Privacy Policy

This Privacy Policy (“Privacy Policy”) explains Velric, Inc.’s (“Velric,” “we” “us” or “our”) privacy practices relating to the collection and use of information that may identify you and covers information collected from any source including, for example, through its websites (collectively, the “Site”), and any smartphone, device or other electronic applications or tools, through any social media platform (together, the “Electronic Platforms”), emails, text messages, direct messages, or other communications whether electronic or written, or from any third party such as a contractor acting on Velric’s behalf (all of the above is referred to collectively as the “Resources”).

For the avoidance of doubt, this Privacy Policy applies only to information processed by Velric in its capacity as a data controller, unless expressly stated otherwise.

It is Velric’s policy to respect your privacy regarding any information we may collect, subject to the provisions of this Privacy Policy and, if you receive services from Velric, or any other agreements between you and Velric (together, “Terms of Use”). In addition, various Resources of Velric may include different terms or policies, and you should review any such terms and policies carefully, as they will control your use of that Resource. By providing us any information or accessing one or more Resources, you agree to the following provisions as final and binding.

If you do not agree to the provisions of this Privacy Policy, including having your Personal Information (as defined below) used in any of the ways described in this Privacy Policy, do not provide us with your information. Please note, however, that if you don’t provide us with your information, you may not be able to obtain certain services or features of our Site.

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational needs. When we make material changes, we will update the “Effective Date” at the top of this Privacy Policy. Your continued use of the Site after the effective date of a revised Privacy Policy constitutes your acknowledgment of such changes. In the event we materially change the way in which we use your Personal Information that we previously collected, we will provide you with notice and ask you to affirmatively accept the new uses.

This Privacy Policy applies to the processing of personal data of individuals wherever located including those in the United States, Canada, or any other countries worldwide. If you are located in the European Union, if the processing of your data is subject to the laws of a member state of the European Union by virtue of public international law, if your information is otherwise governed by European Union Law, or if the processing activities of Velric are related to the offering of goods or services to data subjects in the European Union or the monitoring of individuals’ behavior that takes place within the European Union, please review carefully the “General Data Protection Regulation (“GDPR”)” section below for more information regarding your rights and our activities relating to your personal data. If you are a resident of California, please review the “California Residents’ Privacy Rights” and the “Rights under the California Consumer Privacy Act” sections below for additional information regarding your rights and our activities relating to your personal data. If the GDPR or California sections are applicable to your information, then other sections in this Privacy Policy still may apply to you but are subject to (and considered modified by) those sections.

We require Site visitors who register an account to provide us certain Personal Information. Information we collect when you register to use our services may include your name, email address, physical address, as well as, potentially, other information that identifies you or that, in combination with other information we hold, may reasonably be used to identify you (together, “Personal Information”).

We also may use the Personal Information you provide when you visit our Sites, create an account, or email or otherwise contact us, to contact you to further discuss the product offerings and services we provide to customers. You may choose to opt out of providing your Personal Information by not disclosing it to us or entering it when asked, though this may preclude your ability to receive our services.

Generally, we collect, or may collect, the following data elements from you when we process your Personal Information for the purposes we described in this Privacy Policy. We process:

Your first and last name
Email address
Phone number
Physical address
Country of residence or business
Internet or other electronic network activity.

Generally, for operational purposes or to verify identity, or if we offer new products or services, and depending on the reason for your contacting us, we may also collect additional information such as:

Date of birth
Industry
Company
Sensitive identifiers such as government-issued identification numbers or financial account information are collected only where strictly necessary for payment processing, tax compliance, or other legal obligations
Testimonials and other information you voluntarily provide

We do not share with or disclose Personal Information to third parties except when one or more of the following conditions is true:

We have your permission to make the disclosure;
The disclosure is necessary for the purpose for which the Personal Information was obtained;
The disclosure is permitted by relevant law;
The Personal Information to be disclosed is otherwise publicly available in accordance with applicable law;
The disclosure is for Velric’s own marketing purposes, subject to applicable law and user consent requirements
The party to whom the disclosure is made controls, is controlled by, or is under common control with Velric;
The disclosure is in our sole discretion necessary for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, subpoena or government request, or in connection with litigation;
The disclosure is, in our sole discretion, about users who we believe are engaged in illegal activities, even without a subpoena, warrant or court order; or
The disclosure is to outside businesses to perform certain services for us, such as maintaining our Site, processing of payments, assisting us in the provision of services, providing marketing assistance and data analysis including service providers outside the country or jurisdiction in which you reside.

If you are a resident of the United States, you have the following rights with respect to your Personal Information, subject to certain exceptions under applicable law. These rights apply regardless of the state in which you reside.

Right to Know / Access
You have the right to request confirmation of whether Velric processes your Personal Information and to access such information. This includes the right to request:
The categories of Personal Information we collect about you
The specific pieces of Personal Information we have collected about you
The purposes for which we process your Personal Information
The categories of sources from which Personal Information is collected
The categories of third parties with whom we disclose Personal Information

Right to Correction
You have the right to request that we correct inaccurate or incomplete Personal Information that we maintain about you, taking into account the nature of the information and the purposes of the processing.

