Privacy Policy

This privacy policy (“Policy”) describes how Velou, Inc. (“Company”, “Velou”, “we”, “us”) collects, uses, and shares personal information of consumer users of our websites, including www.velou.com and our subscriber website, as well as associated products, mobile applications and services (together, the “Services”), and applies to personal information that we collect through our websites and our Services as well as personal information you provide to us directly.  This Policy also applies to any of our other websites or mobile applications that post this Policy.  Please note that by using our websites or the Services, you accept the practices and policies described in this Policy and you consent that we will collect, use, and share your personal information as described below.  If you do not agree to this Policy, please do not use our websites or the Services.

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TABLE OF CONTENTS

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1. Personal Information We Collect
2. How We Use Your Personal Information
3. How We Share Your Personal Information
4. Your Choices Regarding Your Personal Information
5. Security Of Your Personal Information
6. Retention of Personal Information
7. International Users
8. Children
9. Do Not Track
10. Updates To This Privacy Policy   
11. Notice to European Users
12. California Shine the Light Disclosure
13. Contact Us

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1. Personal Information We Collect

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We collect personal information about you in a number of different ways:

Personal Information Collected From You On Velou.com and Through Our Services.  When you use the velou.com or visit our physical locations, we collect personal information that you provide to us, which may include the following categories of personal information depending on how you use the velou.com or our Services and communicate with us (please note that this section does not apply to users of subscribers of our Services):

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• General identifiers, such as your full name, home or work address, zip code, telephone number, email address, job title and organizational affiliation.
• Online identifiers, such as information we automatically collect through cookies and similar technologies used on our websites.  
• Commercial information, such as your billing and payment history, and any records of personal property that we collect in connection with providing our Services to you.  We also collect information about your preferences regarding marketing communications.
• Audio, electronic, and visual information that we collect in connection with providing our Services to you, such as video or audio recordings of conversations made with your consent, and any security camera recordings of your activity in our physical locations.
• Professional or employment-related information that we collect in connection with employment applications for prospective employment with us, such as your resume, identity, professional qualifications, job title, employer information and work history.
• Other information you provide to us.
• Personal Information We Get From Others.  We may collect personal information about you from other sources.  We may add this to information we collect from subscribers of our Services. 
• Information We Collect Automatically.  We automatically log information about you and your computer, phone, tablet, or other devices you use to access velou.com.  For example, when visiting velou.com, we may log your computer or device identification, operating system type, browser type, screen resolution, browser language, internet protocol (IP) address, unique identifier, general location such as city, state or geographic area, the website you visited before browsing to our website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on velou.com.  How much of this information we collect depends on the type and settings of the device you use to access velou.com.
• Cookies.  We may log information using “cookies.”  Cookies are small data files stored on your hard drive by a website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on velou.com.  Other similar tools we may use to collect information by automated means include web server logs, web beacons and pixel tags.  This type of information is collected to make the velou.com more useful to you and to tailor the experience with us to meet your interests and needs.
• Analytics.  We may use analytics providers to help analyze how users use velou.com.  Analytics providers use Cookies to collect information such as how often users visit velou.com, what pages they visit, and what other sites they used prior to coming to velou.com.  We use the information we get from our analytics providers only to improve velou.com and the Services.  Although some analytics providers plant a persistent Cookie on your web browser to identify you as a unique user the next time you visit velou.com, the Cookie cannot be used by anyone but the analytics provider.  The provider’s ability to use and share information collected by the analytics tool about your visits to velou.com is restricted by the providers’ terms of service and privacy policy.
• Additional Information.  If you choose to interact on velou.com or through the Services (such as by registering; using our Services; entering into agreements with us; or requesting information from us), we will collect the personal information that you provide.  We may collect personal information about you that you provide through telephone, email, or other communications.  

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Personal Information Collected From Our Subscribers’ Users.  Where required by law, our data collection practices with respect to our subscribers and our subscribers’ users are addressed in our data processing agreement.  Where our data processing agreement with our subscriber is more restrictive than this Privacy Policy, the provisions of the data processing agreement govern.  When you use our Services as a user of one of our subscribers, we collect personal information that you provide to us, which may include the following categories of personal information depending on how you use our website or our Services and communicate with us:

