Privacy Policy

Effective Date: 06.06.2025, Version: 1.1 

This privacy notice (hereinafter referred to as “Privacy Notice” or “Notice”) describes the manner in which Vilgain Inc., whose registered office is at 111 Congress Avenue, Suite 500, Austin, Texas 78701 (hereinafter referred to as “Vilgain” or “we”) collects, processes and safeguards your personal information (as defined below).  Your privacy is important to us, and we are committed to protecting your Personal Information.

This Notice applies to the processing of Personal Information of individuals in the United States within all services, applications and websites operated by Vilgain in which the Personal Information is processed and that contain this Notice, reference to it or link thereto. It applies to the processing of Personal Information of visitors of our website, users of our services and also representatives of our business partners and persons who contact us through our website or otherwise. Vilgain is the Personal Information data controller when processing Personal Information under this Privacy Notice.

For the purposes of this Notice, “Personal Information” means information that is linked or reasonably linkable to an identified or identifiable individual, acting in an individual or household capacity, who is a resident of a state that has enacted privacy legislation.

For the purposes of this Notice “US State Laws” include privacy laws in the states of California, Delaware, Maryland, Rhode Island, Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Tennessee, New Jersey, New Hampshire, Nebraska, Minnesota, Kentucky, Indiana and Utah, together with any other U.S. state comprehensive privacy law that comes into effect subsequent to the date hereof.

In the event of any conflict between this Privacy Notice and any specific privacy notice applicable to any Vilgain product or service, the specific privacy notice shall prevail.

The provisions of this Privacy Notice are effective as of the above effective date.

 

I. What Personal Information we process and for what purpose

Fulfilment of sale contract 
When you, as a customer (hereinafter referred to as “Customer”), place an order through our website and purchase goods from us, we process the Personal Information you provide to fulfil your purchase and deliver to you the ordered goods. The information you submit in the order is either mandatory for the performance of the purchase agreement or provided voluntarily by you.

Mandatory Personal Information is necessary for the conclusion and subsequent performance of a purchase agreement. We require it in order to process and fulfill your order. Mandatory Personal Information includes, but is not limited to, your first name, last name, delivery details, billing information, email address, and phone number. The email address and phone number are used to confirm receipt of your order, provide payment confirmation, issue a receipt in compliance with applicable tax regulations (if required), provide updates on the status of your order, and facilitate any necessary follow-up communication regarding your purchase.

Optional Personal Information you can fill in voluntarily. While not required to process your order, this information helps us better understand your needs and enables us to handle your order more accurately and efficiently.

Account registration and its usage and management 
When you, as a Customer of Vilgain, create an account on the Vilgain website the Personal Information  we process includes, but is not limited to: identification details (name, surname), log-in data (your e-mail address, password), contact and delivery data (shipping and billing addresses, phone number), loyalty and membership data (accumulated points, membership tiers, reward-related data), shopping activity data (favourite items, shopping lists, watchlist, order history, back-in-stock or price drop alerts) and completed feedback from questionnaires, product reviews, comments, discussion, posts and any other user-generated input and also any other Personal Information you decide to share with us.

After your purchase is completed, you may receive a request to rate your shopping experience with us and provide feedback on the products you ordered. We only share limited data necessary for this review request – specifically, order number and your email address, to allow the service to send you the invitation. No other Personal Information is transferred. Based on your choice we will publish your review under your real name or anonymously.

We may process sensitive Personal Information such as your allergies or dietary requirements shall you proactively share this information with us. We process this data solely to fulfill your request and do not disclose this data to third parties. The Personal Information we process depends on what you share with us. If you provide this information voluntarily to the public Q&A on our website, then this information is generally visible to the public.  

Provision of customer service and support
When you use our services or contact our support team for assistance, we process your Personal Information necessary to provide you with service or handle your request.

Direct marketing and promotion
We use your Personal Information for our own marketing purposes, i.e., to send you newsletters and other marketing communication. For this purpose, we process the following Personal Information: identification details (name, surname), contact details, such as address, phone number, e-mail address, information about newsletters you signed up for (if any) and your preferences regarding marketing communication (if any). You can unsubscribe from receiving marketing newsletters and other communication at any time by using the unsubscribe option in the footer of each marketing email.

Management of our contractual relationships
When you or your organization engage with us as a Customer, business partner, advisor, or in a similar capacity, we may process your Personal Information for the purpose of effectively managing and maintaining our contractual relationship. For this purpose, we process the following Personal Information: identification details (name, surname), contact details, such as address, phone number, e-mail address, information about the company you work for and your work position.