Right to Deletion
You have the right to request that we delete Personal Information that we have collected about you, including information obtained from third parties, subject to applicable legal exceptions (such as compliance with legal obligations, fraud prevention, or security purposes).

Right to Data Portability
You have the right to obtain a copy of your Personal Information in a portable, readily usable format that allows you to transmit the information to another entity without hindrance, where technically feasible.

Right to Opt Out of Certain Processing
Where required by applicable U.S. state privacy laws, you may have the right to opt out of certain processing activities, including the sale or sharing of Personal Data, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. The availability of these rights may vary depending on your state of residence and the nature of the processing activities.
Velric recognizes browser-based opt-out preference signals, such as the Global Privacy Control (GPC), where required by law. When an opt-out request is received and honored, Velric will provide confirmation of such action.

Right to Appeal
If we decline to take action on your request, you have the right to appeal our decision. Instructions for submitting an appeal are provided in the “How to Exercise Your Privacy Rights” section below.

Velric will not discriminate against you for exercising any of your privacy rights.

You may exercise your privacy rights by submitting a request to legal@velric.ai

To protect your Personal Information, Velric may take reasonable steps to verify your identity before responding to a request. This may include requesting information sufficient to confirm you are the individual about whom we collected Personal Information. Information provided for verification purposes will be used solely for that purpose and will not be retained longer than necessary.

Velric will respond to a verifiable consumer request within 45 days of receipt. Where reasonably necessary, we may extend this period once by an additional 45 days, and we will notify you of the extension and the reason for it.

You may designate an authorized agent to submit a request on your behalf, where permitted by law. We may require proof of authorization and verification of your identity.

If your request is denied, you may submit an appeal by contacting legal@velric.ai and clearly indicating that your request is an appeal. Velric will respond to appeals within 60 days. If the appeal is denied, you will be informed of any additional steps available to you, including the right to contact the appropriate state regulatory authority.

Velric may use automated processing, including profiling, to support certain business functions such as service optimization, security, fraud prevention, or personalization. Where such automated decision-making produces legal or similarly significant effects, individuals have the right to: Obtain meaningful information about the logic involved; Opt out of such processing, where required by law; and Request human review of the decision. Requests related to automated decision-making may be submitted as described in the “How to Exercise Your Privacy Rights” section.

Velric is headquartered in the United States. Your Personal Data may be transferred to and processed in countries outside the European Union and European Economic Area, including the United States, which may not provide a level of data protection equivalent to that of your home jurisdiction. Where required under the GDPR, Velric transfers Personal Data using lawful safeguards, including the European Commission’s Standard Contractual Clauses, and implements appropriate technical and organizational measures to protect such data.

In limited and exceptional circumstances, Velric may rely on the derogations set out in Article 49 of the GDPR, including where the transfer is necessary for the performance of a contract between you and Velric, for the implementation of pre-contractual measures taken at your request, or where you have explicitly consented to the transfer after being informed of the possible risks involved.

You may exercise your rights under the GDPR by submitting a request in accordance with the procedures described in the “How to Exercise Your Privacy Rights” section above. We will respond to verified requests within the timeframes required by applicable law and may request additional information as necessary to verify your identity before processing your request.

The Data Controller is Velric. You may contact the Velric legal@velric.ai Monday through Friday 9 am to 5 pm Eastern time.

Data Protection Officer
Velric has appointed a Data Protection Officer or Privacy Lead, who may be contacted at: legal@velric.ai

You have the right to lodge a complaint regarding the processing of your Personal Data with us by contacting our Data Protection Officer listed above. You also may lodge a complaint with the Data Protection Authorities in the Member State where you habitually reside, work, or where an infringement occurred.

Velric processes your Personal Data for the lawful purposes, and under the legal bases, set forth above.

Velric will not disclose Personal Data to a third party except as stated below:

We may disclose Personal Data to subcontractors and third-party agents. Before disclosing Personal Data to a subcontractor or third-party agent, we will obtain assurances by contractual agreement from the recipient that it will: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the subcontractor or third-party agent is obligated to provide at least the same level of privacy protection as is required by the GDPR; (iii) take reasonable and appropriate steps to ensure that subcontractors and third-party agents effectively process the personal information transferred in a manner consistent with the organization’s obligations under the GDPR; (iv) require subcontractors and third-party agents to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the GDPR; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with subcontractors and third-party agents to the Supervisory Authorities upon request.

Velric also may be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements, or in the event of a merger or acquisition.

Personal Data obtained by Velric is adequate, relevant and not excessive in relation to the purposes described in this Privacy Policy. The Personal Data is processed for purposes specified herein and will only be processed consistent with the purposes described herein. We will request only the minimum amount of information required to perform the applicable Services and/or to comply with legal requirements and will retain such information only for as long as necessary to provide the Services or for compatible purposes, such as to provide additional Services, to comply with legal requirements, or to preserve or defend our legal rights.

