ABC PHONES OF NORTH CAROLINA, INC. (“VICTRA”)

PRIVACY NOTICE

Last Updated: February 14, 2025

  1. INTRODUCTION

At VICTRA (“we”, “us,” or “our”), we are committed to maintaining strong and meaningful privacy protections for our visitors (“you,” “user,” “customer,” or “consumer”). This privacy notice (“Privacy Notice”) is designed to inform you about the personal information (“Personal Information”) we collect, how we use and share it, and the choices you have about how such information is used and shared. This Privacy Notice applies to Personal Information we collect from visitors online through the VICTRA website, https://victra.com (“Site”), mobile applications (“Apps”), and from visitors through offline channels, such as interactions in our stores or phone calls (collectively, the “Platform”). For state-specific information, please see Section 5 of this Privacy Notice.

This Privacy Notice may be updated from time to time. Please check this webpage on our Site periodically for further updates and changes. If we make material changes, we may notify you by revising the “Last Updated” date at the top of this Privacy Notice. We encourage you to review this Privacy Notice whenever you access our Site or Apps or when you otherwise interact with us. You understand and agree that your continued use of the Platform after the “Last Updated” date means that the collection, use, and sharing of your Personal Information is subject to the updated version of this Privacy Notice. This Privacy Notice is incorporated into and subject to our Terms of Use. Unless otherwise noted, your use of our Platform constitute your agreement to our use of your Personal Information in accordance with this Privacy Notice.

Verizon Privacy Notices. Additional privacy notices that apply to Verizon, Fios, and other services offered by the Verizon family of companies may be viewed in Verizon’s  Privacy Notice. For example, when you purchase a device from a Victra store, your Personal Information must be shared with Verizon to activate the device and provide you with services.

  1. COLLECTION OF PERSONAL INFORMATION

As set forth below, we may collect the following Personal Information about you. We use this Personal Information to operate our Platform, carry out our business, comply with applicable laws, and for other purposes described in this Privacy Notice.

Information We Collect Directly.

We collect Personal Information that you provide when you interact with us, including, but not limited to, when you purchase a product or services, visit our store, participate in a sweepstakes or promotions, attend an event, contact us, request information, or complete a survey. We may also collect photos, images, or video of you when you visit our stores and recordings of your voice when you call customer service. You can limit the Personal Information you provide to us, but if you choose not to provide certain requested information, you may be unable to access some of the functionality, offers, or content available on our Platform.

Financial incentives. From time to time, we may offer coupons, discounts, and other promotions whether online or in stores, in exchange for voluntarily providing us with your email address and/or cell phone number (“Incentive Programs”). No purchase is necessary to participate. We use the information you provide in accordance with this Privacy Notice. All Incentive Programs are provided to you in exchange for the value of your Personal Information to the Company. We use the Personal Information we collect from the Incentive Programs for lead capture, marketing, research, and product development purposes. The financial incentive we provide in exchange for your Personal Information (e.g., discounts, special offers) is reasonably related to the value of your Personal Information to us. You must opt in to participate in an Incentive Program. By opting in to an Incentive Program, you authorize us, our affiliates, and partners to send marketing communications to you. You can withdraw from an Incentive Program at any time by following the unsubscribe/opt-out button in communications sent to you.

Social media and related services or websites. We may collect information about you through your social media services consistent with your settings on such services or from publicly available websites consistent with their terms and conditions. If you create an account or access our Site using credentials from a third-party social media platform (e.g., Facebook), we have access to certain information from that platform, such as your name, email address, friends list and public profile information, in accordance with the authorization procedures determined by that platform.

Third Parties. As noted above, we may collect information about you from third parties that are lawfully entitled to share your Personal Information with us such as our subsidiaries, related entities and affiliates; service providers and contractors; your family and friends; our business partners; marketing and advertising companies; vendor partners; your references, etc. We may combine or link information we receive from third parties with information we have about you.

Store Cameras and audio recordings. We may collect Personal Information through cameras located in and around our stores. We use this information for operational purposes such as measuring traffic patterns, tracking in-stock levels, as well as for fraud and theft prevention and security. We may also record your call to customer services for customer service management and quality control purposes.

Information We Collect Passively or Automatically.

