Privacy policy

Effective Date: February 26, 2018

This Privacy Policy (this “Policy”) describes the privacy practices of Velou Inc. as well as our family of affiliated companies (“Velou”, “we”, or “us”) with respect to information collected from you through our Collection Activities (defined below) and how we use and share that information.Personal information we collect may be stored and processed in the United States or any other country in which Velou or its affiliates, subsidiaries, agents, or third party service providers maintain facilities and/or infrastructure, and by submitting information to us, you consent to the transfer, processing and storage of such information outside of your country. Note that the United States is a jurisdiction in which the data protection regime may not provide the same level of security as those in the nation where you reside. Unless applicable law requires different security and protections to be applied in any given relevant jurisdiction, we apply the same principles in using, handling and transmitting data as described in this Policy in all of our operations. If you do not agree with any part of this Policy, please do not access or continue to use any the Web Sites orBusiness Services or participate in Marketing Activities or otherwise provide your personal information to us.

This Policy covers the following areas:

• The Personal Data Collected

• How Velou Collects Personal Data

• Cookies and Other Automatic Collection Tools

• Personal Data Retention

• How Velou Uses Personal Data

• How Velou Shares Personal Data

• Data Security

• How to Manage your Privacy Settings.

• Special Disclosures for Subscriber Data Obtained by the Business Services

• Children

• Amendments

• How to Contact Velou

Please note that Section 9 of this Policy contains special disclosures and terms thatapply to Personal Data submitted by our subscribers to our Business Services. For more information on Personal Data we process on behalf of our subscribers, and your rights with respect to how Velou collects, uses and shares that information and how Velou secures and retains that information, please see Section 9.

1. The Personal Data Collected

• When you sign up for, use, access or otherwise interact with and all websites within that domain and other online services and products of Velou, including mobile applications and websites or applications operated by Velou and connected products and services that reference this Policy(the “Websites”);

• Information obtained from third-party sources such as data brokers, publicly available sources, and Velou’s suppliers andrelated partners;

• Registration information provided by individuals that register to attend our marketing or corporate events or receive our marketing materials (“Marketing Activities”); and

• Subscriber data submitted to Velou’s search-as-a-serviceand related business services (the “Business Services”) by our subscribers or their end users (or obtained by Velou on subscriber’s behalf) (such as through our SDKs or APIs). Section 9 of this Policy separately covers and describes how Velou collects, uses and discloses suchPersonal Data.

In general, we may collect information that identifies you, information about how you use our Websites, and the information that you create while you interact with the Websites.Information that we collect may include the following: information that can personally identify you, such as name, telephone number, email address, or postal address; information about the equipment used to access the Websites, and use of the Websites; information provided when completing forms on our Websites; records and copies of correspondence (including email addresses and social media handles) between us; your survey responses; data ontransactions or orders on or forthe Websites orBusiness

Services.You also may contribute information that is published or displayed on public areas of our Websitesor communicated to other users of our Websites or third-parties. Such user contributions are posted and communicated to others at your own risk.

2. How Velou Collects Personal Data

Velou and its partners use a variety of technologies to collect information about your use the Websites or Business Services, including sending cookies to your device and using web beacons. This information helps us to improve and customize our Websites, Marketing Activities, and Business Services, and mitigate risks and the potential for fraud.

Information that is collected automatically may include the following:browser type, IP addresses,operating system, Internet Service Provider (ISP), and browsing behavior.

When you access or use the Websites or Business Services, a cookie may be sent to your device. “Cookies” are small data files placed on a device’s hard drive or memory when you interact with a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may use cookies to:

• Remember that you have visited us or used the Business Services before and personalize our content for you and remember your preferences (for example, your choice of language or region).

• Ensure we have enough capacity to accommodate all of our users and that users are finding what they are looking for easily and do not encounter technical errors.

• Collect anonymous statistical information about how you use the Websites or Business Services (including the length of your web or application session) and the location from which you access the Websites or Business Services, so that we can improve the Websites or Business Services and learn which elements and functions of the Services are most popular with our users.

• Helps us and our advertising partners to deliver marketingcommunications that are relevant to you and your interests. We may also share this information with third parties for this purpose.

We may allow third parties to collect information via the Web Sites or Business Services through cookies, third party plug-ins and widgets. Third party cookies enable third party features or functionality to be provided on or through the Sites (e.g., we may use Google Analytics and Google Adwords to collect and process certain analytics data). Note that you may visit or to learn about the options that some of the third parties we work with offer for opting out of certain ad targeting activities. You will need to visit those websites from each browser and device that you would like to be covered by your opt-out. Because the opt-out tools may depend on cookies, you may need to visit these sites again to reinstate your preferences if you delete your cookies.

