Effective Date: September 16, 2020

Whatever Works VIP Privacy Policy

Potpourri Group Inc. (PGI, "we" "us") is the owner of the site WhateverWorksVIP.com, (the "Site") and has developed this Privacy Policy which details important information regarding the use and disclosure of user information collected on the Site. PGI provides this Privacy Policy to help you make an informed decision about whether to use or continue using the services found at its Site ("Services").

This Privacy Policy is incorporated into and subject to the Terms and Conditions. Each time that you access or use the Site or our Services you signify that you agree to be bound by the Terms and Conditions and this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must discontinue using the Site and accessing the Services available on the Sites.

For California residents, see below regarding your rights under the California Consumer Privacy Act of 2018. 

I. INFORMATION WE COLLECT

Information Provided by You.

Registration and Membership. We will collect personal information from you when you visit our Site, sign up for our Services, interact with our Site, register with us, or use various features of our Site. In order to register on our Site, you must first complete the registration form providing contact information (such as name, email, and address). To become a member you must also provide billing information (such as credit and/or debit card account information). This information is used for enrollment and billing purposes; to verify customer membership; and to fill customer orders. If we have trouble processing an order, the information may be used to contact you. When you provide us with information in connection with a particular activity or otherwise register for our Services or provide your contact information, including an email address or telephone number in connection with that activity, product or service, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you regarding future information about our Services using the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide us with the authorization to contact you. This means we may contact you, in person or by recorded message, by e-mail, telephone and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.

Surveys and Sweepstakes. From time-to-time we may request information from users or members via surveys or sweepstakes. Participation in these surveys or sweepstakes is completely voluntary and you therefore have a choice whether or not to disclose this information. Contact information may be used to notify the winners and award prizes and file winners as required by law. Survey information will be used for purpose of the survey, including for the monitoring or improvement of the use and satisfaction of the Site.

Web Logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) in order to improve security, analyze trends and administer the Site. We may track your movement within the Site and through our offers on affiliate websites, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the internet address from which you linked to our Site, the operating system of your computer, the unique IP address of the computer you used to access our Site, and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness of our Site, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information.

Cookies. To help make sure you receive information that is relevant to you, our Site and advertisements on affiliate sites use data "cookies." We use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser. We use persistent cookies to differentiate visitors to our Site from visitors, and registered users and members, to customize the content of certain sections of the Site, and to enable us to track and cater to the interests of users, in order to enhance their experience on the Site. A persistent cookie remains on your hard drive. You can remove persistent cookies by following directions provided in your Internet browser’s "help" file. Cookies help us learn which areas of our Site are useful and which areas need improvement. You may configure your browser to prevent cookies from being set on your computer. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site may be limited, and you may not be able to use certain features of the Site.

Web Beacons. Our web pages contain "web beacons." Web beacons allow us to count users that have visited a web page or opened an email that contains a web beacon and collect other types of aggregate information. Using this information, we are able to measure the effectiveness of our advertising and how visitors use our Site. This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of offers our registered users like to see. Some of the web beacons that are in place on our Site are used only by us, and other web beacons are from our affiliates, vendors and advertisers who use this data to assist us in analyzing how our offers and Site are accessed and used.

Supplemental Information.

We may supplement information you give us with information from other sources, such as information to validate or update your address, payment card or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to enable us to fulfill our products and services, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal business analysis or other business purposes. In the event that additional information is requested from a member to support a claim made under a specific benefit provided, we will use this information to validate the nature of the claim. This may include contacting the retailer where a purchase was made to verify that an item was purchased, the amount paid, if a benefit was utilized, or if an item has been returned.

II. HOW WE USE YOUR INFORMATION

Service Providers. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending emails, processing orders, order fulfillment and sweepstake administration and state filings. We may share your information with these third parties for those limited purposes.

Strategic Partners. We have entered into agreements with third party affiliated companies to enable us to provide our Services in connection with sales our members have made with those companies, such as shipping fees charged by those companies. In certain situations, we may provide your information to those companies informing them of your membership or to investigate a claim or inquiry regarding any benefit you may make pertaining to our Services and your interactions with those companies. Since these third parties will use your information in accordance with their own privacy practices, you should check their websites for information regarding their privacy policies.

Other Uses: We may use your personal information to contact you about the Services on our Site for which you have expressed an interest, for example, if you have contacted customer service or made an inquiry.

Announcements. We may send you service-related announcements and emails from time to time relating to your account. These include emails such as order confirmations, renewal/expiration notices, and payment-card problem notifications. We may also send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if any service is temporarily suspended for maintenance, or the delivery of a service is delayed we might send you a notice, or if there is some service issue with something you might have requested. You may not opt-out of these communications, which are not promotional in nature.

Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms and Conditions, or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat.

Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information of our visitors and registered users and members may be one of the assets sold or merged in connection with that transaction. Information about our visitors may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding. In such transactions, personal information will be subject to the promises made in any pre-existing Privacy Policy in effect when the information was obtained.