Any time you use our Platform, we may collect the following Personal Information:

  • Means used to access our Site or Apps;
  • Precise location of your device or information about your approximate location each time you access our Site or Apps, in accordance with your device permissions;
  • Internet Protocol (“IP”) address or other unique identifier of your computer, cell phone, or other device used to access our Site or Apps;
  • Browser information and reference site domain name when you visit our Site or Apps;
  • Device identifier when using our Site or Apps;
  • Session data (e.g., your interactions with the Site or Apps, including products you recently viewed, shopping cart, browsing history, date and time, etc.); and
  • User ID when using the Apps.
  1. HOW WE USE PERSONAL INFORMATION

In general, we use Personal Information we collect only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, or as otherwise provided in this Privacy Notice. For example, we may use your Personal Information in the following ways:

  • To communicate with you including to fulfill or meet the reason you provided the information, respond to your comments, questions and requests for information; provide customer service; send you technical notices, updates, security alerts, support and administrative messages; send you confirmations, receipts, invoices, marketing messages; provide information related to insurance or warranty coverage.
  • To provide and deliver products and services; process your payments, transactions and returns; for purposes related to warranties and repairs; to prevent transactional fraud. We may also save your information to facilitate new product orders or process returns.
  • To provide technical support (e.g., troubleshooting).
  • Engage in advertising, promotional, and marketing activities; to deliver content and product and service offerings relevant to your interests including targeted offers and ads through our Site, third-party websites, and via email, phone or text message (with your consent, where required by law). For example, we may create look alike audiences, remarket, and retarget ads; tailor content and information we send or display to you; offer location customization and personalized recommendations, help, and instructions; personalize your experience including linking or combining with other information we receive from third parties to help understand your preferences; or administer promotions, sweepstakes, gift card services.
  • Verify or enforce compliance with the Terms of Use and policies that govern our Platform.
  • To administer the Site; provide support, personalize your Site experience, analyze Site usage, and develop our Site.
  • To create, maintain, customize, and secure your customer profile.
  • To conduct research and development; monitor and analyze trends, usage and activities relating to the Site and its functionality, in-store activity, purchases, and experiences.
  • For other everyday business purposes (e.g., financial account management, product development, contract management, IT and website administration, corporate governance, record keeping, reporting and legal compliance, internal investigations, quality control and monitoring customer service response).
  • To prevent, detect, and investigate fraud and other suspected illegal activities; protect the rights, property, security, and safety of Victra, our Site, our employees, customers and others.
  • To investigate claims or allegations; establish, exercise or defend a legal claim; enforce our rights arising from any contracts entered between you and us including billing and collection; to respond to law enforcement requests and as required by applicable law or court order; and for other lawful processes or public safety purposes.
  • To provide ADA requested accommodations.
  • To comply with legal and regulatory obligations (e.g., certain laws and regulations may require us to process your Personal Information. For example, we may collect your age to comply with laws applicable to the collection and disclosure of Personal Information belonging to minors.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
  • To fulfill any other purpose for which you provide it.
  1. DISCLOSURE OF PERSONAL INFORMATION

In general, we will not disclose your Personal Information except with your consent and as described in this Privacy Notice unless otherwise permitted or required by law. To carry out such purposes, we may disclose your Personal Information to:

  • Our related entities or affiliates. (e.g., for assistance with our or their advertising or marketing).
  • Service providers and contractors who collect or process information on our behalf (e.g., to help us offer, provide, repair, and bill for products and services, for Site operation or hosting, fulfillment services, payment authorization and processing, email services, HR management, tax reporting, security, fraud protection and credit risk reduction, product customization, marketing and promotional services including material distribution, website evaluation, website analytics including session recording services, chatbot services, biometric data collection services, IT services, cloud storage, background checks, benefits administration). These third parties are not authorized to use or disclose Personal Information you provide to us on or through the Site for any purpose other than to perform the services designated by us.
  • Third party marketing companies that assist us with creating marketing profiles, delivering targeted ads, etc.
  • Business partners (e.g., as part of promotions or events).
  • Manufacturers and others related to repairs and warranty coverage.
  • Third parties and vendors (e.g., advertising and marketing vendors; financing; credit companies and collection agencies).
  • Professional advisors (e.g., lawyers, accountants, auditors, bankers, insurers).
  • Social networks.

We may disclose your Personal Information to third parties as necessary:

  • When needed by outside auditors and regulators.
  • To comply with federal, state, or local laws.
  • To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
  • To cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws.
  • To protect you, others, or us.
  • To investigate allegations or claims and establish, exercise or defend legal claims.
  • In connection with a merger or sale involving all or part of our Site or as part of a corporate reorganization, stock sale or other change of control. Personal Information that we have collected about may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets.

The following tables describes the categories of Personal Information we may collect or may have collected about you, the categories of third parties to whom we may disclose or may have disclosed Personal Information, and the categories of third parties to whom we may “sell”/”share” or may have sold/shared (as those terms are defined by the applicable state consumer data protection law) your Personal Information in the preceding twelve months.

Category Examples Collected
A. Identifiers.