Data Subjects have the right to access the Personal Data an organization holds about them. If such Personal Data is inaccurate or processed in violation of the GDPR, a Data Subject also may request that Personal Data be corrected, amended, or deleted. When we receive Personal Data, we do so on behalf of the individual submitting such Personal Data. To request access to, or correction, amendment or deletion of, Personal Data, Data Subjects should contact our Data Protection Officer. We will cooperate with all reasonable requests to assist Data Subjects to exercise their rights under the GDPR.

Data Subjects have the right to opt out of (a) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and (b) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized. Data Subjects who wish to limit the use or disclosure of their Personal Data should submit that request to our Data Protection Officer. We will cooperate with Data Subjects’ valid instructions regarding Data Subjects’ choices.

Velric retains Personal Information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Retention periods vary depending on the nature of the data and applicable legal obligations. When Personal Information is no longer required, it is securely deleted or anonymized.

See “Confidentiality and Security” below for more information about our security practices.

By using the Site, your Personal Data may be transferred to and processed in the United States, which is not currently recognized by the European Commission as providing an adequate level of protection for Personal Data. Where required under the GDPR, Velric relies on appropriate safeguards, including contractual arrangements with its data processors that ensure the protection and security of your Personal Data. In limited and exceptional circumstances, Velric may rely on the derogations set out in Article 49 of the GDPR, including where you have explicitly consented to the proposed transfer after being informed of the possible risks, or where such transfer is necessary for the performance of a contract between you and Velric or for the implementation of pre-contractual measures taken at your request.

We use cookies and similar technologies (such as pixels, tags, and local storage) to operate and improve our Site, understand how users interact with our Services, and, where permitted by law, deliver relevant content and advertising. Cookies may be first-party or third-party, and may be session-based or persistent.

Cookies used on our Site generally fall into the following categories: (i) strictly necessary cookies, which are required for the Site to function and cannot be disabled; (ii) functional cookies, which enable enhanced functionality and personalization; (iii) analytics cookies, which help us understand Site usage; and (iv) advertising or targeting cookies, which may be used to deliver relevant advertisements.

Where required by applicable law, non-essential cookies are deployed only after you have provided your consent through our cookie management or consent tool. You may withdraw or modify your cookie preferences at any time through the cookie settings link available on the Site.

Some browsers offer a “Do Not Track” (DNT) or similar signal. Because there is no universally accepted standard for interpreting such signals, we respond to browser-based opt-out or preference signals, including the Global Privacy Control (GPC), only where required by applicable law.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or websites that may be displayed to you in search results, websites that may include Velric services, or other websites linked from our Site. This Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

We maintain reasonable safeguards to protect the Personal Information we collect. While we implement these measures, please note that 100% security is not possible, and we cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.

You play a role in protecting your information as well. For example, Velric may assign you a user ID and a password as part of your participation and access to the Site and your account. Only you may use your user ID and password. You may not share your user ID or password with anyone else, and you are solely responsible for maintaining and protecting the confidentiality of your user ID and password. You are fully responsible for all activities that occur under your user ID even if undertaken by someone else. You are also responsible for assuring the security of your email address and any other address you provide to us, and Velric is not responsible for any loss arising from loss of any such security or for any unauthorized access to your accounts.

If we or any of our affiliates is involved in a merger, acquisition, asset sale, joint venture or other, similar transaction, we will continue to ensure the confidentiality of any Personal Information. We may transfer or allow access to Personal Information as part of the transaction and in review or preparation for it as described below.

In the event that:
We engage in one more asset sales or purchases;
We are acquired;
We engage in one or more business combinations, mergers or acquisitions;
Substantially all of our assets are acquired; or
We are subject to an event of bankruptcy

you acknowledge and agree that personal and other information comprises an asset of ours and that Personal Information and other information is subject to assignment, transfer and/or acquisition by a third party. Accordingly, and notwithstanding anything to the contrary in this Privacy Policy, you acknowledge and agree that such transfers may occur and that a person or entity that acquires us may continue to subsequently use your Personal Information, and that such subsequent use may not be consistent with this Privacy Policy.

We do not knowingly collect or solicit personal information from children under the age of 13. By using the Site or Services, you represent that you are at least 13 years old. If you are under 13, please do not attempt to register for an account or send any Personal Information about yourself to us. If we become aware that we have inadvertently received or collected Personal Information from a user of the Site who is under the age of 13, we will attempt to immediately delete that information from our files and records. Furthermore, we encourage users of the Site that are minors that are 13 years of age or older to ask their parents or guardians for permission before sending any information about themselves over the Internet.

If you believe a child who is under the age of 13 has provided us with Personal Information, please contact us at the address listed above.

If you have any queries concerning your personal information or any questions on our use of that information, please contact us as noted below or as otherwise advised on the Sites or other Services:

legal@velric.ai