Recruitment process
If you apply for any open job positions at Vilgain, we will process Personal Information you provide to us for the purposes of evaluating your suitability for any of our open positions. For this purpose, we will process the following Personal Information: identification details (name, surname), contact details, such as address, phone number, e-mail address, information from your CV, Cover Letter about your past positions, qualifications, etc., and any further information you share with us during the recruitment process. If you are a successful candidate, you will receive a job offer from us. For this purpose, we will process the offered position and salary and other relevant job details. If you are unsuccessful in the application process, we may also keep your CV in our internal database in order to consider you for future job positions at Vilgain.

Defending our rights and claims
When you make a legal claim against us, or when we need to protect our rights through legal or other means, we process your Personal Information necessary to be able to effectively defend our rights and defend ourselves against a claim.

Fulfilment of legal obligation
In some instances, legal regulations impose obligations on us under which we are obliged to process Personal Information. Such cases are for instance tax and accounting laws, whistleblowing laws, anti-discrimination laws and the provision of some Personal Information to public authorities based on applicable legislation. We process your Personal Information within the scope as required by applicable legislation.

Contacting us
If you contact us via our website or by different means we will process your Personal Information to reply and provide you with what you have requested. We process the following Personal Information: identification details (name, surname), contact details, such as address, phone number, e-mail address, information about the company you work for and your work position, any further information you share with us.

Whenever we process your Personal Information based on your consent, you can withdraw your consent with the given processing at any time by contacting Vilgain at support@vilgain.com.

 

II. Cookies and other tracking technologies.

Our websites and services (jointly “Websites”) use cookies, web beacons and other similar technologies to automatically collect information about individuals who visit and use our Websites. These are small files that are stored on your device. They help us to operate our Websites, provide important features and functionalities and enable us to better understand how you use our Websites.

We use the following types of cookies:

(i) essential (technical) cookies that are necessary to provide access to our website and to provide the services you have specifically requested, to enable basic website functions such as tagging your data inputs, network management and accessibility. We process your Personal Information on contractual basis – to provide you with the services requested by you on our Websites and on the basis of our legitimate interest to operate the Websites. It is not possible to disable essential cookies through the Privacy Settings as our Websites might not function properly when you disable this type of cookies.

(ii) functional (preference) cookies allow us to remember choices you have made in the past, such as what language and currency you prefer, remember your name and email, and automatically fill out forms and allow for personalization.

(iiI) analytical (statistical) cookies help us analyse how you move around our website and what content is relevant to our users. They are used for performance measurement and improvement.

(iv) advertising (marketing) cookies that help deliver tailored and personalised advertising.

We may collect the following information through cookies: IP address, type of device, device ID.  gender, time zone, browser settings, operating system, website traffic information including URL, searched terms, information about what you have viewed or searched for on our website, website response time, download errors, length of visits to certain pages, information about how you interact with the website (such as scrolling, clicking and hovering).

Other tracking technologies 
Apart from cookies, we also use other technologies that help us to operate our Websites and to analyse your behaviour. We currently use:

• Pixels
• Web beacons
• URL tracking

The above technologies may have access to your device's IP address, device screen size, device type, unique device identifiers, operating system, browser information, geographic location, time stamp, time zone, preferred language used to display our website, activities and navigation on our website, length of visit.

Opting out of use of and disabling cookies and other tracking technologies
For the purposes of this section cookies also includes pixels, web beacons and URL tracking. [PM1] When you visit our Websites, you will be informed via the cookie banner located at the bottom of the website that we collect cookies. This banner allows you to opt out of the use of cookies. You can change your settings at any time via the Privacy  Settings at the bottom of our Websites.

If you do not wish cookies to be collected, you can restrict, block or delete them at any time by adjusting your browser configuration.

If you wish to prevent the installation of new cookies or if you wish to delete existing cookies, you can find instructions at the links below. The exact procedure depends on the browser you are using:

• Internet Explorer: here
• Firefox: here and here
• Google Chrome: here
• Safari: here

For mobile devices, you can limit tracking through your device's cookie settings (by turning off the advertising identifier), see https://www.networkadvertising.org/mobile-choice/.

In addition, you can use a third-party tool to opt out of targeted advertising. Third party opt-out tools available include Digital Advertising Alliance and Network Advertising Initiative.

To opt out of receiving cross-device web advertising (i.e., tracking a user across devices), you can access your device settings or visit and use the controls described on NAI Mobile Choices.

Global Privacy Control
We recognize and honor the Global Privacy Control (GPC) signal[2] . GPC is a browser or device setting that enables you to communicate your privacy preferences to websites you visit, such as opting out of the sale or sharing of your Personal Information.