 

 A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

 Yes
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
E. Biometric information.

 

 Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Yes
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location or movements. Yes
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

We may disclose your Personal Information to a third party for a business purpose subject to confidentiality and non-use restrictions, which disclosure practices are further detailed in the table below.

Personal Data Category Categories of Third-Party Recipients
Business Purpose Disclosures Sales or Sharing for Cross-Context Behavioral Ads
A. Identifiers.

 

 ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
C. Protected classification characteristics under California or federal law. ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
D. Commercial information. ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
E. Biometric information.

 

 ·       Vendors, contractors and service providers.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Other third parties as directed by you.

 None
F. Internet or other similar network activity. ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
G. Geolocation data. ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
H. Sensory data. ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
I. Professional or employment-related information. ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.
K. Inferences drawn from other personal information. ·       Affiliates and related entities.

·       Vendors, contractors and service providers.

·       Business partners.

·       Manufacturers and others related to warranty coverage.

·       Third parties as required by law or administrative orders and similar disclosures.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

·       Third-party links and widgets.

·       Governmental entities, including law enforcement.

·       Professional advisors, such as accountants and lawyers.

·       Other third parties as directed by you.

 ·       Affiliates and related entities.

·       Business partners.

·       Advertising and marketing companies.

·       Third parties in connection with a merger, divestiture, sale, or asset transfer.

 

  1. S. STATE PRIVACY RIGHTS

U.S. state consumer privacy laws may provide residents with additional rights regarding our use of their Personal Information. California, Colorado, Connecticut, Delaware, Florida, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia provide their state residents with certain rights, including:

  • Confirming whether we process Personal Information.
  • Accessing and deleting certain Personal Information.
  • Correcting inaccuracies in Personal Information, taking into account the nature of the processing purpose (excluding Iowa and Utah).
  • Data portability.
  • Opt-out of the processing of the Personal Information for:
    • targeted advertising (excluding Iowa);
    • sales; or
    • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limiting (opt-out of) or requiring consent to process sensitive Personal Information.
  • Non-discrimination against consumers for exercising rights.

Nevada provides its residents with a limited right to opt-out of certain Personal Information sales. Nevada residents who wish to exercise this sale opt-out rights may submit a request to us via email at [email protected] or call us at 1-800-279-3550.

The exact scope of consumer privacy rights may vary by state. Where permitted by law, we reserve the right to respond only to a verifiable consumer request to exercise a right. A verifiable request may be made by any of the following:

  • the consumer who is the subject of the request,
  • a consumer on behalf of the consumer’s minor child, or
  • a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer, where permitted by applicable law.

You are required to provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide Personal Information that we already maintain about you or we may use a third-party verification service. We may not be able to respond to your request if we cannot verify your identity or authority to make the request and/or confirm the Personal Information relates to you. Please note that making a consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond to such request. We will not use the Personal Information we collect from an individual to determine a verifiable request for any other purpose, except as required by law.

Fees. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will attempt to respond to a verifiable consumer request within forty-five days of receipt, but we may require up to ninety days to respond, under which circumstances we will notify you of the need for an extension.

Response. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve-month period preceding the receipt of your verifiable consumer request.

To exercise a consumer privacy right or to appeal a decision regarding a consumer rights request, please contact us at the following:

  • Call: 1-800-279-3550.

California’s “Shine the Light Law.” If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of Personal Information and the names and addresses of third parties with whom we shared the Personal Information for the immediately prior calendar year. You may submit your request using the information provided in Section 14, “Contact Us,” below.

  1. COOKIES AND WEB TECHNOLOGIES

Our Site and Apps use cookies and other web technologies to collect and store certain information when you visit or use the Site or Apps.

A cookie is a small file consisting of letters and numbers. This file uniquely identifies and recognizes your browser or device and transmits information to the server. Some of these cookies are placed by us (i.e., first-party cookies) and others are placed by third parties (i.e., third party cookies). We use the following cookies on our Site:

  • Strictly Necessary/ or Essential Cookies: These cookies are essential to the basic operation of our Site. They help identify you when you sign in, remember the information you input in an online form or shopping cart, enable you to navigate around our Site or Apps, use its features, or provide you with services you have requested. Without these cookies, we may be unable to provide the Site, Apps, or certain services or features on the Site or Apps.
  • Performance/Analytics Cookies: These cookies gather information on your use of our Site. For example, how you interact with the Site so we can improve it and whether the Site is working properly. Some of these cookies may be analytics cookies set by companies that analyze how you use our Site in order to help us improve and optimize our Site, Apps, and the products and services we offer.
  • Functionality/Personalization Cookies: These cookies help save information you have entered so the Site can recognize you, remember your username, remember your choices such as font size and color or language, or personalize Site content when you return. The information these cookies collect may be anonymized and set by us or by a third party.
  • Advertising/ or Targeting Cookies: These cookies help us provide relevant advertising to you, measure its effectiveness, or limit the number of times you have seen it. They may record your visit to our Site including the links you follow to other sites so we can tailor our Site, communications, and advertising or remember whether you have visited the Site before. These technologies may also collect information including details about the device you use to access the Site, your IP address, browser type, and operating system.

