Privacy Notice

This Privacy Notice is effective as of July 29, 2021.

At Vee24, Inc., we recognize the importance of protecting your Personal Information. We are committed to processing your it responsibly. We are also committed to complying with applicable data protection laws in all countries in which we operate.

1. Scope of this Privacy Notice

Vee24 collects, processes, and shares Personal Information in order to run its day-to-day operations and provide products and services for your use. This Privacy Notice applies to all users of Vee24 products and services. This notice also applies to visitors to our websites and Vee24-operated social media sites (we refer to the Vee24 website, social media sites, and our products and services as “Sites and/or Services” in this notice). This Notice describes Vee24’s general privacy practices that apply to such Personal Information collection and use including:

• Personal Information we are collecting,
• Why we are collecting the Personal Information,
• How Personal Information is collected,
• Sharing Personal Information,
• How the Personal Information is stored and protected,
• Your rights regarding the Personal Information,
• How to contact us.

This Notice does not apply to:

• Personal Information relating to employees, applicants for employment, or contractors providing services to Vee24,
• user content that is stored in our products and services, or
• when we are processing Personal Information on behalf of another organization.

In this last case, please contact the organization for whom we are processing information regarding their privacy practices.

2. Personal Information we are collecting and why

In this Notice, we refer to “Personal Information.” This is any information that is related to an identified or identifiable person.

We collect Personal Information such as:

• Identifying information such as your name, address, telephone number, and email address used when you register on our site for newsletter subscriptions, event participation, responding to a survey, filling out a form, or similar activities. This information is collected with your consent which may be implied by the submission of the information.
• IP address and site usage information for the legitimate interest of monitoring the use of and improve our website and services.
• Supplemental information you may provide to us when we provide services to you to assist us in establishing or fulfilling our contract with you.

We do not require that customers, partners, or other visitors to our site provide us with Personal Information and you may visit our site anonymously. If you do not provide the Personal Information requested, you may not be able to fully utilize the activities and services making the request. The decision to provide Personal Information is voluntary and you may withdraw your consent at any time by contacting us at privacy@vee24.com.

3. How Personal Information is collected

We use different methods to collect Personal Information:

• We collect the Personal Information you provide to us in optional, voluntary submissions such as registration forms, user profiles, promotional signups, sweepstakes/contest entries, requests for customer service, and software and mobile applications downloads.
• We may collect some Personal Information automatically to perform a contract with you, where we have legal obligations to do so, or where our legitimate interests permit such collection.
• We may also obtain information, including Personal Information, from third-party sources to perform a contract with you, where we have a legal obligation to do so, or where our legitimate interests permit such collection. If we directly combine information from third parties with Personal Information we have collected, we will treat the combined information as Personal Information and handle it in accordance with this Notice. In addition, please note we may solicit third parties to collect Personal Information on our behalf such as social media platform providers, and, in such cases, we instruct those third parties to comply with this Notice and all applicable data protection laws.
• On behalf of our customers where we act as a processor of Personal Information through our online services. In this situation, this Notice does not apply.

3.1 Passive data collection

3.1.1 Analytics tools

We use analytics tools and other third-party technologies to collect information in the form of various usage and user metrics when you interact with, use, or install Vee24 Sites and/or Services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information (referred to as “Collected Data”).

The third parties that provide these analytics tools may also use the Collected Data with other information they have independently gathered from other websites and/or other online or mobile products and services you have used or interacted with, pursuant to their own policies or privacy notices. In addition to our use of technologies as described herein, we may permit certain third-party companies to help us tailor advertising we think may be of interest to you based on your use of our Sites and/or Services and to otherwise collect and use data about your use of our Sites and/or Services. For more information about this practice, please see the “Third-Party Advertising Technologies” section below.

3.1.2 Cookies

We may use a variety of methods, including “cookies” to collect information.

Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. The contents of these cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device and save information between website pages or online sessions. You can find more information about cookies at All About Cookies.Org.

Cookies do lots of different jobs, such as letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure advertisements you see online are more relevant to you and your interests.

The cookies used on our Sites and/or Services by category are described below.

3.1.2.1 Optional cookies

3.1.2.1.1 Targeting cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not directly store Personal Information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

3.1.2.1.2 Social media cookies

These cookies are set by a range of social media services we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

3.1.2.2 Strictly necessary cookies

3.1.2.2.1 Always active

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, or logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will become disabled. These cookies do not store any Personal Information.

3.1.2.2.2 Functional cookies

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly.

3.1.2.2.3 Performance cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our websites and social media sites. They help us know which pages are the most and least popular and see how visitors move around these sites. If you do not allow these cookies, we may not know when you have visited our site, and we are not able to monitor the sites’ performance.