You also can learn more about cookies by visiting or, which include additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. For most mobile devices, you can control the interest-based ads you see in two different ways: (1) changing the privacy settings of the device itself; and (2) changing the privacy settings of your browser. In addition, please note that if you use ad blocking software on your device, this may interfere with certain features and cause a disruption of service.

4. Personal Data Retention

Velou will retain Personal Data for so long as it continues to be useful in connection with providing or improving Velou’s Websites and Business Services and product offerings and this Policy, except if required otherwise by applicable law. We may further retain and use data as necessary to pursue legitimate business interests, comply with our legal obligations, resolve disputes, conduct audits and enforce our agreements.

5. How Velou Uses Personal Data

Velou uses Personal Data that you provide to us to deliver content on our Websites, carry out Marketing Activities, and to provide our Business Services.We may use this Personal to achieve any of the following

• Present products and content and Websites tailored to you, your interests and location.

• Troubleshoot problems with your experience with the Websites or Business Services

• Improve the experience of using our Websites, Business Services, and Marketing Activities.

• Provide you with information on the products and Business Services that we think are most relevant to or appropriate for you and to track the success of our marketing activities

• Manage your access to the Business Services.

• Respond to requests for support, online services, product information or to any other interaction you initiate

• Communicate with you about Marketing Activities, which may include promotional information.

• Send promotional or other communications regarding Velou products or Business Services.

• Perform our obligations and enforce our rights that arise from any contracts entered into between you and us.

• Develop a list of actual and potential users and subscribers for our products or Business Services.

• Assemble statistics regarding the use of our Websites, product or Business Services.

• Mitigate fraud or abuse.

• Comply with any governmental, legal or regulatory obligations.

• For any other purpose we describe at the time we collect information.

• For any other purpose with your consent.

6. How Velou Shares Personal Data

Velou may share your Personal Data with certain third-parties. This sharing is based on our relationship with those third-parties, your consent, or legal or contractual obligations that require us to share such information.We may share your Personal Data that we collect or you provide as follows:

• To businesses controlling, controlled by, or under common control with, Velou Inc. for the use purposes and under the conditions outlined herein.

• Velou may (a) coordinate the provision of services and products to you through third party service providers and (b) partner with third parties in order to promote, support, enable or expand Velou’s business and products and services or enable those third parties to deliver content or advertise the products and services of Velou. We may share Personal Data with those service providers and partners and they may have access to or process your Personal Data. These entities are bound by contractual obligations to keep Personal Data confidential and can use it only for the purposes for which we disclose the information to them.

• In the event Velou sells certain of its assets or goes through a structural change, such as a merger, acquisition by another company, bankruptcy, insolvency, or dissolution, to the extent permitted by applicable law Personal Data may be transferred to a third party as part of such event and thereby become subject to the privacy practices of that third party, which may materially different than those of Velou.

• We may be required, subject to applicable law, to disclose your Personal Data if: (i) it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority, (ii) such a disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) it is necessary to protect the legal rights or property or physical security of others, or for the prevention or detection of crime and such disclosure is lawful. For residents of the European Economic Area our disclosure is limited to situations where we are permitted to do so under applicable European and national data protection laws and regulations.

• To enforce or apply our Terms of Service and other subscription agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Velou, our subscribers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

Velou may disclose aggregated statistical data that does not contain Personal Data with third-parties.

Velou partners with third-parties that serve applications or content. These partners, including (i) third-parties that either surface advertising on the Websites or manage Velou advertising on third party sites and (ii) application providers may collect your information as you interact with them through our Websites.

You may login to our Websites using a sign-in service which authenticates your identity and provides you the option to disclose certain Personal Datato us such as your name and email address and collection of your Personal Data may occur as a result of login to our Websites using these third party sign-in services.

From time to time, we may include links to third party websites. If you submit Personal Data to any of those sites, your information will be governed by such third-party’s privacy policies. Please carefully read the privacy policy of any website you visit.

7. Data Security

Velou takes precautions to secure your personal information and protect it from loss, theft, unauthorized access, destruction, use, modification and disclosure. Such measures include technological, physical and organizational safeguards that are appropriate given the sensitivity of the personal information, including maintaining controlled access to electronic and paper documents and files, and using appropriate technology safeguards such as passwords firewalls and encryption as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your data. However, please note that Velou’s security measures may change or be unavailable from time to time and no data transmission over the Internet or any wireless network is 100% secure.