If your browser or browser extension sends a GPC signal, we will treat it as a valid request to opt out of the sale or sharing of your Personal Information for the browser or device that sends the signal, in accordance with applicable privacy laws (such as the California Consumer Privacy Act, as amended by the CPRA).

To learn more about GPC and how to enable it, please visit https://globalprivacycontrol.org.

Vilgain does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

 

III. How long will we process your Personal Information?

In general, Personal Information shall only be retained for as long as necessary for the purpose for which it was collected. The period for which Vilgain will retain your Personal Information depends on the purpose for which we process the Personal Information, the legal basis, as well as applicable legal limitations (if any).

If the processing is based on a legitimate interest, your Personal Information will be processed for the duration of that legitimate interest of Vilgain, or until you request deletion of such Personal Information.

In the case of Personal Information retained on the basis of legal obligations, the retention period is determined by applicable legal regulations.

For data processed on the basis of the performance of a contract, the Personal Information is processed for the duration of the contractual relationship and for the relevant limitation period.

If you create an account on our website or application, we will process your Personal Information for the duration of that registration. You can request deletion of your account at any time.

If the processing is based on your consent, your Personal Information will be deleted after the withdrawal of consent. You can withdraw your consent to the processing of your Personal Information at any time by sending a message to support@vilgain.com. Please note that the same Personal Information may be processed on more than one legal basis, in which case your withdrawal of consent or request for erasure of Personal Information may not result in the complete erasure of your Personal Information. Withdrawal of consent does not affect the lawfulness of processing based on consent given before its withdrawal.

 

IV. Data sharing, processors and transfers to third countries

Your Personal Information will not be shared with any third party except in the following situations: 

• Personal Information is necessary for the provision of Vilgain services,
• You have provided us your consent, entrusting Personal Information to processors who process Personal Information on behalf of Vilgain,
• Vilgain is obliged to provide Personal Information based on the law or order of a public authority.

Categories of Processors
We may share your Personal Information with the following categories of processors:

• data centre, hosting providers
• payment providers
• logistics & delivery providers
• electronic communication and messaging providers
• marketing providers
• analytics & business intelligence providers resource planning, business management, task management, support management, communication and other IT providers
• our contractors and other partners who assist us in providing our services
• legal services, tax, accounting, and audit services
• recruitment and applicant verification providers
• information security providers.
   

V. Data security

Vilgain undertakes to ensure that your Personal Information is stored securely. Therefore, taking into account the nature of the Personal Information processed,  Vilgain has taken appropriate technical and organizational measures to secure the Personal Information processed by Vilgain, including, for example:

• Encryption: All Personal Information is encrypted both in transit and at rest
• Access Controls: Access to Personal Information is restricted to authorized personnel only, based on the principle of least privilege
• Secure Hosting: We store Personal Information on secure servers with robust firewalls and intrusion detection systems
• Password Protection: All systems and databases are protected by strong password policies and multi-factor authentication.
• Employee Training: Our team undergoes regular training to understand and comply with data security best practices.
• Regular Updates: Our software, systems, and hardware are regularly updated to address potential security vulnerabilities.

These measures do not relieve you of the obligation to take appropriate measures to secure your Personal Information. You should, among other things, change your passwords for your Vilgain account regularly. On the other hand, you should not, among other things, use predictable usernames and/or passwords, share your passwords with others or provide access to your administrator account and/or disclose your Personal Information to others. Vilgain will never ask you for your password in any unsolicited communication. Immediately notify us of any unauthorized use of your administrator account or any other suspected breach of security.

 

VI. Your Rights

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by US State Laws, you have:

• Right to notice. You have the right to be informed about how your Personal Information will be used;
• Right of access. You are entitled to be informed about what Personal Information Vilgain processes about you, for what purposes and who are the recipients of your Personal Information;
• Right to obtain a copy of your Personal Information (Right to portability). We will provide your Personal Information in a portable and usable format that allows you to transfer Personal Information easily to another entity – provided that this is technically feasible;
• Right to correct inaccurate Personal Information. You may ask Vilgain to correct inaccurate information that Vilgain has about you;
• Right to request deletion. You are entitled to the erasure of certain Personal Information that we have collected and processed about you;
• Right to Opt-out of advertising and profiling. You have the right to object or opt-out of certain types of processing, including; targeted advertising and profiling and automated decision-making;
• Right to opt-out of sale or sharing. You may request Vilgain to stop selling or sharing your Personal Information ("opt-out"), including via a user-enabled global privacy control. Vilgain does not intend to sell your Personal Information, however, as we may process your Personal Information via cookies and such processing could be considered as a sale, kindly note that you have the right to opt-out from cookies or disable cookies completely as described in Section II (Cookie section) of this Privacy Policy;
• Right to receive equal services. You have a right to not be discriminated against even if you exercise any of your rights;
• Right to limit use of sensitive Personal Information. You can direct Vilgain to only use your sensitive Personal Information for limited purposes, such as providing you with the services you requested.

