GoVyrl, Inc. is headquartered in the State of California in the United States (“we,” “us,” “our,” and “GoVyrl”) and operates a variety of Websites and online marketing services and applications, including the Carro application and Carro APIs (the “Services”).
GoVyrl is passionate about connecting Brands with their customers, subscribers, and social media followers. Our Services enable Brands to identify and communicate with Contacts and Influencers in their networks for their marketing purposes. Our Services also enable Brands to get real-time data analytics on how their Contacts and Influencers are interacting with their Brand. Our Services also provide Contacts and Influencers with the opportunity to receive discounts and free items from the Brands that they already love and follow.
Find out more about our Services at www.vyrl.co and www.getcarro.com.
In this privacy policy, these terms have the following meanings:
“Contact” is a person a Brand may contact through our Services. In other words, a Contact is anyone on a Brand’s Distribution List or about whom a Brand has given us information. For example, if you are a Brand, a subscriber to your email marketing campaign, a social media follower, or a purchaser of your products, would be considered a Contact.
“Influencer” is a person with 5,000 or more followers on a social media network. This number may be updated from time to time. Brands may have Contacts who are Influencers in their Brand’s Distribution Lists. Influencers may also choose to opt-in to our Services directly for the purposes of receiving communications and discounts from Brands.
“Distribution List” is a list of Contacts a Member may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).
“Brand” means any person or entity that is registered with us to use the Brand-side Services.
“Personal Information” means any information that reasonably identifies a natural person who is a Brand, a Contact, an Influencer, or a Visitor. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
“Website(s)” means any website(s) we own and operate (such as www.vyrl.co or www.getcarro.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs,” or other online, mobile, or wireless offerings that post a link to this privacy policy.
“Visitor” means any natural person who visits any of our Websites.
“You” and “your” means, depending on the context, either a Member, a Contact, an Influencer, or a Visitor.
This section applies to the Personal Information we collect and process from individuals who are Brands or potential Brands through the provision of the Services. If you are not a Brand, the Contacts and Influencers or Visitors section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Brands and potential Brands.
The Personal Information that we may collect broadly falls into the following categories:
Information You Give Us. You may give us information about you. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with Carro), or communicate with us in any other way. The categories of information include:
You may also give us information about Contacts in your Distribution List. Please see the Additional Terms for Brands for your obligations with respect to the privacy of your Contacts’ data.
Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookie Policy.
The categories of information include:
We generally collect this information in the aggregate. We do not associate this information with you or your computer, unless you specifically ask us to troubleshoot any technical or security issues you have with using our websites, or we need to investigate a violation of our Terms.
Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public databases, public profiles on social media platforms, and third-party data providers. We take steps to ensure that such third parties are legally and/or contractually permitted to disclose such information to us.
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:
Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. For example, we use third-party credit card processors to process billing and payments. These service providers are under a duty of confidentiality.
Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, we share your information with third party marketing and advertising partners, such as Google, Facebook, Instagram, and YouTube to provide tailored advertising on our Sites and other websites that you may visit.
Third Party Links and Websites. Our website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.
Social Media. Our website may include social media buttons or widgets (“social media elements”). These social media elements may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media elements are governed by the privacy policy of the social media company providing the feature and/or widget.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
If you are from the European Economic Area, our legal bases for collecting and using your Personal Information is as follows:
If you have questions about or need further information concerning the legal bases on which we collect and use your Personal Information, please contact us using the contact details provided in the “Contact Information” section below.
This section applies to the Personal Information we collect and process from individuals who are Contacts or Influencers. If you are not a Contact or Influencer, the Brand or Visitors section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Contacts and Influencers.
The Personal Information that we may collect broadly falls into the following categories:
Information We Receive From Brands. Brands may provide us Personal Information about you through the Services. For example, when a Brand uploads their Distribution List or integrates the Services with another website or service (for example, when a Brand chooses to connect their e-commerce account with Carro), or when you sign up for a Brand’s Distribution List through the Carro signup procedure, they may provide us with your Personal Information. This information includes:
Brands are responsible for their privacy and security practices. You may have the opportunity to update some of your information by electing to update or manage your preferences directly with the Brand.
Information You Give Us. If you are a Contact or an Influencer, you may choose to give us information about you directly. You may provide us information in the following ways:
The categories of information include:
Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookie Policy.
The categories of information include:
We generally collect this information in the aggregate to improve our services. We do not associate this information with you or your computer, unless:
Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public databases, public profiles on social media platforms, public posts on social media platforms, and third-party data resellers. We take steps to ensure that such third parties are legally and contractually permitted to disclose such information to us.
We may use the Personal Information we collect from Brands or other sources for a range of reasons, including:
Brands. We share your public information with Brands that you already follow or buy from, so Brands can contact you with offers for discounted or free products. We may share this information with Brands through avenues such as the Carro browser dashboard, the Carro application dashboard, or through tools and APIs that may integrate with our products and/or services. In order to help protect your privacy, we ask Brands to abide by our Additional Terms for Brands. These terms require Brands to only communicate with (i) Contacts or Influencers that they already have a relationship with, or (ii) Influencers that have opted-in directly to our Services for the purposes of receiving communications and discounts from Brands. These terms also require Brands to respect your privacy when they contact you. If you would like to opt out of this sharing of information with Brands in exchange for discounted or free products, please contact us at the contact information below or submit a request online.
Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. These service providers are under a duty of confidentiality.
Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, we share your information with third party marketing and advertising partners, such as Google, Facebook, Instagram, and YouTube to provide tailored advertising on our Sites and other websites that you may visit.
Third Party Links and Websites. Our website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.
Social Media. Our website may include social media buttons or widgets (“social media elements”). These social media elements may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media elements are governed by the privacy policy of the social media company providing the feature and/or widget.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
Deidentified and Aggregate Data. We may share deidentified and aggregate data with Brands or other third parties to analyze sales and customer trends. This data cannot be reasonably identified to an individual and is not Personal Information.
If you are from the European Economic Area, our legal bases for collecting and using your Personal Information is as follows:
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the “Contact Information” section below.
This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our sales and marketing activities, recruitment, and events. In this section “you” and “your” refers to Visitors.
If you sign up for a GoVyrl account and use it to communicate with Brands, please go to Section 3 regarding Privacy for Contacts and Influencers.
The Personal Information that we may collect broadly falls into the following categories:
Information You Give Us. If you are a Visitor, you may choose to give us information about you directly. You may provide us information in the following ways:
The categories of information include:
Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookie Policy.
The categories of information include:
We generally collect this information in the aggregate to improve the performance of our Websites. We do not associate this information with you or your computer, unless we need to investigate a violation of our Terms.
We may use the Personal Information we collect for a range of reasons, including:
Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. These service providers are under a duty of confidentiality.
Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, we share your information with third party marketing and advertising partners, such as Google, Facebook, Instagram, and YouTube to provide tailored advertising on our Websites and other websites that you may visit.
Third Party Links and Websites. Our Websites may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.
Social Media. Our website may include social media buttons or widgets (“social media elements”). These social media elements may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media elements are governed by the privacy policy of the social media company providing the feature and/or widget.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
If you are from the European Economic Area, our legal bases for collecting and using your Personal Information is as follows:
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the “Contact Information” section below.
Marketing Opt-Out From Brands: If you no longer want to be contacted by one of our Brands through our Services, please unsubscribe directly from that Brand’s email list or contact the Brand directly to update or delete your data.
Marketing Opt-Out From GoVyrl Communications: If you have opted-in to GoVyrl or Carro directly, we may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send. You will still continue to receive service-related messages concerning our Services.
Opt-Out From Carro Dashboard: Influencers have the option to remove their profiles from our Brand dashboard by using the contact form below or submitting a request online. Once removed, Brands would no longer be able to contact you for partnership opportunities.
Exercising Your Privacy Rights: We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws, and may remove or update your information within a reasonable time and after providing notice to the Brand of your request. If you authenticated into the Services via Instagram, we will remove any “User Content” (as defined in the Instagram Platform Policy) or other information that you request within a reasonable time (please write to remove@getcarro.com). We may ask you to verify your identity in order to help us respond efficiently to your request.
Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the Contact Information below.
California Consumer Privacy Act. If you are a California consumer, you have the following rights beginning on January 1, 2020:
Requests for Deletion and Information. In certain circumstances, California consumers have the right to request that we delete their information. In addition, California consumers have the right to request, up to twice in a 12-month period, that a business that collects Personal Information about the consumer disclose to the consumer the information listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information.
(1) The categories of Personal Information it has collected about that consumer.
(2) The categories of sources from which the Personal Information is collected.
(3) The business or commercial purpose for collecting or selling Personal Information.
(4) The categories of third parties with whom the business shares Personal Information.
(5) The categories of Personal Information that the business sold about the consumer and the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold.
(6) The categories of Personal Information that the business disclosed about the consumer for a business purpose.
(7) The specific pieces of Personal Information it has collected about that consumer.
To make such a request, please contact us at the contact information below.
Do Not Sell My Personal Information. We are not data brokers and we do not sell your data on the open market. However, under California’s new privacy law, the California Consumer Privacy Act, some of the ways we share information may constitute a “sale.”
EEA Privacy Rights. If you are from the European Economic Area, you have the right, under certain circumstances, to:
If you are from the European Economic Area, you also have the right to lodge a complaint with a supervisory authority, under certain circumstances.
You may contact us at the contact information below for more information, or to exercise your rights.
Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States and abroad, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail a transfer of your Personal Information across international borders, including, but not limited to, transfers from within the European Economic Area (the “EEA”) to the United States. The data protections standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any Personal Information transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.
This website is not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with Personal Information, please contact us at the Contact Information below. If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete such information.
In accordance with our Additional Terms for Brands, Brands are also required to implement age-gating techniques appropriate to the products and services they provide. If you become aware that an individual or Brand has provided us with Personal Information in violation of these Additional Terms (e.g. Personal Information from individuals under 18 for tobacco products or adult services), please contact us at the Contact Information below.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
To make our Websites and Services work properly, and to provide tailored advertising, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. To learn more, please see our Cookie Policy.
Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your Personal Information.
Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine the appropriate retention period:
When we have no ongoing lawful basis to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
GoVyrl accounts require a username and password, or social media authentication, to log in. Account holders must keep their username and password secure, and never disclose it to a third party in accordance with our Terms.
We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Websites.
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact us by postal mail or email at:
For EEA Residents:
GoVyrl’s Data Protection Officer can be contacted at privacy@getcarro.com.
For Non-EEA Residents:
GoVyrl, Inc.
Attn. Privacy Officer
privacy@getcarro.com
2372 Morse Avenue, Ste. 128
Irvine, California 92614