3.1.3 Third-party advertising technologies

We may permit certain third-party companies to help us tailor advertising we think may be of interest to users. We allow these companies to collect and use other data about user activities on our Sites and/or Services to allow them to tailor ads on third-party services. These companies may deliver ads that might place cookies or otherwise track user behavior.

These third-party companies may place or recognize a unique cookie on your computer that may record information based upon your activities on any of our Sites and/or Services and on third-party websites. Each of these companies uses this cookie information according to their own privacy and security policies. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out as indicated in this Notice. Please note this does not opt you out of being delivered advertising; you will continue to receive generic ads.

3.1.3.1 Opting out of cookies

By using the Sites and/or Services, you consent to the placement of the cookies referenced above. You can, however, set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. You may also change your cookie settings through preference options in our Sites and/or Services, where applicable. We will indicate that upon selecting your preferences, we will use a cookie to remember your preferences.

4. Personal Information relating to children

We do not knowingly seek or collect Personal Information from users under the age of 16 (a “Child”). In the event we learn we have collected Personal Information from a Child without parental or guardian consent, we will delete that Personal Information as quickly as possible. If you believe a Child may have provided us Personal Information please contact us at privacy@vee24.com.

5. Sharing Personal Information

We do not share your Personal Information with third parties except as noted below.

• We may share your Personal Information as necessary to maintain business operations, such as with vendors working on our behalf (for example, delivery of services and digital advertising);
• as required by law or to respond to legal process;
• to maintain the security of our products;
• to monitor and enforce our rights as a licensor;
• to protect Vee24’s customers, employees, rights, or property;
• as part of a merger or acquisition; or
• with your expressed consent.

We do not sell your Personal Information for monetary or other considerations.

5.1 Links to other sites

The use of our Sites and/or Services may allow you to visit our partners’ websites. When visiting these sites, you may be asked to provide Personal Information to the owner of the website. These sites are independent of Vee24 and the collection and use of such Personal Information are controlled by the policies found on those sites. Additionally, Vee24 does not monitor nor participate in the transactions you undertake on these websites. We recommend that you read these policies before providing Personal Information to these sites.

6. How Personal Information is stored and protected

6.1 Storage of Personal Information

Personal Information collected by Vee24 may be stored and processed in any country where Vee24, its processors, or its sub-processors operate and/or have facilities including the United States. We take steps to ensure that the data we collect under this Notice is processed according to this Notice and the requirements of applicable law relating to the Personal Information.

6.2 Protecting Personal Information

Vee24 uses a variety of technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it.

While these safeguards are designed to protect your Personal Information, no security system is impenetrable. Due to the inherent nature of the internet, we cannot guarantee that data, during transmission through the internet, while stored on our systems, or otherwise in our care, is absolutely safe from intrusion by others. You should take steps to protect the security of your user account information, login, and password.

6.3 Retention of Personal Information

We retain Personal Information for as long as necessary to fulfill the transactions you have requested. Additionally, we retain the information for other legitimate purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and improving our products. Because these needs can vary for different data types, the context of our interactions with you or your use of products, actual data retention periods can vary significantly.

When we have no longer have a legitimate business need to process your Personal Information, we will either delete or anonymize the Personal Information. If this is not possible (for example, because your Personal Information has been stored in backup archives), we securely store your Personal Information and isolate it from any further processing until deletion is possible.

When we collect Personal Information as a processor on behalf of the controller, the controller is the party who provides instructions on deleting or anonymizing the Personal Information.

7. Your rights regarding Personal Information

With some restrictions, you may make requests of us with regard to your Personal Information. Please contact us at privacy@vee24.com with these requests. To request these rights to organizations for which we provide service, please contact those organizations.

Access — You may request a copy of the Personal Information we hold about you. You will not have to pay a fee to access your Personal Information.

Transfer — You may request we provide an electronic copy of the information you have provided to us to be shared in a format that may be sent to a third party.

Correction — You may request that we modify any incomplete or inaccurate information we hold about you.

Erasure — You may request that we delete elements of your information. Please note that it is not always possible to completely remove all of your information from our systems. This is often due to legal or regulatory requirements. Also, some data may remain on our backup media for a limited period of time.

Restrict processing — You may request that we suspend the processing of your Personal Information. You may want to do this, for example, if you want us to verify the accuracy of the information. Another example may be to ask us to confirm the reason the processing is occurring.

You may change or cancel the marketing emails you currently receive from us by following the instructions found in our promotional emails. Please note that we will continue to send you communications about the business activities you undertake with us or use of our Site. This includes administrative communications and Site announcements.

8. Jurisdictional specific information

8.1 European Union

Our privacy practices as required under the European Union General Data Protection Regulation (“GDPR”) have been incorporated into this Policy.