Velouis not responsible if you circumvent any privacy settings or security measures on our Websites. You are responsible for keeping any passwords confidential. We cannot control the actions of other users of our Websites with whom you choose to share your information; as such we cannot guarantee your contributed information cannot be viewed by unauthorized parties.

8. How to Manage your Privacy Settings

For additional guidance on how to manage the privacy of Personal Data submitted by our subscribers to our Business Services please see Section 9 of this Policy.

By using our Websites, Business Services, and Marketing Activities you expressly give your consent for the collection and use of your Personal Data in compliance with this Policy. This does not affect lawful processing under applicable laws based on other legal basis such as contractual obligation, compliance with applicable laws, and legitimate purposes.

Consent Withdrawal

Youhave the right to withdraw any consent of give us to process Personal Data oropt-out of marketing or promotional communications received from usat any time by doing the following:

• Using certain web browser and opt-out options discussed in this Policy to limit the Personal Data you provide to us or our third-party partners,

• Following the unsubscribe instructions included in emails,

• If applicable by accessing the email settings page in your Business Servicesaccount, or

• Sending us an email at the address noted in the How to Contact Velou section below.

Accessing or Correcting Personal Data

You have the right to review and correct your Personal Data and may do so by visiting your account settings page (if applicable) or by contacting us at the address noted in the How to Contact Velou section below.

Deletion of Personal Data

You have the right to request removal of your Personal Data and we areobligated to delete your Personal Data, where:

• The Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed,

• You object to the processing and there are no conflicting legitimate grounds for the processing,

• You withdraw consent on which the processing is based and where there is no other legal ground for the processing,

• The Personal Data has been unlawfully processed, or

• The Personal Data has to be erased for compliance with a legal obligation in the European Union or a Member State law to which Velou is subject.

• If you want to request removal of your Personal Data from our Websites or Business Services, you can login to the appropriate Website or Business Service or contact us at the address noted in the How to Contact Velou section below. You can also request closure of your account. We will respond to your request within 30 days. In the event we areunable to delete your Personal Data we will contact you and describe the nature of the inability.

Restrictions on Processing of Personal Data

You have the right to request the restriction of processing of your Personal Data, where:

• You contest the accuracy of the Personal Data until we take sufficient action to correct or verify its accuracy,

• Where the processing is unlawful but you do not want us to erase the Personal Data,

• Where we no longer need the Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims, or

• Where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether Velou has compelling legitimate grounds to continue processing.

• For applicablePersonal Datasubject tothe foregoing restrictions we will only process it with your consent or for the establishment, exercise, or defense of legal claims. This right includes restricting the processing of your Personal Data to only include storage of your Personal Data (e.g. during the time when Velou assesses whether you are entitled to have Personal Data erased).

If you want to request restriction of processing of your Personal Data, you can login to the appropriate Website or Business Service (if applicable or contact usat the address noted in the How to Contact Velou section below.

Note that where we are relying upon legitimate interest to process Personal Data, you have the right to object to that processing and we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your request or where we need to process the Personal Data for the establishment, exercise, or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each on a case-by-case basis.

If you want to request restriction of, or object to, the processing of your Personal Data, you can login to the appropriate Website or Business Service (if applicable or contact usat the address noted in the How to Contact Velou section below.

Data Portability

You have the right to a copy of your Personal Data, where:

• We are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for the processing, and

• Personal Data is processed by automatic means.

• This copy will be provided to you in a common machine-readable format. You may also require us to transmit it to another party to the extent technically feasible.

• If you want to request a copy of your Personal Data, please contact us at the address noted in the How to Contact Velou section below.

Complaints and Reporting Abuse

If you have a complaint concerning our collection or use of your Personal Data or believe that the processing of your personal Data infringes applicable laws you have the right to submit a complaint to your appropriategovernmental authority.If you need to report abuse, please contact us via the How to Contact Velou section below.

Residents of California

Under law California residents have the right to periodically (typically once per calendar year) request information relating to the information we disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us at an email or mailing address set forth below.

Note that where California State residents opt-out from permitting their Personal Data to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

9. Special Disclosures for Subscriber Data Obtained by the Business Services

Business subscribers to Velou’s Business Services electronically submit (or cause to be submitted) data to the Business Services for hosting, indexing and related processing. Velou processes such data as provided in our subscription agreements with our subscribers, such as our Business Services Terms of Service.

