Effective Date: March 10, 2022
Table of Contents
1. Privacy Introduction
Unless the context otherwise clearly indicates, all capitalized terms used in the singular include the plural and vice versa.
Personal Data is information about a living person, including their identity, finances, online behavior, and other personal information that can be used to identify them.
2. Your Role With Us
We obtain Personal Data about you from various sources to provide our programs, services, products, and subscriptions (collectively, “Offering“), and to manage the Site.
We use the terms “Client“, “Consumer“, “Partner“, “User” (collectively, “Member“), and “Visitor” to describe the various roles “you” assume when interacting with us.
Clients are Users that have purchased one or more of our service Offerings.
Consumers are Users that have purchased one or more of our product Offerings.
Partners are Users that have applied and have been accepted to participate in one or more of our partner Offerings.
Users are people or entities that have shared Personal Data with us, but may or may not be a Client, Consumer, or Partner.
Visitors are people that visit the Site.
3. As a Visitor
- No Personal Data is collected;
- No Personal Data is stored in the browser;
- No Personal Data is shared with or sold to third parties;
- No Personal Data is shared with advertising companies;
- No Personal Data is mined or harvested; and
- No Personal Data is monetized.
Learn all about cookies at https://allaboutcookies.org.
3.1 Site Analytics
We run an analytics script by Plausible Analytics to collect anonymous usage data for statistical purposes and to track overall trends in the Site traffic, not individual Visitors.
Data collected includes websites that send us traffic, pages on the Site that are visited, duration of the visits, information from the devices used during the visit, and more.
- Check the Plausible data policy for full details.
4. As a Member
We collect only what we need to provide you with the service you requested.
We use a selection of trusted external (third-party) service providers and partners for certain services. These service providers are carefully selected to meet high data protection, data privacy, and security standards. We only share information with them that is required for the services offered.
4.1 Personal Data We Collect
While using the Site or interacting with us in person, and on networking sites and apps, we may collect Personal Data from you or an external service provider.
You can withdraw consent at any time, but doing so may affect your ability to use the Site and certain Offerings.
Personal information is Personal Data that we collect about you, including your public, identity, financial, and private information.
We use personal information to…
- Obtain financial or legal advice;
- Comply with our legal obligations;
- Assist law enforcement as necessary;
- Exercise or defend against legal claims;
- Prevent or address fraud and avoid credit risks;
- Protect the vital interests of you, others, or our company;
- Acquire and maintain insurance as reasonably necessary;
- Allow a merger, acquisition, bankruptcy, or sale of our assets; and
- Investigate and remedy any violations of our rights or policies;
Public information is Personal Data that we access through networking sites and apps. This data includes anything you make public, such as your username, email address, gender, pronouns, location, job title, workplace, or pet’s favorite toy.
We use public information to…
- Market and interact with you via social media; and
- Manage and improve our business via market research.
To restrict our access to this data, you can change your privacy settings on the specific networking sites or apps that you use, or simply update your profile to exclude it.
Identity information is Personal Data that can be used to identify you specifically and may include your name, email address, telephone number, shipping address, financial data, or images and videos of you.
We use identity information to…
- Request feedback from you;
- Enter into a contract with you;
- Share your testimonial on the Site;
- Create or administer your account;
- Enter you into a contest or giveaway;
- Notify you of updates to our Offering;
- Perform our contractual obligations to you;
- Deliver your online orders to you through the mail;
- Resolve disputes or troubleshoot problems with you;
- Respond to your questions, comments, and requests;
- Email you about new offerings we think you will like; and
- Send you a newsletter or other updates about our company.
Financial information is Personal Data that is related to your payment method and may include your credit card or bank transfer details.
We use an external payment processor when you purchase any of our Offerings. When we process your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.
At no time is your financial information passed to us or the Site, unless you consent to certain optional personal shopping features.
We use financial information to…
- Allow us to personal shop for you; and
- Process orders, returns, exchanges, or refunds.
Private information is Personal Data that may or may not be personally identifiable. It may include written correspondence between us, your sizing and measurements, events you plan to attend, recent lifestyle changes, your shopping habits, etc.
We use private information to…
- Perform our contractual obligations by delivering a personalized styling experience to you.
4.2 How Do We Collect Your Data?
You directly provide us with most of the Personal Data we collect. We also collect Personal Data about you from other sources.
- If you use third-party software via the Site or the Offering, they may transfer information to us; and
- If you use a provider that is a part of our network, we may receive information through this network or a Partner.
We collect and process Personal Data when you:
- Update any of your Registration Data;
- Use any of the fillable forms on the Site;
- Place an order with us for any of our Offerings;
- Register as a Client with us and create an account;
- Complete a satisfaction survey or provide feedback to us;
- Correspond with us via email, telephone, networking websites, or other apps; and
- Use one of our trusted external service providers to help us perform our contractual obligations to you.
4.3 How Do We Secure Your Data?
We maintain security measures to protect your Personal Data from unauthorized access, misuse, or disclosure. However, no system is 100% secure.
While we make every effort to protect your Personal Data shared with us, we can’t guarantee the security of any information you provide to us. To the fullest extent permitted by applicable law, we don’t accept liability for unauthorized disclosure of your data.
We store email correspondence and other files that contain your Personal Data in our secure Google Workspace.
- Check the Google security overview for full details.
Your information is encrypted at rest and in transit. Encryption is an important piece of the Google Workspace security strategy, helping to protect your emails, chats, video meetings, Google Drive files, and other data.
The Site is hosted on Flywheel, a leading hosting provider for thousands of businesses. We store your name, an image of you, and your feedback about your level of satisfaction when you consent to us posting your testimonial on the Site.