III. ACCESS TO YOUR INFORMATION

If you have an online account with us, you also may choose to resign and deactivate your account at any time. Please visit our FAQ for removal information for your particular product. After you close your account, you will not be able to sign in to our Site or access any of your personal information. However, you can open a new, separate account at any time or re-activate your previous account by logging in again. If for any reason you are concerned that the personal information you provided to us is not correct and you cannot change it by accessing your account, or should you wish to have your email address removed from our mailing list or contact information changed, please contact us at [email protected]. We will be happy to review, update or remove information as appropriate. If you deactivate your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, resolve disputes, enforce our Terms and Conditions or other policies, take actions we deem necessary due to technical and legal requirements and constraints related to the security, integrity and operation of our Site. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.

IV. CHOICE AND OPT OUT

You may remove your information from our database so as not to receive future promotional communications or to close your account by emailing us at [email protected] or sending mail to the following address:

Whatever Works VIP
P.O. Box 290728
Wethersfield, CT 06129-0728

If you prefer not to receive electronic promotional communications from us, you can also opt-out by following the unsubscribe instructions included in each communication.

Please note, changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personally identifiable information removed from our database. We will endeavor to comply with your request as soon as reasonably possible. Note that despite any request for removal of or change to personally identifiable information, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. This residual information will be retained in accordance with applicable law.  

V. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Links to other sites. To the extent hyperlinks may be utilized to access external or third party sites or if you come to our Site through a link from any such third party sites, you should be aware that these external or third party sites are not controlled by us and, therefore, are not subject to this Privacy Policy. We recommend that you check the privacy policies of these sites to determine how your personal information will be utilized by the proprietors of those third party sites.

Security. When you enter credit card information on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). While using the encryption software, the lock icon on the bottom of Web browsers such as Google Chrome and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just 'surfing'. We also take precautions offline to protect your information. However, despite our efforts, no system can completely guarantee that there will never be unauthorized access to your personally identifiable information, and your use of the Site indicates that you are willing to assume this risk.

A Note To International Users. The Site is hosted in the United States. If you are accessing the Site from outside the United States, by providing your information to the Site, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this Privacy Policy and our Terms and Conditions. You are also consenting to the application of United States law in all matters concerning the Site.

Children's Privacy. The Site is not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Site.

Changes to the Privacy Policy. We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Site, with the "Effective Date" posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your personal information, you will know because the Effective Date of the Privacy Policy will change. If we are going to use any personal information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. If you do not consent, your personal information will be used as agreed to under the terms of the privacy policy in effect at the time we obtained that information. By accessing our Site or Services after the Effective Date, you are deemed to consent to our then-current privacy policy. We will use information previously obtained in accordance with the privacy policy in effect when the information was obtained from you.

Applicable Law. If you choose to visit the Site your visit and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions including limitations on damages, and governing law. By visiting the Site, you agree that the laws of the Commonwealth of Massachusetts, without regard to its conflict of laws principles, govern this privacy policy and any dispute of any sort that might arise between us or our affiliates. We participate in the Better Business Bureau's BBB OnLine Program. This means that we have committed to cooperating with BBB efforts to resolve disputes that may arise from your use of access to the Site or our products or services. Upon your request, we will agree to participate in a BBB dispute resolution process to resolve these disputes. There are limits as to the kinds of claims that the BBB will handle -- call the BBB for more information. Other than for those disputes resolved through the BBB dispute resolution process, you consent to exclusive jurisdiction and venue in the courts of the Commonwealth of Massachusetts.

Your California Privacy Rights.

As described above, we collect various types of personal information about you when you visit our Site, sign up for our Services, interact with our Site, register with us, or use various features of our Site.  If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with certain rights regarding your personal information.  This section describes your CCPA rights and how to exercise them. 

 

  • You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve months. Once we receive and verify your request, we will disclose to you:

 

The categories of personal information we collected about you.

  • The categories of sources from which the personal information is collected.
  • The specific pieces of personal information we collected about you.
  • Our business or commercial purpose for collecting or selling any personal information.
  • The purposes for which the information we collected will be used.
  • The categories of third parties with whom we share personal information.
  • If we sold or disclosed your personal information for a business purpose; and, if so, any categories of personal information that were sold or disclosed, and the categories of any third parties to whom personal information was sold or disclosed.
  • If you wish to request the description of collection and use of your personal information over the past 12 months, please use the following link to form or write to us at the address in the Contacting Us section below.
  • You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

  • We may deny your deletion request if retaining the information is necessary for us or our service providers to:
    • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our agreement with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act.
    • Enable internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
  • If you wish to request that we remove any of your personal information that we collected from you, please use the following link to form or write to us at the address in the Contacting Us section below.

 

Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. However, you may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request up to two times within a twelve-month period, without charge. Unfortunately, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension time period (up to 90 days). If you have an account with us, we will deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt. The response we provide will also explain any reasons we cannot comply with a request, if applicable.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Contacting Us.If you have any questions about this Privacy Policy, or the practices of the Site, please visit our Contact Us or write to us at:

Whatever Works VIP
P.O. Box 290728
Wethersfield, CT 06129-0728