Some of these cookies may follow you when you leave the Site and travel to other websites so that we can serve personalized ads targeted to your preferences. We may place some of these cookies on your device or third parties may place them when you visit the Site to serve advertisements (banners or links) on our behalf across the Internet. These advertising companies use tracking technologies (including cookies and pixel tags) to collect information about your visits to our Site and your interactions with our products to provide tailored advertisements based on your interests and browsing of our Site.

Our Site and Apps also use the following:

  • Pixels. These small electronic files, also known as pixels, are set by us or third parties, help with functions such as tracking, analytics, counting Site visitors or for related marketing and media services including targeted ads. These pixels may collect your email, name, order items and ID, page ID, quantity, unit price, size, and product ID. This data is aggregated and anonymized.
  • Email pixel tracking. We may embed email pixels in emails we send you. When you open the email, it sends back information. These pixels help us determine information including how many people open our emails, click on links, the percentage of recipients who read email on their phones, etc.  We use this information for marketing purposes and to learn more about our audience.
  • Facebook meta pixel. This pixel is used for analytics, tracking and serving targeted ads. It tracks information such as your page view, view content, search, add to cart, purchase information, sign up, download, submit form, or user information (IP address, browser information). This data is aggregated and anonymized.
  • URL trackers. These third party trackers are strings of code that track user behavior after clicking on a URL for analytics and marketing purposes. This data is aggregated and does not collect data on individuals.
  • Browser/device/online fingerprinting. These tools use scripts to track the attributes of the visitor’s device or browser and IP address to build a profile of the user.
  • Chatbot. Our website uses chatbots which are operated by humans and not bots to help process and respond to user questions. The chatbots help with customer service, analytics and tracking. The user’s interaction with the chatbot is recorded and used for customer relations management history.  A third party helps operate these bots for us, including storing and processing the information collected through the bots.
  • Session replay. We may use web technology tools to record you interaction with the Site for tracking and to help us analyze and understand how the Site is utilized by visitors.  These tools may record information such as your clicks, scrolls and mouse movements, feedback polls, country, duration, device, name, email, ID, browser, OS, and IP address. A third party helps operate these tools for us, including storing and processing the information collected through the tools.
  • Social media widgets. Our Site includes social media features, such as the Facebook, X, Instagram, TikTok and LinkedIn widgets. These features may collect information about you such as your IP address and which pages you visit on our Site. They may set a cookie or employ other tracking technologies to accomplish this. Social media features and widgets may be hosted by a third party. Your interactions with those features are governed by the privacy policies of the companies that provide them.
  • Analytics. Our Site uses analytics tools to help us analyze utilization of the Site, track users, help with activities such as remarketing, audience or customer match. These tools collect user information (e.g., IP address, browser information, page views), shares, conversions, demographic and interest information.
  • reCAPTCHA. Our Site uses the reCatptcha tool for security purposes. Please see reCatptcha’s privacy notice for more information on its privacy practices.

When you visit or register on our Site or Apps or otherwise use our Platform, our online data partners or vendors may use cookies, ad beacons, and similar technologies to associate these activities with Personal Information they or others have about you, including your email address. We may then send communications and marketing to these email addresses. You can unsubscribe by following the directions in the email communication.

Exercising Choice. Most browsers allow you to block or refuse cookies. The Help Menu on the menu bar of many browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. If you do so, you may need to adjust your preferences manually each time you visit a website. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work and you may be required to re-enter any user IDs and passwords more frequently.

You can limit our sharing of certain types of information, known as Customer Proprietary Network Information (“CPNI”), for certain marketing uses. You can monitor or limit information that is shared by setting alerts, clearing the cache manually, or disabling cookies entirely.

  1. BROWSER-BASED DO NOT TRACK

Some browsers incorporate a Do Not Track (“DNT”) feature. When turned on, the feature signals to websites and online services that you do not want to be tracked. We track Websites users over time and across third-party websites; however, because there is no currently accepted standard for responding to a DNT signal, we do not respond to DNT signals on our Site where we provide advertisements, content, or other services. To find out more about DNT, please visit http://www.allaboutdnt.com.