• Online identifiers, such as information we automatically collect through cookies and similar technologies used on our websites.  
• Other information you provide to us.
• Personal Information We Get From Others.  We may collect personal information about you from other sources.  We may add this to the information we collect from subscribers of our Services.  
• Information We Collect Automatically.  We automatically log information about you and your computer, phone, tablet, or other devices you use to access our subscriber website.  For example, when using the Services, we may log your computer or device identification, operating system type, browser type, screen resolution, browser language, internet protocol (IP) address, unique identifier, general location such as city, state or geographic area, the website you visited before browsing to our subscriber website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our subscriber website.  How much of this information we collect depends on the type and settings of the device you use to access our subscriber website.
• Cookies.  We may log information using “cookies.”  Cookies are small data files stored on your hard drive by a website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our subscriber website.  Other similar tools we may use to collect information by automated means include web server logs, web beacons and pixel tags.  This type of information is collected to make our Services more useful to you and to tailor the experience with us to meet your interests and needs.
• Analytics.  We may use analytics providers to help analyze how users use our Services.  Analytics providers use Cookies to collect information such as how often users visit velou.com, what pages they visit, and what other sites they used prior to coming to velou.com.  We use the information we get from our analytics providers only to improve velou.com and the Services.  Although some analytics providers plant a persistent Cookie on your web browser to identify you as a unique user the next time you visit our subscriber website, the Cookie cannot be used by anyone but the analytics provider.  The provider’s ability to use and share information collected by the analytics tool about your visits to our subscriber website is restricted by the providers’ terms of service and privacy policy.
• Additional Information.  If you choose to interact with us through the Services (such as by registering; using our Services; entering into agreements with us; or requesting information from us), we will collect the personal information that you provide.  We may collect personal information about you that you provide through telephone, email, or other communications.  

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Information About Third Parties.  You may not provide us with personal information, including biometric information, regarding another individual.  Providing personal information about another individual without their consent could be viewed as a data privacy violation and could subject you to sanctions.

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2. How We Use Your Personal Information

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Generally, we may use your personal information in the following ways and as otherwise described in this Privacy Policy or to you at the time we collect the personal information from you:

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To Provide the Services and Personalize Your Experience.  We use personal information about you to provide the Services to you, including:

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• To help establish and verify your identity;
• For the purposes for which you specifically provided it to us, including, without limitation, to enable us to process and fulfill your requests or provide the Services to you;
• To provide you with effective customer service;
• To provide you with a personalized experience when you use our Services or by delivering relevant website or Services content;
• To send you information about your relationship or transactions with us;
• To otherwise contact you with information that we believe will be of interest to you, including marketing and promotional communications; and
• To enhance or develop features, products or services. 

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Research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Services, our websites and our business.  As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect.  We make personal information into anonymous data by removing information that makes the data personally identifiable to you.  We may use this anonymous data and share it with third-parties for our lawful business purposes.

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Marketing.  We may use your personal information in connection with sending you marketing communications as permitted by law, including by mail and email.  You may opt-out of marketing communications by following the unsubscribe instructions at the bottom of our marketing communications, emailing us at hello@velou.com or calling us at +1 (415) 825-3805.

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Compliance and protection.  We may use any of the categories of personal information described above to:

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• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

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• Protect our, your and others’ rights, privacy, safety and property (including by making and defending legal claims);

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• Audit our internal processes for compliance with legal and contractual requirements and internal policies;

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• Enforce the terms and conditions that govern our websites and our Services; and

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• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

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We may also use your personal information for other purposes consistent with this Privacy Policy or that are explained to you at the time of collection of your personal information.

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With your consent.  If you provide us with consent or instruct us to share your personal information with a third party, we may do so.  We will not share such information with third parties without your express consent or instruction.

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3. How We Share Your Personal Information

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We may disclose all categories of personal information described above with the following categories of third parties: 

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Affiliates.  We may share your personal information with our affiliates, for purposes consistent with this notice or that operate shared infrastructure, systems and technology.

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Third Party Service Providers.  We may provide your personal information to third party service providers that help us provide you with the Services that we offer, and to operate our business (for example, web services operators and credit card billing partners).

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Professional Advisors.  We may provide your personal information to our lawyers, accountants, bankers and other outside professional advisors in the course of the services they provide to us.

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Corporate Restructuring.  We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset.  If another company acquires Velou, our business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information described in this Privacy Policy.

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Other Disclosures.  We may disclose your personal information if we believe in good faith that such disclosure is necessary for any of the following:

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• In connection with a legal investigation;
• To comply with relevant laws or to respond to subpoenas or warrants served on us;
• To protect or defend the rights or property of Velou or users of our website or Services; and/or
• To investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our terms of service/terms of use.

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We may also share personal information with other categories of third parties with your consent or as described to you at the time of collection of your personal information.  

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Third Party Websites.  Our websites or the Services may contain links to third party websites or services.  When you click on a link to any other website or location, you will leave our websites or the Services and go to another site and another entity may collect your personal information from you.  We have no control over, do not review, and cannot be responsible for these outside websites or their content, or any collection of your personal information after you click on links to such outside websites.  The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, websites or privacy practices.

