Privacy Policy, vlvt

1. Who we are

vlvt is a private membership concierge service operated by VLVT Ventures, Inc., a Delaware corporation. In this policy, "vlvt", "we", "us", and "our" mean VLVT Ventures, Inc. "You" and "member" mean the individual whose information we handle.

This policy explains what we collect, why we collect it, who we share it with, and the choices you have. It applies to the vlvt concierge service, the vlvt concierge messaging programme, and this website.

2. Information we collect

We collect only what we need to run a concierge service for you.

Identity and contact information: Your name, mobile telephone number, email address, and postal address where relevant to a booking.
Membership information: Your membership tier, agreement details, concierge assignment, and billing records.
Request and preference information: What you ask us for, and the context needed to deliver it well. This can include travel dates and itineraries, dining and seating preferences, dietary requirements and allergies, party composition, accessibility needs, loyalty programme numbers, and notes on what worked previously.
Communications: The content of your text messages, emails, and calls with your concierge, and the records of when they were sent, received, and delivered.
Payment information: Billing details needed to charge membership fees and to arrange payment to suppliers. Card numbers are handled by our payment processors, and we do not store full card numbers on our own systems.
Information about people you nominate: Details of household members, assistants, guests, or travelling companions that you ask us to act for. You confirm you are authorised to share those details with us.
Website information: Standard server log information such as IP address, browser type, and pages requested, used to keep the site available and secure.

Some request information, such as dietary requirements, allergies, accessibility needs, or health-related travel constraints, may be sensitive. We collect it only when you provide it for the purpose of fulfilling your request, and we use it only for that purpose.

3. Phone numbers and SMS data

Concierge messaging is central to the service, so we set out its handling separately.

What we hold. Your mobile number, the record of your opt-in and any opt-out, the content of messages exchanged with your concierge, and carrier delivery metadata such as timestamps and delivery status.
Why we hold it. To route your requests to your concierge, to reply to you, to maintain a record of the commitments we have made to you, and to comply with messaging regulations and carrier requirements.
Who processes it. Our messaging provider transmits messages on our behalf and processes them only under our instructions. Mobile carriers necessarily handle messages in order to deliver them.

We do not sell your phone number, and we do not share your mobile number, your SMS opt-in status, or your consent records with third parties or affiliates for their own marketing or promotional purposes.

The vlvt concierge messaging programme carries service messages only. We do not send promotional or advertising text messages. You can end concierge messages at any time by replying STOP, or get help by replying HELP. Message and data rates may apply. See the SMS programme terms for full detail.

4. How we use information

To fulfil your requests, place bookings, and coordinate suppliers on your behalf.
To give your concierge the context needed to serve you without making you repeat yourself.
To communicate with you about arrangements in progress, confirmations, and changes.
To administer your membership, invoice you, and arrange supplier payments.
To keep records of the commitments we have made and the outcomes we delivered.
To maintain the security, integrity, and availability of our systems.
To improve our service quality and internal training, using the minimum information necessary.
To comply with law, including tax, sanctions, and messaging compliance obligations, and to resolve disputes.

We do not use your information to build advertising profiles, and we do not use it for automated decisions that produce legal effects for you.

5. AI and automated processing

vlvt uses automated systems, including large language models, to help your concierge retrieve context, structure requests, source options, draft candidate replies, and track commitments. This processing supports a human concierge who reviews and approves every message sent to you and every commitment made on your behalf.

Where request content is processed by a third-party model provider, we send only what is needed for the task, that provider acts as our processor under contract, and the provider is not permitted to use your content to train its own general-purpose models.

We share your information only in these circumstances.

With suppliers, to fulfil your request: A restaurant needs your name, party size, time, and dietary notes. A hotel needs your name and stay details. An operator may need documentation for travel. We share the minimum the supplier needs to deliver what you asked for.
With service providers acting for us: Messaging, email, cloud hosting, database, payment processing, and AI model providers. Each is bound by contract to process your information only on our instructions, and only for the purpose we specify.
With people you nominate: Where you ask us to coordinate with an assistant, a household member, or a travelling companion.
Where the law requires it: In response to a valid legal request, to protect our legal rights, or to prevent fraud or harm.
In a corporate transaction: If vlvt is involved in a merger, acquisition, financing, or sale of assets, information may transfer as part of it, subject to this policy continuing to apply.

7. No sale, no marketing sharing

We do not sell your personal information. We do not rent, trade, or otherwise disclose your personal information to third parties for their own marketing purposes. We do not share your mobile number or SMS consent records with anyone for marketing, and we do not permit our service providers to use your information for their own purposes.

8. How long we keep information

We keep your information for as long as you hold a vlvt membership, and afterwards only for as long as we need it. Membership and financial records are retained for the periods required by tax and accounting law. Messaging consent and opt-out records are retained for as long as needed to honour your choice and to evidence compliance with messaging regulations. Request history is retained while it remains useful to serving you, and is deleted or de-identified when it is not.

9. Security

We protect member information with encryption in transit, access controls limited to staff who need the information to do their work, audit logging of access to member records, and hosting with reputable infrastructure providers. No system is perfectly secure, and we cannot guarantee absolute security, but we will tell you promptly if a breach affects your information and the law requires notice.

10. Your choices and rights

Access and portability. Ask us for a copy of the information we hold about you.
Correction. Ask us to fix anything inaccurate. Your concierge can do this directly.
Deletion. Ask us to delete your information, subject to records we must keep by law.
Restriction and objection. Ask us to limit how we use your information.
Channel preferences. Tell your concierge how you want to be reached. Reply STOP to end SMS at any time.
Withdraw consent. Withdraw a consent you previously gave, without affecting processing already carried out.

To exercise any of these, write to privacy@clients.vlvt.life. We will verify your identity and respond within the time the applicable law allows. We will not treat you differently for exercising a privacy right.

11. United States state privacy rights

If you are a resident of California, Colorado, Connecticut, Virginia, or another state with a comprehensive privacy law, you may have the rights described above, along with the right to appeal a decision we make on a privacy request and the right to be free from discrimination for exercising your rights.

For California residents, we confirm that in the preceding twelve months we have not sold personal information and have not shared personal information for cross-context behavioural advertising. The categories of personal information we collect, the purposes for collecting them, and the categories of recipients are described in sections 2, 3, 4, and 6 of this policy. To appeal a decision on a request, reply to our response or write to privacy@clients.vlvt.life with the word "appeal" in the subject line.

12. International transfers

vlvt is based in the United States, and our systems are hosted in the United States. If you are outside the United States, or if a booking requires us to work with a supplier in another country, your information will be transferred to and processed in those countries. We use appropriate contractual safeguards for those transfers.

13. Children

vlvt membership is for adults. We do not knowingly collect information from children under 13, and we do not direct our service to them. Where a member asks us to arrange something for a child in their party, we collect only what a supplier needs, such as a first name and an age, and we handle it under this policy. If you believe a child has provided information to us directly, write to us and we will delete it.

14. This website

This site is a static informational site. It sets no advertising cookies and runs no third-party analytics or advertising trackers. Web fonts are loaded from Fontshare and Google Fonts, which receive a standard request from your browser in order to serve the font files. Our hosting provider keeps standard server logs for availability and security.

15. Changes to this policy

We may update this policy. When we do, we will change the effective date at the top of this page, and we will tell you about material changes through your concierge, by email, or by a notice on this site.

16. Contact us

Privacy enquiries and rights requests: privacy@clients.vlvt.life
Concierge and general enquiries: concierge@clients.vlvt.life
Data controller: VLVT Ventures, Inc., a Delaware corporation

Privacy Policy