We store similar Personal Data, such as your name and website, if you consent to us using your photography so we may credit you properly.
- Check the Flywheel security overview for full details.
Your information is encrypted at rest and in transit. SSL is employed on the Site to ensure that all data passed between the web server and browser remain private.
The Site forms do not store your Personal Data in any way. We have disabled all analytics and tracking from the Site forms. We have chosen to do so to put your privacy first.
The Site forms also use hCaptcha, a GDPR-compliant and privacy-friendly captcha. We use captcha technology to help stop junk email from ever hitting our servers. Junk email may contain links that lead to phishing websites or sites that are hosting malware or include malware as file attachments.
Please contact us directly at hellobri [at] vostramoda.com if you are having trouble filling out the Site forms.
We store your email address and name in Buttondown, a privacy-first newsletter software. We use your email address for the purposes for which you provided it to us, and also to send you emails regarding the Offerings or services that we believe may be of interest to you. We have disabled analytics including open and link tracking, and any other behavioral tracking on all emails sent.
You may opt out of such email communications at any time by clicking the “unsubscribe” button in the email.
To make scheduling our appointments together easier, we use Calendly, instead of going back and forth via email. We store your appointment information, which can include your name, email address, and phone number; the subject of the meeting; and any other information provided to us.
Zoom or Google Meet
When scheduling our meetings with Calendly, we will collect Personal Data about your appointment with us. The Calendly service (as detailed above) will automatically send both of us an email with a link to our meeting, either hosted on Zoom or Google Meet.
We use Intuit to process any payments you make to purchase our Offerings by an invoice sent to your email address. We receive only the information used for order fulfillment.
- Check the Intuit privacy and security policies for full details.
Hue and Stripe
We use Hue and Stripe to organize some of our Clients’ Personal Data to help us perform our contractual obligations to you by digitally managing your wardrobe with images that you supply us, and creating interactive lookbooks for you.
The Personal Data we require from you to create an account with us via Hue and Stripe is your name, email address, country, state/province/region, and city where you reside. Other information may be collected and stored within Hue and Stripe as provided by you.
You may request your Personal Data be provided to you or deleted by us or by Hue and Stripe directly.
We use Voxer to enhance our communication with our Clients. Voxer is a secure, real-time communication push-to-talk (PTT) website and app that we use to collect multimedia messages from you without the need to collect your telephone number.
We collect images, text, video, and audio that you send us, and use this data to make communication between us easier, and help us perform our contractual obligations to you.
4.4 How Do We Share Your Data?
We may also share your Personal Data with trusted external (third-party) service providers and partners to contact you based on your request to receive such communications, help us provide sales support, or provide customer support.
4.5 How Long Do We Retain Your Data?
We keep your Personal Data and other relevant information only so long as we need it to provide you with the services you request, and thereafter for no longer than is reasonably necessary for internal reporting and reconciliation purposes and to provide you with any feedback or information that you might request or require.
Note: As long as you have an open account with us, we will continue to retain your Personal Data. This allows you to participate in programs that we may share with you that require an open account.
When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either delete it from our systems or depersonalize it so that we can not identify you.
4.6 What Are Your Data Protection Rights?
We believe in fundamental privacy rights, and that those rights should not differ depending on where you live in the world.
That’s why we treat any information that relates to an identified or identifiable individual as “Personal Data”. No matter where you live, you have…
- The right to access – You have the right to request copies of your Personal Data. We may charge you a small fee for this service.
- The right to withdraw consent – You have the right to request that your consent be withdrawn from our use of your Personal Data.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your Personal Data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- The right to notification of data breaches – You have the right to be notified of data breaches. If we learn of a breach, we will notify you by sending an email to you.
- The right to lodge a complaint – You have the right to lodge a complaint about us with a supervisory authority.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us by your preferred method.
To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to submit your request via the account email address you provided to us.
5. Privacy of Other Sites
6. Embeds From Other Sites
Articles on the Site or in the newsletter may include embedded content (e.g. videos, images, etc.). Embedded content from other websites behaves in the exact same way as if the visitor had visited the other website.
7. Children’s Personal Data
The Site and Offerings are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Site or to us directly without verifiable consent from a parent or legal guardian.
If we learn that we have collected Personal Data of a child under the age of thirteen (13) without verifiable consent from a parent or legal guardian, we will take reasonable steps to delete such data from our files promptly, unless we have a legal obligation to retain it. Please contact us by your preferred method if you believe we have any Personal Data from or about a child under the age of thirteen (13).
8. How to Contact Us
All notices or communications will be by email or in writing. Email is permissible but will only be considered sufficient notice if the non-sending party affirmatively confirms receipt.
Vostra Moda, LLC.
159 Main Street
Nashua, NH 03060
Email: hellobri [at] vostramoda.com
Contact form: Send a message
Monday – Friday: 9:00 am – 4:00 pm ET
Saturday – Sunday: Closed
9. Policy Changes
Personal Data collected prior to changes will be used according to the policies that applied at the time the information was collected.
- March 10, 2022
- edit Section 2.1: Definitions, to include “Partner” and “Consumer”.
- edit Section 4.2: How Do We Collect Your Data, to include reference to our Partners.
- edit Section 4.3: How Do We Secure Your Data, to include Intuit as our payment processor and removed PayPal and Stripe.
- edit Section 4.4: How Do We Share Your Data, to include reference to our Partners.
- edit Section 9: Policy Changes, to incorporate this changelog.
- fix Section numbering, typographical and grammatical errors, and clarified existing text.
- April 13, 2021
- Initial release