As subscribers (or their partners) control the data to be processed, Velou’s network, platform, and Business Services may be used as a conduit for information.

‍Collection, Use and Sharing of Business Services Personal Data

The collection,use and sharing of Personal Data collected through our Business Services at the direction of our subscribers the purpose of providing the Business Services for which the subscriber has engaged Velou.

Although Velou collects Personal Data related to subscriber personnel as they configure a subscriber’s use of our Business Services, Velou has no direct relationship with individuals whose Personal Data is hosted or transmitted through the Business Services by subscribers or their permitted internet We may share your information with third-party business partners for the purpose of providing the Services to you. Those business partners will be given limited access to your personal data as is reasonably necessary to deliver the Services. Subscribers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the data to Velou for processing purposes.

Velou also collects, uses, and discloses Personal Data of individuals who visit our Websites or engage in Marketing Activitiesas well as individual representatives of our subscribers, suppliers, and business partners. This Section 9 does not apply to Personal Data associated with such visitors and individual representatives collected, stored, and processed by Velou which are governed by the other provisions of this Policy.

Sub-processor Accountability

Velou may share Personal Data with third-party business partners for the purpose of providing the Business Services. Those business partners will be given limited access to your personal data as is reasonably necessary to deliver the Services. Velou maintains contracts with these third-parties restricting their access, use, and disclosure of Personal Data.If you do not consent to sharing your Personal Data received in connection with the Business Services with our partners, please contact us at an address set forth in the How to Contact Velou section below.

Subscriber Data Purpose Limitation

As a data processor, Velou hosts, transmits, discloses, and processes data, which may include Personal Data about EU personnel of our subscribers administering, using or supporting the Business Services. Velou may process data to provide the Business Services, to prevent or address technical or service problems, to follow the instructions of our subscribers and their personnel who submitted the Personal Data, or in response to contractual or legal requirements. Velou does not control or own the data submitted by its subscribers, or their internet clients or end users, to the Business Services. Velou may share Personal Data with its subsidiaries, contractors, or third-parties if Velou undergoes a business transaction, such as a merger, acquisition by another company or sale of all or substantially all of its assets.

Rights to Subscriber Data

In Velou’s role asa data processor of Personal Datacollected on our subscriber’s behalf, Velou has no direct relationship with the individuals associated with suchPersonal Dataand has limited ability to access such Personal Data. A person who (a) seeks to access, amend or delete such Personal Dataor (b) would like your information not to be disclosed to a third-party or to be used for a purpose that is materially different from the purpose(s) for which the Personal Data was originally collected, then you should contact the subscriber directly. Subscribers have the ability to fulfill these requests, and Velou will provide assistance for requests that subscribers are not able to complete. We will refer your requests to the appropriate subscriber.

Subscriber Data Retention

Velou retains the Personal Data we process on behalf of our subscribers for as long as needed to provide the Business Services to our subscribers and in accordance with our subscription agreements and for so long as it continues to be useful in connection with improving the Business Services to the extent permitted by law. To the extent not deleted by our subscribers, Velou may also retain and use certain Personal Data for a reasonable period of time thereafter as necessary to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.

10. Children

The Websites and Business Services are intended for general audiences and is not directed to persons less than 13 years of age and we do not knowingly collect Personal Data from those persons. If you become aware that personal information about your child has been provided to Velou without your consent, please contact us. If we become aware that a child under 13 has provided us with Personal Data, we will take steps to delete the information, except where we are required by applicable law to keep it.

11. Amendments

We may change this Policy from time to time. The most current version of this Policy will be effective at the time it is posted. By continuing to access or use the Websites or Business Services after those changes become effective, you agree to be bound by the revised Policy. If you have a registered account, we may notify you of any changes to our Privacy Policy via email and/or we may ask you to affirmatively acknowledge and consent to the changes the next time you use our Services.

12. How to Contact Velou

Depending on the context of Personal Data you provide, Velou may be the data controller (“controller”) or data processor (“processor”) of your Personal Data under this policy. Velou is a processor of Personal Data submitted to the Business Services or collected through the Business Services on behalf of or at the direction of subscribers. If you have any questions or concerns regarding this Policy or our privacy practices, including the processing of your Personal Data, if you would like to exercise your data rights under applicable laws, or if you believe your privacy rights have been violated, please contact Velou at, or:Velou Inc., 2443 Fillmore St #380-4734, San Francisco, CA 94115, USA.