws of
jurisdictions where we operate without his or her parent’s verified consent, we will use that personal information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services and subsequently we will delete that personal information.
Notice to California Residents
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary for the last twelve (12) months of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the third parties that we may share the Personal Information.
We generally collect the following categories of Personal Information when you use our Services:
identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP
address, software, and identification numbers associated with your devices;
commercial information such as records of products or services purchased, obtained, or considered by you;
Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
your geolocation, to the extent you have configured your device to permit us to collect such information; your geolocation, to the extent you have configured your device to permit us to collect such information; audio recordings of your voice to the extent you call us, as permitted under applicable law; and inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect “Sensitive Information”, as identified and defined by the CCPA (California Civil Code section 1798.140 (o)), or protected classifications about our users such as, social security numbers, driver’s license or state identification numbers, account numbers, credit or debit card, in combination with any required security code, access code, password or credentials that would permit access to an individual’s financial account, medical information, biometric information, professional or employment-related information, education-related information user name or email address in
combination with a password or security question and answer that would permit access to an online account.
For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.
We collect your Personal Information for the business purposes described in Section 3, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.
The categories of third parties with whom we may share your Personal Information are listed in Section 4, above.
Privacy Rights
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information your account with us or the security of our network systems.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, access, delete, or opt-out of sales.
Right to Know. You have the right to request in writing a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes. In addition, you have the right to request: (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
Right to Access. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
Right to Delete. You have the right to request us delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.
Right to Opt-Out of Selling. The CCPA broadly defines “Personal Information” and “selling” such that sharing identifiers and identifiers linked to you in exchange for money or other valuable benefit may be considered a sale. You have the right to opt-out of having your Personal Information sold. We do not sell your Personal Information.
To assert any of your rights above Information, please contact us by email at contact.ledx@ledxperienceusa.com or via phone at (702) 917-7894. To confirm your identity, we may ask you to verify Personal Information we already have on file for you. Verification is required for all access
and Deletion requests. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
Notice to Individuals in the European Economic Area, the United Kingdom and Switzerland
This section only applies to individuals that access or use our Service while located in the EEA, United
Kingdom and/or Switzerland (collectively, the “EEA”). We may ask you to identify which country you are located in when you use some of the Services or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the EEA. If any terms in this section conflict with other terms contained in this Privacy Policy, the terms in this section shall apply to users in the EEA.
Our Relationship to You
This Privacy Policy is provided on behalf of Villar Trade LLC and each of its Affiliates, and there are no joint controllers with regard to personal information collected under this Privacy Policy. Depending on the type of or location our services are provided, different Entities may be the data controller in relation to your personal information. The data controller (“we”, “us”, “our”) is the Entity named when we collect your personal information or in the location where we referred you to this Privacy Policy (e.g., the Entity identified in the email signature containing a link to this Privacy Policy). If no Entity has been clearly identified, the data controller or data controllers may be identified in the following order or precedence:
For personal information that LEDxperience collects on or through its websites and mobile applications, the Entity that operates the website or mobile application is the data controller.
For personal information that is collected in connection with our newsletters and other marketing message, the data controller is identified on the subscription form and in each subsequent marketing message you receive.
For personal information collected in connection with invitations and participation in events, the data controller will be the Entity which is organizing such event as identified in the announcement for the event.
For personal information collected in the context of a recruitment process, the data controller is the Entity identified in the job posting.
For personal information that LEDxperience collects pursuant to a customer or contractor relationship, the LEDxperience Entity with which you have the customer or contractor relationship is the data controller.
For activities in the context of the procurement of products and services, the data controller will be the Entity identified in the order form or agreement.
Marketing
We will only contact individuals located in the EEA by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal information in this way or to disclose your personal information to third parties for marketing purposes, please click an unsubscribe link in your emails or contact us at contact.ledx@ledxperienceusa.com. You can object to direct marketing at any time and free of charge.
Legal Bases for Processing Your Personal Information
Below is a list of the purposes described in our Privacy Policy with the corresponding legal bases for processing.
Legal Bases for Processing: Based on our contract with you or to take steps at your request prior to entering into a contract.
Section 3 a) To Provide You Our Services Section 3 b) For Internal Use
Section 3 c) To Provide You with Service-Related Communications Section 3 d) To Provide Customer Support or Respond to You
Section 3 e) To Enforce Compliance with Our Terms and Agreements or Policies Section 3 f) To Ensure the Security of the Services
Section 4 a) Disclosure to Service Providers
Legal Bases for Processing: Based on your consent. Section 3 h) To Engage in Marketing Activities Section 4 c) To Industry Partners or Sponsors Section 4 b) To Affiliates
Legal Bases for Processing: Based on our legal obligations. Section 3 f) To Ensure the Security of the Services
Section 3 g) To Maintain Legal and Regulatory Compliance Section 4 e) Other Lawful Disclosures
Legal Bases for Processing: To protect your vital interests. Section 4 d) Other Lawful Disclosures
Legal Bases for Processing: Based on our legitimate interests. When we process your personal data for our legitimate business interests we always ensure that we consider and balance any potential impact on you and your rights.
Section 3 b) For Internal Use
Section 3 c) To Provide You with Service-Related Communications Section 3 d) To Provide Customer Support or Respond to You Section 4 b) Disclosure to Our Affiliates Businesses
Section 4 d) Disclosure Relating to Corporate Transactions
Your Individual Rights
We provide you with the rights described below when you use our Services. We may limit your individual rights requests in the following ways: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; and (d) where the request is frivolous or burdensome.
If you would like to exercise your rights under applicable law, please contact us at contact.ledx@ledxperiencusa.com. Please note, we may seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information. When we fulfill your individual rights requests for correct (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort.
Right of Access. Upon your request, we will provide you with a copy of your personal information in our files without undue delay and free of charge, unless we permitted by law to charge a fee.
Right to Rectification (or “Correction”). You may request to correct or update any of your personal information in our files. We may provide you with the ability to update some or all of your personal information directly via the Services.
Right to Erasure (or the “Right to be Forgotten”). Upon your request, we will erase any of your personal Information in our files that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object and there are no overriding legitimate grounds for our processing.
Right to Data Portability. If we process your personal information based on a contract with you or based on your consent or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another controller, where technically feasible. personal information.
Automated Individual Decision-Making, Including Profiling. While you do have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, under applicable law, we do not subject your personal information to such processing activities.
Right to Object to and Right to Restrict Processing. Under certain situations, you may object to or seek to restrict our processing of your personal information.
Complaints
To assert any of your rights above, or if you believe that we have infringed or violated your rights under this Privacy Policy, please contact us at contact.ledx@ledxperienceusa.com so that we can work with you to fulfill your request or resolve your concerns. You can also complain about our processing of your personal information to the relevant data protection authority where you live or work, or in the place where the alleged breach of data protection law has taken place.
International Transfers of Personal Information
We may store, process and transmit personal information in locations around the world, including locations outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.
We transfer your personal information subject to appropriate safeguards as permitted under the applicable data protection laws. Specifically, when your personal information is transferred out of the EEA, we have the required contractual provisions for transferring personal information in place with the third parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Binding Corporate Rules, Standard Contractual Clauses, or we work under international agreements and treaties with respect to data privacy and cross border transfers of Personal Information, as may be applicable.
HOW TO CONTACT US
We welcome your questions or comments about this Privacy Policy or how we process your personal information. Please contact us using the information below and we will route your question or comment to by email at contact.ledx@ledxperienceusa.com, or via phone at (702) 917-7894, or by writing us at Villar Trade LLC, 2001 Ramrod Ave Apt 1511, Henderson, Nevada, 89014.
