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Velo Privacy Policy

Velo-Payments Inc. and/or its parent company, subsidiary and affiliated companies (hereinafter referred to as “ Velo”, “we”, “our” or “us”) provides online payment facilitation and other services, including any related offline components (such as mobile applications) and any content, data or information (such as APIs or developer kits) made available through the www.velopayments.com (“ Site”) which allow our clients (“Payors”) to make payments to other parties (“Payees”) strictly for lawful business purposes (the “Service”). In this privacy policy (“Privacy Policy”), we explain how we use any Personal Information we collect about your use of the Service. You may be a visitor to the Site or a Payee.

  1. We may change the Privacy Policy and the Service, and we will update this page when we do so. Please be sure to check the Privacy Policy periodically.

    We may update this Privacy Policy and the Service at any time to reflect our information practices. We will provide updates by posting the amended Privacy Policy on this page or by notifying you in writing sent to the e-mail address specified in your account of the amendments. The amendments shall be effective upon such posting or notification. You agree to review this Privacy Policy periodically so that you are aware of any amendments.

    However, if we make a material change to this Privacy Policy, we will provide a prominent notification to you. If you do not accept the material change after we notify you of such updates, please immediately stop using the Service. If you continue to use the Services, you agree to be bound by the amended Privacy Policy.

  2. We collect Personal Information from you and third-party service providers for the legitimate purpose of providing, improving and protecting the Service.

    In order to receive payments or otherwise use the Service, you will be required to provide us with “Personal Information”) (which is information that, on its own or when combined with other information, can be used to identify you), and you also authorize us to request information about you from third parties (for example, to verify your identity). We collect the following information:

    • Identification information - your name, address, email address, date of birth, social security number, bank account information, digital wallets/payment account information, social media information, other government issued identification information, and location information.
    • Information about payments made to you and your use of the Service.
  3. We automatically collect information from you in order to track how the Service is used and to make the Service perform better for you.

    Whenever you visit or interact with the Service, we, as well as our third-party service providers, use a variety of technologies that automatically or passively collect information about how you access and use the Service (“Usage Information”). Usage Information includes:

    • Your IP address or other unique identifier for your device.
    • Device information, including machine or mobile device ID, browser type, software versions, and other similar information.
    • Your location.
    • The type of browser software and operating system you are using.
    • The web page(s) you have accessed, and the time you accessed them.

    Cookies. Cookies are small computer files we place on your computer’s hard drive that we and our third party service providers place on your device in order to recognize your device and collect Usage Information, for security purposes, and to enable you to use the Services, as well as for market research related purposes.. The Help portion of the toolbar on most browsers will tell you how to restrict cookies or disable them altogether. However, restricting or disabling cookies may prevent you from using some of the features of the Service.

    Google Analytics: We use a tool called “Google Analytics” to collect information about your internet use. For example, how often you visit our site, the pages you visit, and what other Sites you may have visited prior to coming to our site. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google.

  4. We use the information we collect from you to provide the Service, distribute updates, improve your experience, respond to inquiries and enforce our rights.

    We use the information we collect:

    • To provide and develop, enhance, and market the Service.
    • To customize and improve your online experience, including conducting surveys, research and evaluations, and collect any applicable fees related to the Service.
    • To distribute news, updates and other information you may find useful, unless you opt out of receiving these notices in the manner provided by the Service.
    • In connection for risk control and fraud detection and prevention.
    • To verify your identity and the validity of any payment account information you provide to us. We may combine this information with information collected from online and offline sources or information we already have.
    • To provide customer support and manage any consumer complaints.
    • For any other purpose to which you explicitly consent.

    You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, updating your online profile or you can contact us at support@velopayments.com.

  5. We share your Personal Information with our affiliates and service providers. We will also share your information if we reorganize our business and as necessary to enforce our legal rights or meet our legal obligations.

    Except as described below, we do not share with third parties information by which you can be personally identified unless you give your consent. You may not opt out of the following disclosures. If you do not want your information shared with third parties in the ways described below, you should not use the Service.

    In connection the provision of the Service (as may be amended and supplemented from time to time), you authorize and consent that we share your Personal Information:

    • With affiliated entities, the Payor(s), the third party financial institutions and payment processors involved in facilitating the payments, and our third party service providers.
      as permitted by any legal agreement between you and us (including the Terms of Use).
    • When we believe disclosure is appropriate to law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure.
    • To enforce or apply the Terms of Use and other agreements.
    • To protect our rights, property or safety, or those of third parties.
    • In the event that Velo plans to merge with or by acquired by another company, or in the event of a bankruptcy.
    • For any other purposes to which you consent.
  6. We have a legal basis to process your Personal Information.