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4. Your Choices Regarding Your Personal Information

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You have several choices regarding the use of your personal information on our websites and our Services:

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Email Communications.  We may periodically send you free newsletters and e-mails that directly promote the use of our websites or the Services.  When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below) or following the instructions on the bottom of the email.  Despite your indicated e-mail preferences, we may send you Services-related communications, including notices of any updates to our Privacy Policy or terms of service/terms of use.

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Cookies.  If you decide at any time that you no longer wish to accept cookies from our websites for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.  Consult your browser’s technical information.  If you do not accept cookies, however, you may not be able to use all portions of our websites or all functionality of the Services.  If you have any questions about how to disable or modify cookies, visit https://www.allaboutcookies.org/.

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5. Security Of Your Personal Information

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Velou is committed to protecting the security of your personal information.  We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.  No method of transmission over the internet, or method of electronic storage, is 100% secure, however.  Therefore, while Velou uses reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

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6. Retention of Personal Information

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We keep your personal data only as long as necessary to provide you with the Services and for our legitimate and essential business purposes, such as complying with our legal obligations, preventing violations of the law, our terms of service and this Policy.  

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7. International Users

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Please note that our websites and the Services are hosted in the United States, Europe and Sri Lanka.  Please be aware that, unless provided otherwise in a data processing agreement with our customer, your personal information may be transferred to, stored, and processed in the United States, Europe or Sri Lanka or other countries where our servers are located and our central database is operated. The data protection and privacy laws of the United States, Europe or Sri Lanka may differ from the laws in your country. By using our websites or our Services, you consent to the transfer of your personal information to these countries or other countries as described in this Privacy Policy.

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8. Children

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Our websites and the Services are not intended for children under 18 years of age, and you must be at least 18 years old to have our permission to use our websites or the Services.  We do not knowingly collect, use, or disclose personally identifiable information from children under 13.  If you believe that we have collected, used, or disclosed personally identifiable information of a child under the age of 13, please contact us using the contact information below so that we can take appropriate action.

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9. Do Not Track

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We currently do not support the Do Not Track browser setting or respond to Do Not Track signals.  Do Not Track (or DNT) is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you.  For more details about Do Not Track, including how to enable or disable this preference, visit http://www.allaboutdnt.com.

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10. Updates To This Privacy Policy

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We reserve the right to change this Policy at any time.  If we make any material changes to this Policy, we will post the revised version to our website and update the “Effective Date” at the top of this Policy.  If we make material changes to this Policy, we will notify you of the changes and provide you with an opportunity to accept or reject the changes (note that if you choose to reject the changes, you may not be able to continue to utilize the Services).  

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11. Notice to European Users

The information provided in this “Notice to European Users” section applies only to individuals in Europe.  

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation, including the General Data Protection Regulation and the U.K. General Data Protection Regulation.

Controller. Velou is the controller of your personal information covered by this Policy for the purposes of European data protection legislation, except to the extent that we process your personal information on behalf of our customer, in which case our customer is the controller of your personal information, and Velou is the processor.

We have appointed a Data Protection Officer, whose contact information is: Sadee Gamhewa, 33 W 17th St 4th Floor, New York, NY 10011 USA, +1 (415) 825-3805, hello@velou.com.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Policy are described in the table below.

Use for new purposes. We may use your personal information for reasons not described in this Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We do not intentionally collect sensitive personal information (e.g., information related to racial or ethnic origin, health, or biometrics characteristics) through the Services or otherwise.  If you provide us with any sensitive personal information when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Services.

Automated Decision-Making and Profiling. We do not use automated decision-making and/or profiling in regard to your personal information in connection with the Services. 

Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

When we no longer require the personal information we have collected about you, 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights.  

European data protection laws give you certain rights regarding your personal information. If you are located within the European Economic Area, the United Kingdom or Switzerland, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information. 
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to a third party of your choice.
• Restrict. Restrict processing of your personal information.
• Object. Object to our reliance on our legitimate interests as a legal basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to hello@velou.com or our postal address provided below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer.

If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:

• Pursuant to the recipient’s compliance with standard contractual clauses or Binding Corporate Rules;
• Pursuant to the consent of the individual to whom the personal information pertains; or
• As otherwise permitted by applicable European requirements.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

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12. California Shine the Light Disclosure

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California’s “Shine the Light” law gives residents of California the right under certain circumstances to obtain certain information regarding the sharing of certain categories of personal information (as defined in California Civil Code Section 1798.83) with third parties for their direct marketing purposes.  If you would like to obtain a Shine the Light disclosure, please email hello@velou.com, and include in the subject line “California Shine the Light Request”.  Please allow up to 45 days for a response.

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13. Contact Us

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Our contact information is as follows:

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Velou, Inc.

33 W 17th St

4th Floor

New York, NY 10011 USA

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Telephone: +1 (415) 825-3805

Email: hello@velou.com

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