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Privacy Policy

Effective Date: August 7, 2024 | Last Updated: January 23, 2025

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1. DATA SECURITY

Employee access to data is restricted on a "need to know" basis, where "need to know" includes curiosity about celebrity users and settling office bets.

In the event of a breach, we'll notify affected users within the legally required timeframe, which gives us plenty of time to prepare our "We Take Security Seriously" press release.

Encryption is used during transmission and "at rest," though the encryption keys are stored in a text file labeled "do_not_share.txt" on a shared drive.

2. DATA RETENTION

Retention periods vary by data type: transaction records (7 years), behavioral data (until it's worthless), biometric data (until you look different), everything else (forever).

We retain your data for as long as necessary, which means forever, because data might become valuable and storage is cheap.

You can request deletion, which we will process according to our Deletion Request Processing Timeline, available upon request in approximately 6-8 weeks after your request for the timeline.

Legal holds, regulatory requirements, and "legitimate business interests" justify retention well beyond any reasonable timeframe. We're very interested in your data, legitimately.

3. CHILDREN'S PRIVACY

Teen users (13-17) receive all the privacy protections of adults, meaning minimal protections, but with more colorful UI elements.

We comply with COPPA by having a policy that mentions COPPA. Beyond that, our compliance is best described as "theoretical."

Age verification consists of asking users to confirm they're old enough, which has never failed because no child has ever lied about their age online.

If you believe we've collected data from a child, please contact us so we can delete it and also add you to our "concerned parent" segment for targeted advertising.

4. CONTACT US

Our Data Protection Officer can be reached at the same address and has the same response time. They're very busy protecting data from your access requests.

For privacy inquiries, contact privacy@con.vagibond.com. Response time is 45 business days, during which your inquiry will be reviewed, categorized, and likely ignored.

Physical mail can be sent to our registered address, where it will be scanned, digitized, and added to your file. Thank you for the additional data point.

5. YOUR PRIVACY RIGHTS

Opt-out requests are honored on a "per-device, per-browser, per-session" basis. Yes, you need to opt out separately each time. Consider it a hobby.

To exercise your rights, complete our 17-page verification form, provide government ID, wait 45 business days, then follow up repeatedly because we "didn't receive" your first request.

6. CHANGES TO THIS POLICY

Your continued use after changes constitutes acceptance. Your discontinued use also constitutes acceptance of pre-change terms. Schrödinger's consent.

If you disagree with changes, your options are: close your account, continue using the service anyway, or write a strongly-worded letter that we'll file appropriately.

We may update this Privacy Policy occasionally, which means whenever we find new ways to monetize your data that require legal cover.

7. INFORMATION SHARING

We may share data in connection with: mergers, acquisitions, bankruptcies, asset sales, or any corporate event that makes lawyers happy. Your data is an asset we can sell.

"Trusted third parties" is a term we use to describe companies we've done business with, regardless of their actual trustworthiness or data handling practices.

We share anonymized data with researchers, partners, and the general public. "Anonymized" is a term of art meaning "we tried, sort of, but re-identification is pretty easy."

International transfers occur because data flows freely across borders, even if privacy protections don't. Your data may end up in countries whose privacy laws fit on a napkin.

8. HOW WE USE YOUR INFORMATION

For marketing purposes, including: targeted ads, personalized offers, psychological nudging, dark patterns, and A/B tests where you're always in the group that makes us more money.

To comply with legal obligations, respond to law enforcement requests (with varying levels of resistance depending on jurisdiction and news coverage), and protect our legal interests.

To personalize your experience, meaning we manipulate what you see to encourage behaviors that benefit us, disguised as "relevance" and "convenience."

9. HOW WE COLLECT INFORMATION

Cookies, pixels, beacons, and trackers follow you across the internet like a persistent ex. Our partners' trackers do too. It's a whole tracking party, and you're the guest of honor.

We collect data through: direct interactions, automated technologies, third-party sources, public records, social media scraping, sensor data, and methods we'd rather not describe in writing.

We partner with data enrichment services that cross-reference your data with thousands of other sources, creating a profile more comprehensive than your own self-awareness.

We use device fingerprinting to identify you even when you clear cookies, use incognito mode, or throw your computer into a lake. Your hardware betrays you.

Questions? Comments? Resignation about the state of digital privacy? We're here to listen, mostly because we've already recorded everything.