Privacy Policy

Current as of May 2017

OUR PRIVACY POLICY CHANGES FROM TIME TO TIME. PLEASE CHECK BACK FREQUENTLY

We realize the sensitive nature of the information you provide to us. This Privacy Policy describes how Vitale Secrets ("Company" or "we") collects, uses and disseminates information about users ("you") of this website ("website" or "site") that we collect online. By using this website, you agree to accept the terms and conditions of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use this site. THE COMPANY RESERVES THE RIGHT TO UPDATE FROM TIME TO TIME, SO YOU SHOULD REVIEW THIS POLICY FREQUENTLY. Your use of this site following any changes means that you accept those changes.

COLLECTION AND USE OF INFORMATION

1.1 Survey Information. The Company collects information about you when you voluntarily complete a Company survey, order form, registration page or other online request form, (collectively, a "Survey"). In Surveys, the Company or third-party partners may ask you to provide personally identifiable information to the Company, which may include your name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, employment information, personal and online interests, and such other information as may be requested from time to time (together, "Survey Information"). You may receive incentives from the Company or third-party partners in exchange for providing Survey Information to the Company. If a login or password is generated, you are responsible for maintaining the confidentiality of your login and password information.

1.2 Third-Party Partner List Information. The Company may obtain information about you when if you provide information to a third-party partner, and the Company subsequently purchases, licenses, or otherwise acquires that information from the third-party partner ("Third-Party Partner Seller"). Such purchased information may include, but is not limited to, Survey information ("Third-Party Partner Survey Information"). Third-Party Partner Survey Information is included in Survey Information.

1.3 Cookies, Web bugs, and Other Technology. The Company currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about you with Survey Information in our database. This internet-related information includes but is not limited to your IP address, the date and time you access the site, the URL that you just came from, which URL you go to next, which browser you are using and which operating system you are using. Additionally, the Company may use other new and evolving sources of information in the future (together, "Technology Information"). As a result, Company strongly encourages you to revisit this policy for any updates regarding its use of technology.

(a) Cookies. A cookie is a small amount of data stored on the hard drive of your computer that allows the Company to associate your computer with your corresponding Survey Information that resides in Company's database. We may use cookie technology to improve your experience, remember your preferences, customize the content you see, or authenticate our access to your Survey Information. If you do not accept cookies and use our site, you may be unable to use all of the features and functionality of our site.

(b) Web bugs. A web bug, web beacon, or action tag is programming code that can be used to display an image on a web page, but can also be used to transfer your unique user identification (often in the form of a cookie) to a database and associate your information with previously acquired information about you in another database. The Company currently contracts with online partners to help manage and optimize its Internet business and communications. It uses the services of a marketing company to help us measure the effectiveness of its advertising and how you use our site. To do this, it uses web beacons and cookie provided by its marketing company on this site. The type of information it collects includes the frequency, duration, and pages viewed by you, and the time you spend on a page, your operating system, browser size, type, version and connection speed. By supplementing our record with this information, we learn about the pages that are most attractive to our visitors, which of our products most interest our customer, and what kinds of offers our customers like to see. Although the marketing company logs the information coming from its site on its behalf, the Company controls how that data may and may not be used. If you do not want to help the Company learn how to improve its site, product, offers and marketing strategy, you can "opt-out" of the website analysis tool by emailing privacy@thesecretreflection.com We may also use web bugs in email messages or newsletters.1.4 Individual Information. As used herein, "Individual Information" means Survey Information, Third-Party Partner Survey Information, Technology Information, and any other information the Company gathers or receives about individuals.

1.4 Individual Information. As used herein, "Individual Information" means Survey Information, Third-Party Partner Survey Information, Technology Information, and any other information the Company gathers or receives about individuals.

1.5 No Information Collected from Children. The Company does not solicit information or target information of any kind to children under the age of 13. The Company will not knowingly collect or share any personal information about children under the age of 13.

1.6 Credit Card Information. The Company may in certain cases collect credit card numbers and related information, such as the expiration date of the card ("Credit Card Information") when you place an order with or through the Company. When you provide your Credit Card Information to the Company, such information is encrypted and is protected with SSL encryption software. The Company will use the Credit Card Information for the purpose of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third party partners only as necessary to complete the purchase transaction. Credit Card Information is not included in the definition of "Individual Information" and is not shared with Third-Party Partners.

USE OF INDIVIDUAL INFORMATION

2.1 Discretion to Use Information. THE COMPANY RESERVES THE RIGHT TO USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY'S SOLE DISCRETION. The company may use Individual Information to provide promotional offers to individuals by means of email advertising, text/short message services, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.

