Our Privacy Policy

INFORMATION COLLECTION

The Velvet Lily, LLC (referred to herein as "The Velvet Lily", "our", "us" or "we") is the sole owner of the information collected on our web sites and on the replicated The Velvet Lily web sites that we provide for use by independent contractor Consultants (hereafter the "web sites"). We collect information from Independent Consultants ("Consultants") and customers at different points on the web sites.

Personally Identifiable Information

Through your use of our web sites, you may be required or requested to provide personally identifiable information to us. Personally identifiable information is any piece of information which can potentially be used to uniquely identify, contact, or locate a single person including names, addresses, email addresses, telephone numbers, social security and tax identification numbers, and credit card information.

Consultant and Customer Registration

In order to become a Consultant, an applicant must provide biographical and contact information (such as name, mailing address, telephone numbers, and email address) to us. We also require an applicant’s Social Security Number or Federal Tax ID Number so that we may prepare and file necessary non-employee compensation forms for the IRS. Certain customers may be required to register in order to purchase products directly from us ("Registered Customers"). Registered Customers will be required to provide contact information (such as name, mailing address, telephone number(s), and email address) and payment information (such as credit card or checking account information). We use this information to maintain contact with the customer and to process the Registered Customer’s orders.

Downline Genealogy Reports

As a party plan company, The Velvet Lily provides certain information to Consultants regarding the other Consultants and Registered Customers enrolled in a Consultant’s marketing organization. If you enroll as a Consultant or Registered Customer with The Velvet Lily, your name, address, email address, and telephone number will be provided to your Sponsor and the Senior Event Planner above your Sponsor. No other personally identifiable information will be shared with other Consultants. Such information is made available to The Velvet Lily Consultants subject to a confidentiality and non-disclosure covenant in The Velvet Lily Policies and Procedures.

Product Ordering

When you order products from us through any of our websites, you must provide us with mailing and contact information as well as payment information. This information is used for billing and payment purposes and to fill orders.

INFORMATION USE

Personally Identifiable Information

Personally identifiable information that is collected from Consultants and customers through Consultant and Customer Registration, Product Ordering and/or Surveys is used as described above. The Velvet Lily DOES NOT share personally identifiable information except as may be necessary to fill an order. The Velvet Lily may share aggregated information from time to time with its partners, vendors or other third parties. When such aggregate information is shared by The Velvet Lily, no personally identifiable information is shared.

Profile Information

The Velvet Lily stores information that it collects through cookies, log files, clear gifs, and/or third parties to create a profile of visitors to our web sites ("users"). A profile is stored information that The Velvet Lily keeps on individual users, including Consultants and customers, that details their viewing preferences. Profile information is tied to the user’s personally identifiable information to provide offers and improve the content of the site for the user. The Velvet Lily does not share profile information with other third parties.

Cookies

A cookie is a piece of data stored on a user’s computer tied to information about the user. Cookies can be removed by following Internet browser help file directions.

By setting a cookie on a user’s computer, users do not have to log in a password more than once, thereby saving time while at the web sites. If a user rejects the cookie, the user will still be able to use the site. The only drawback to this is that the user may need to enter his or her password every time he or she accesses the site.

Log Files

Like most standard web site servers The Velvet Lily’s web sites use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. We use a tracking utility that uses log files to analyze user movement.

Clear Gifs (Web Beacons/Web Bugs)

The Velvet Lily employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help The Velvet Lily to better manage content on the web sites by informing it what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence.

In addition, The Velvet Lily uses clear gifs in its HTML-based emails to let it know which emails have been opened by the recipients. This allows The Velvet Lily to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

COMMUNICATIONS FROM US

Special Offers and Updates

The Velvet Lily sends all new Consultants and Registered Customers a welcoming email to verify password, username, and acceptance of the Consultant Agreement or Customer Agreement. All Consultants and Registered Customers will occasionally receive information on products, services, special deals, and a newsletter. Customers who have not registered with The Velvet Lily and who grant permission will also receive occasional information on products, services, special deals, and the like.

Service Announcements

On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send Consultants and/or customers an email. Generally, Consultants may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

Consultant and Customer Service

The Velvet Lily communicates with Consultants via email, regular mail and telephone on a regular basis to provide requested services and in regards to issues relating to their The Velvet Lily business.

SHARING

Legal Disclaimer

Though The Velvet Lily makes every effort to preserve user privacy, The Velvet Lily may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on The Velvet Lily.

Aggregate Information (non-personally identifiable)

The Velvet Lily shares aggregated demographic information with our partners and advertisers. This is not linked to any personally identifiable information.

These are the instances in which we will share users’ personal information: The Velvet Lily DOES NOT Share Personally Identifiable Information about users with any Third Parties except as provided in this Privacy Policy.

Third Party Fulfillment

The Velvet Lily uses an outside shipping company to ship orders, and a credit card processing company to bill Consultants for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.

Service Providers

The Velvet Lily partners with other third parties to provide specific services. When necessary to provide services or products to Consultants and customers, we share names and/or other contact information with service providers and vendors. Such third parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Business Transitions

In the event The Velvet Lily goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, the personal information of Consultants and customers will, in most instances, be part of the assets transferred. If as a result of the business transition, a Consultant’s or customer’s personally identifiable information will be used in a manner different from that stated at the time of collection, the Consultant or customer will be given choice consistent with our notification of changes section.

Choice

Users are always notified when their information is being collected by any outside parties. We do this so users can make an informed choice as to whether or not they should proceed with services that require an outside party.

Links

The Velvet Lily’s web sites may contain links to other sites. Please be aware that The Velvet Lily is not responsible for the privacy practices of such other sites. We encourage users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by The Velvet Lily web sites.

Security

The Velvet Lily takes every precaution to protect all users’ information. When users submit sensitive information via The Velvet Lily’s web sites, their information is protected both online and off-line.

When the Consultant Application, Customer Registration, and/or online order forms ask users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with the best encryption software in the industry - SSL. While on a secure page, such as the Consultant Application and Agreement and online order forms, the lock icon on the bottom of web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just 'surfing'.

While The Velvet Lily uses SSL encryption to protect sensitive information online, the Company also does everything in our power to protect user information off-line. All user information, not just the sensitive information mentioned above, is restricted in The Velvet Lily’s offices. Only employees who need the information to perform a specific job are granted access to personally identifiable information. ALL employees are kept up-to-date on Company security and privacy practices. Finally, the servers that store personally identifiable information are in a secure environment.

MISCELLANEOUS

Changes to this Privacy Policy

The Velvet Lily reserves the right to amend or change this Privacy Policy at any time at its sole discretion. It is your responsibility to periodically access this Privacy Policy by clicking on the Privacy Policy link at our home page. When material changes or amendments are made to the Privacy Policy, we will announce the same at our home page for a period of 30 days following implementation of the amended Privacy Policy.

Making Changes to Your Personally Identifiable Information Consultants and Registered Customers may update your personal information as necessary by logging into the Back Office, which allows them to access and edit their registration account information. In addition, you may contact us at support@thevelvetlily.com to update your profile.

Minors

The Velvet Lily is committed to the safety of our children. Persons under the age of 18 may not enroll as The Velvet Lily Consultants, register as customers, or purchase products through any of our web sites. We do not knowingly collect any personal information from minors at this site or any of its other sites.

Questions

Questions regarding this Privacy Policy should be directed to support@thevelvetlily.com, or by mail to The Velvet Lily, 51 North 3rd Street, Suite 118, Philadelphia, Pennsylvania 19106.

Effective Date

The effective date of this Privacy Policy is January 15, 2009.