  1. YOUR CHOICES AND OPT-OUT PROCEDURES

You can limit the ways we send marketing offers to you by taking the following actions:

  • Telemarketing: Opt out of marketing-related calls by sending a written request to [email protected]. Please note that it can take up to 30 days to remove you from existing marketing campaigns.
  • Emails: Opt out of receiving marketing-related emails by following the unsubscribe instructions at the bottom of marketing emails you receive.
  • Text messages: Opt out of receiving marketing-related texts by following the unsubscribe instructions included in texts you receive.
  • Postal mail: Opt out of receiving marketing-related mail by sending a written request to [email protected]. Note that even if you unsubscribe, you could still receive mail when we use a bulk mailing service that delivers to all homes within a ZIP code.

Please note that removal of Personal Information from our database or unsubscribing will not stop marketing or advertising content that has already been generated for distribution or is otherwise queued for transmission to you prior before we can implement your request. If you opt out of receiving promotional communications, we may still send you non-promotional/transactional emails, such as emails about your purchases, account verification, or as otherwise consistent with applicable law.

Location Information. The settings of your Internet browser or mobile device may allow you to stop sharing your precise location with us or others.

Emails and Click-Through URLs. Some of our email communications to you may include a click-through URL linked to a particular page on the Site. By clicking on one of these URLs, you will automatically enter our Site and we may collect information related to the click-through. To prevent having this information collected, do not click on URL links in our email communications.

Mobile Push Notifications/Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Google Analytics Opt-Out Browser Add On. If you want to opt-out, download and install the add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Safari, Firefox and Microsoft Edge. In order to function, the opt-out add-on must be able to load and execute properly on your browser. Learn more about the opt-out and how to properly install the browser add-on here. You can also visit the following URL to learn more about how to manage Google from using your user analytics. https://tools.google.com/dlpage/gaoptout

Facebook Usage Tool and Steps to Deactivate. Click here for more information on the Facebook tool and how to deactivate it.

  1. EXTERNAL LINKS AND THIRD-PARTY INTEGRATIONS

Our Site contain links to websites or resources outside of our Site for your informational purposes only. We may also provide links to third-party integrations. Third-party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as maps, sending requested information, etc. You acknowledge and agree we are not responsible for the availability of third-party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services, or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of Personal Information that you provide, or is collected by, such sites.  We encourage you to review the privacy policies and terms and conditions of any site you visit via a link from our Site.

  1. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We will retain your Personal Information for as long as needed to provide services to you (for example, to honor a warranty or as needed to fulfill our own obligations). We may also retain your Personal Information for longer if it is necessary for legitimate business purposes, including to satisfy legal or reporting obligations, resolve disputes, collect fees, improve our services or maintain security, comply with regulatory requirements, or as permitted or required by applicable law.

  1. HOW WE PROTECT PERSONAL INFORMATION

We use technical, administrative, and physical safeguards to help protect against unauthorized access to, use, or disclosure of information we collect or store. In addition, we train our employees about the importance of privacy, security, and the proper ways to access, use, and disclose Personal Information. Our practices and policies prohibit employees with whom we share this information from using Personal Information unless they are authorized to do so and have a business need.

Unfortunately, no data transmission over the Internet or any wireless network is 100% secure. As a result, while we strive to take reasonable measures to protect your Personal Information, we cannot ensure, guarantee or warrant the security of any information you transmit, and you do so at your own risk.

When we collect your Personal Information, it may be transferred to our servers in other jurisdictions, including the United States, which may not have similar data protection laws to the country in which you reside.

  1. CHILDREN’S PRIVACY 

Our Platform is not intended for children under thirteen years of age.  We do not knowingly collect Personal Information from children under thirteen. If you are under thirteen, do not use or provide any information on our Platform. If you believe we might have Personal Information from or about a child under thirteen, please contact us at [email protected]. If we learn we have collected or received Personal Information from a child under thirteen without verification of parental consent, we will delete that information.

  1. APPLICABLE LAW

This Privacy Notice is governed by the laws of North Carolina without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Notice will be exclusively with the state and federal courts of North Carolina. If any provision of this Privacy Notice is found to be invalid by a court having competent jurisdiction, the invalidity of such provision will not affect the validity of the remaining provisions of this Privacy Notice, which will remain in full force and effect.

  1. CONTACT US

If you have questions concerning this Privacy Notice, you may contact us by phone, email, or postal address, as detailed below.

Phone:                                     1-800-279-3550

Email:                                      [email protected]

Postal Address:               VICTRA

8510 Colonnade Center Drive, Suite 300

Raleigh, North Carolina 27615