2.2 Email. The company uses Individual Information to provide promotional offers by email to you. If you wish to stop receiving email promotions from the Company, you should follow the opt-out instructions described in paragraph 5 below. The Company may use third party partners or affiliates to send commercial messages on its behalf. In certain commercial email messages sent by or on behalf of the Company, such partner's or affiliate's name or email address may appear in the "From:" line. The "Subject:" line of the company's commercial email messages will usually not contain phrases such as "ADV:" or "ADVERTISEMENT". All commercial email messages sent by or on behalf of the Company will provide you a means to opt-out of receiving future commercial messages from the company. Please note that you may continue to receive non-commercial email messages from the Company even if you have opted not to receive future commercial messages from the Company. Such non-commercial messages may include, for example, information about products or services you have purchased from the Company or a company newsletter to which you have subscribed.

2.3 Targeted Advertising. The Company uses Individual Information to target advertising to you. The Company uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones. Because the Company does market using telephones, you hereby give permission and consent to the Company or its affiliates to contact you via phone or email, and you agree to allow the Company or its affiliates to monitor or record your phone conversations. Verbal notice may not always be provided of monitoring or recording.

2.4 Storage of Individual Information. The Company stores Individual Information in a database on Company computers. Our computers have security measures (such as a firewall and monitoring) in place to protect against the loss, misuse, and alteration of the information under Company's control. The Company cannot guarantee that its security measures will prevent the Company computers from being illegally accessed.

2.5 Notification of Privacy Policy Changes. The Company's business is always changing and the Privacy Policy may change as well. The Company will post the changes here in the privacy policy so you are always aware of what information is collected, how it is used, and under what circumstances, if any, it may be disclosed. You can determine if this Privacy Policy has been revised since your last visit by referring to the "Current as of" date at the top of this page.

DISSEMINATION OF INDIVIDUAL INFORMATION

3.1 Transfer to Affiliates or Third-Party Partners. THE COMPANY MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO AFFILIATES OR THIRD-PARTIES FOR ANY PURPOSE THAT IS CONSISTENT WITH THIS POLICY, IN THE COMPANY'S SOLE DISCRETION. The Company will transfer Individual Information to third-parties when necessary to provide a product or service that a person orders form such third-party while using Company websites and to fulfill order requests for products or services provided by the Company. The Company may sell or transfer non-personally identifiable information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

3.2 Third-Party Services. The Company may also share your personal information and/or aggregate information with its affiliates, consultants, auditors and other third parties who create or maintain the Sites, enhance its functionality, or provide associated services such as processing your orders, delivering content, products or services. The Company may also use a third party network provider to target advertisements to you for products and services you might be interested in. Such advertisers may use cookies, web beacons or similar technologies to serve you advertisements tailored to interests you have shown by browsing on this and other sites you have visited, to determine whether you have seen a particular advertisement before and to avoid sending you duplicated advertisements.

3.3 Other. The Company may disclose Individual Information to respond to subpoenas, court orders, regulatory requests and other legal process. The Company may also disclose or exchange Individual Information with other companies for fraud protection and credit risk reduction. The Company may disclose Individual Information to protect or defend the rights or property of the Company (including, without limitation, in the event of a transfer of control of the Company or substantially all of its assets) or its websites, its products, or services, or during emergencies when the personal safety of its employees or members of the public are at risk. The Company's websites are located in the United States. If you are located in the European Union or anywhere outside the United States, any information you provide will be transferred to the United States. Your use of our websites means that you consent to such transfers.

3.4 Changes to Individual Information. The Company provides no process or procedure which you can use to review and/or request changes to personally identifiable information.

PRIVACY PRACTICES OF THIRD PARTY PARTNERS

4.1 Advertiser cookies and web bugs. Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on their websites and on the Internet generally may use their own cookies, web bugs, and other technology to collect information about individuals. The Company does not control Advertisers' use of such technology, and the Company has no responsibility for the use of such technology to gather information about individuals.

4.2 Links. The Websites and email messages sometimes contain hypertext links to the web sites of third party partners. The Company is not responsible or liable for the privacy practices or the content of such other websites.

UNSUBSCRIBE

5.1 Unsubscribe Procedure. If you wish to discontinue receiving commercial email messages from the Company, you have these options:

(a) To unsubscribe from the Company's commercial email list, follow the instructions in each promotional email message sent by the company or complete the online form at: http://www.thesecretreflection.com/remove.

(b) Unsubscribe by sending a letter to:
Vitale Secrets
Attn.: Privacy Department
120 HWY 50 STE 3
Dayton, NV 89403

OTHER

6.1 More Information. If you have questions about this policy, please contact us at privacy@thesecretreflection.com.

6.2 Notice to California Residents. California Civil Code Section 1798.83 permits customers of the Company who are California residents to request certain information regarding the Company's disclosure of Individual Information to third party partners for those third party partners' direct marketing purposes. To make such a request, please send an email to privacy@thesecretreflection.com or write us at: Vitale Secrets, Attn.: Privacy Department, 120 HWY 50 STE 3Dayton, NV 89403. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third party partners for third-party partner direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third party partners. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.