    We will only use your information to fulfill contracts we have with you, for certain of our lawful purposes, and for other reasons with your consent.

    We will only ever use your Personal Information:

    • To perform a contract we have with you (for example, if you register for the Services, we will need to use your Personal Information to process payments).
    • If it is in our lawful interests to do so (for example, to let you know about certain services you may be interested in, to carry out market research, or to share your Personal Information with our third party service providers to help us provide our services, sell and operate the Services).
    • If we have told you how we intend to use your Personal Information and you have given us your consent for that use. If you have given us your consent to use your Personal Information in a particular way, you may withdraw it any time by contacting us using the contact details below.
    • If we need to do so in order to comply with a legal obligation.
  7. We only store Personal Information as long as needed for the Service and after ceasing use of the Services, as permitted or required by applicable law.

    Your Personal Information is stored by Velo on its servers, and on the servers of the cloud-based database management services Velo engages, located in the United States of America and the United Kingdom. We will retain your Personal Information for as long as your account is active or as needed to provide you services, and thereafter, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

    Velo collects Personal Information under the direction of its Payors, as well as having a direct relationship with the individuals whose Personal Information it processes. If you are a customer of one of our Payors and would no longer like to be contacted by one of our Payors that use our Service, please contact the Payor that you interact with directly. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Velo at privacy@velopayments.com. If requested to remove data, we will respond within a reasonable timeframe.

  8. You have the right to access, correct, complete, transfer and delete your Personal Information.

    Upon request, Velo will provide you with information about whether we hold any of your Personal Information. You can view, alter, verify, request deletion or update the Personal Information you provide by emailing us at privacy@velopayments.com, or, when available, by logging in to your Velo user account with your username and password. If you update information, we may keep a copy of the prior version for our records. We will respond to your request within a reasonable timeframe. We may also ask you to verify your identity and to provide further details about your request.

  9. The Site may include links to third party websites.

    The Site may include links to other websites whose privacy practices may differ from those of Velo. If you submit Personal Information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

  10. We take reasonable security measures to protect your information in our possession and control.

    The security of your Personal Information is important to us. We take commercially reasonable physical, electronic and procedural steps to help protect against the loss, misuse and alteration of the information under our control, both during transmission and once it is received. If you have any questions about the security of your Personal Information, you can contact us at privacy@velopayments.com.

  11. We do not knowingly collect information from children.

    No one under 18 years of age is authorized to use the Service, and we do not intentionally process information from anyone under the age of 18.

  12. You have certain rights under California Online Privacy Protection Act.

    Residents of California can obtain certain information about the types of Personal Information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. We do not share your Personal Information with third parties for their direct marketing purposes. If we do so in the future, Velo will provide you with a choice prior to sharing your Personal Information with third parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time Velo offers that choice, Velo will not share your information with that identified third party for its direct marketing purposes.

    In addition, California law requires us to disclose how we respond to browser “Do Not Track” signals. We have not yet developed a response to browser “Do Not Track” signals , and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals.

  13. Velo is a global company with headquarters in the United States. Your Personal Information will be transferred to our United States headquarters. We take measures to protect privacy when data is transferred..

    Velo (together with its affiliate, Bold Financial Technologies, Inc.) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Velo is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

    Velo may share or transfer your information to our system or third-party service providers under contract with us, which may be outside your home country. Your Personal Information may therefore be subject to privacy laws that are different from those in your country of residence.

    By using the Site, or by providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be equivalent to those in the country where you reside and/or are a citizen.

    Velo is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Velo complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

    With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Velo is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (“FTC”). In certain situations, Velo may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    Where Personal Information of EU/EEA data subjects is transferred to non-EEA countries, we enter into data processing agreements with third party service providers subject to the Standard Contractual Clauses to ensure ‘appropriate safeguards’ under the General Data Protection Regulation (“GDPR”). Velo collects and transfers to the United States Personal Information only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Velo in a manner that does not outweigh your rights and freedoms.

    If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. Under certain conditions, more fully described on the https://www.privacyshield.gov/article?id=ANNEX-I-introduction, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

  14. Please contact us if you have any inquiries regarding this Privacy Policy.

    Our Chief Compliance Officer is responsible for overseeing the policies and procedures associated with this Privacy Policy. If you have any questions or concerns regarding this Privacy Policy or your information, please contact us:

    By mail:

    Velo-Payments, Inc.
    1001 Bridgeway #502
    Sausalito, CA 94965
    Attn: Compliance Officer

    By email:

    privacy@velopayments.com