Your ability to exercise your rights may be restricted if Vilgain is required to retain your Personal Information for legal obligations, legal claims, or other reasons as outlined in the relevant data protection law.

 

VII. Additional information for California residents

In Section I of this Privacy Policy, you will find a summary of the Personal Information we have collected in the preceding twelve months and the purpose of such collection. Below you will find information on the source of the Personal Information. In Section IV of this Privacy Policy, you will find information on whom your Personal Information is shared with. For information regarding how long we retain Personal Information, please refer to Section III of this Privacy Policy. Please note, in addition to the recipients identified in Section IV, we may disclose any of the categories of Personal Information we collect with government entities, as may be needed to comply with law or prevent illegal activity.

“Do Not Sell or Share My Personal Information”
Under California law, residents of California have the right to opt out of the “sale” or “sharing” of their Personal Information. We do not “sell” your Personal Information however we do use cookies and similar tracking technologies, as specified above in Section II, for purposes of targeted advertising which activity may be considered a “sale”.

• “Sale” is defined broadly and may include transferring Personal Information to third parties in exchange for money or other valuable consideration.
• “Sharing” means disclosing Personal Information to third parties for cross-context behavioral advertising, whether or not money is exchanged.

We may allow certain third-party advertising or analytics providers to collect information about your activity on our website (such as cookies, IP address, and browsing behavior) to help us deliver relevant ads or understand website usage. This kind of data sharing may be considered a “sale” or “sharing” under California law.

If you are a California resident and wish to opt out, you may do so by clicking on the Privacy Settings in the footer of our Website You can also opt out from other sharing of your personal data via Do Not Sell or Share My Personal Information[3]  in the footer of our website. We will apply your opt out based upon the Personal Information in our records that is linked or reasonably linkable to the information provided in your request.

You may also configure your browser to send a Global Privacy Control (GPC) signal, which we recognize as a valid request to opt out of selling/sharing your Personal Information.[4] 

This section VII does not address or apply to our handling of publicly available information or other sources of Personal Information. In general, we may collect Personal Information from the following categories of sources:

• Directly from the individual
• Advertising networks
• Data analytics providers
• Social networks
• Internet service providers
• Operating systems and platforms
• Fraud prevention service providers
• Data brokers
• Business customers/clients

Additional rights for individuals residing in California
In addition to the rights listed above common to all individuals in the United States, as an individual residing in California, you have:

• The right to request to limit our use or disclosure of your sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of sensitive Personal Information is necessary to verify or maintain the quality or safety of our service;
• The right to opt out of the sharing of your Personal Information for cross-context behavioural advertising.

 

VIII. Children

Our websites are not intended for anyone under the age of 16. We will not knowingly collect any Personal Information from children under the age of 16. If we learn that we have obtained any Personal Information about a child under age 16, we will delete that information. If you are the parent or guardian of a child who has provided us with their Personal Information, you may contact us using the contact details set out below to request that it be deleted.

 

IX. Contact details

If you wish to exercise any of your rights set out above, please contact us at support@vilgain.com.

Once we receive your request, we will take steps to verify it by asking you to provide information related to your account or your recent interactions with us, such as information regarding a recent purchase. We will process your request based upon the Personal Information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.

If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid authorization to submit requests on your behalf and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

If you would like to learn more about Vilgain, its privacy protection or this Privacy Notice, you may contact Vilgain at support@vilgain.com.

Please help Vilgain to keep your information up to date. If you believe that any Personal Information processed by Vilgain is incorrect, or if you believe that Vilgain is not complying with this Privacy Notice, please contact Vilgain at support@vilgain.com.

 

X. Final provisions

The English-language version of this Notice shall be controlling in all respects and shall prevail in case of any inconsistencies with translated versions Vilgain may provide, if any.

This Privacy Notice may be amended by Vilgain at any time. If we make any material/substantial changes to this Privacy Notice, we will post the updated version of the Privacy Notice to our website and/or other places we deem appropriate. We may notify you of the change via sending you an email or providing other notice of the update, however you should check this Privacy Notice from time to time for any significant changes to its text.