8.1.1 Legal basis for processing

A legal basis for processing Personal Information is required under GDPR.

• We are fulfilling a contract when we process your information for providing requested services, processing payments, or preventing fraudulent access to your accounts.
• We are meeting the legitimate interests of our business when we contact you regarding new products and services, or we capture analytic information to improve or personalize our products, services, and website, or preventing fraudulent use of our services.
• We are addressing our legal obligations when reporting income and related information to tax authorities.

8.1.2 Objection to processing

You may object to the processing of your Personal Information. This may be done if you feel it is inappropriate for Vee24 to rely on legitimate interest as a legal basis for processing. When you object, we will limit the processing of your information. Once the objection is resolved, we will either resume processing or delete the Personal Information as appropriate. Please email privacy@vee24.com to object to processing.

8.1.3 Transfer of Personal Information outside of the EU

Vee24 transfers Personal Information between the EU and the United Kingdom under the Adequacy provisions in each jurisdiction.

8.1.4 Registering a complaint

There may be times when you have a concern about the processing of your Personal Information. We ask that you please contact us at privacy@vee24.com.

Vee24 commits to resolve complaints about your privacy and our collection or use of your Personal Information. EU, UK, and Swiss individuals with questions or concerns about the use of their Personal Information should contact at privacy@vee24.com.

If a Customer’s question or concern cannot be satisfied through this process, Vee24 commits to an independent dispute resolution mechanism operated by the European Union Data Protection Authorities (EU DPA) or the Swiss Federal Data Protection and Information Commissioner (FDPIC) and to comply with the advice given by the EU DPA or FDPIC, as applicable.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Vee24, EU individuals may bring a complaint before an EU Data Protection Authority or Swiss individuals may bring a complaint before the FDPIC.

8.2 California

8.2.1 California Shine the Light law

Under California Civil Code sections 1798.83–1798.84, California residents may request a notice disclosing the categories of Personal Information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. If you are a California resident and would like to make such a request, please email privacy@vee24.com.

8.2.2 California Online Privacy Protection Act of 2003 (“CalOPPA”)

CalOPPA requires an operator that collects PII about an individual consumer’s online activities to disclose how the operator responds to browser “do not track” signals. Vee24 does not honor “do not track signals.”

8.2.3 California Consumer Privacy Act of 2018 (CCPA)

CCPA provides California residents with specific rights for the collection and use of their Personal Information. These rights are included in the rights we provide to all customers as identified in section 6 above.

CCPA requires that we be transparent about the information we collect, its processing, and sharing. This information may be found in sections 2 through 4 above.

There is an additional right afforded to California residents to request that Vee24 not sell an individual’s Personal Information. Vee24 does not sell Personal Information for monetary or other valuable considerations.

8.3 Canada

As a Canadian citizen, your privacy rights are protected through the Personal Information Protection and Electronic Documents Act (PIPEDA). Vee24 only collects and processes Personal Information for purposes as described in sections above to meet these requirements,

PIPEDA consists of 10 fair information principles for the collection and processing of Personal Information.

Accountability — The individual for maintaining our privacy program, including PIPEDA, may be contacted as described in the section titled “How To Contact Us” below.

Identifying purposes — Our purposes for processing Personal Information may be found in the section titled “Personal Information we are collecting and why.”

Consent — We collect and process Personal Information you provide to us in the course of our transactions with you with your knowledge and/or consent as described in the section titled “How Personal Information is collected.”

Limiting collection — We limit the collection of Personal information to that which is needed for the purposes identified in the section titled “Personal Information we are collecting and why.”

Limiting use, disclosure, and retention — Vee24 limits the processing and sharing of Personal Information to that described in the sections titled “Personal information we are collecting and why” and “Sharing Personal Information”. Data is retained as described in the section titled “How the Personal Information is stored and protected.”

Accuracy — We strive to keep the Personal Information we retain as accurate as required for our processing purposes. The section titled “Your rights regarding the Personal Information” describes how you can assist in keeping your Personal Information current.

Safeguards — The section titled “How the Personal Information is stored and protected” discusses how Vee24 protects your Personal Information.

Openness — This privacy notice serves to provide you with information about our privacy program and the processing of your Personal Information.

Individual access — You may access and request correction of the Personal Information Vee24 maintains about you by following the guidance given in the section titled “6 Your rights regarding the Personal Information.”

Challenging compliance — If you have questions or concerns about this privacy program and our compliance with PIPEDA, please follow the instructions in the section titled “How to contact us” below.

9. How to contact us

If there are any questions regarding this Privacy Notice or the information that we collect about you, or if you feel that your privacy was treated not in accordance with this Privacy Notice, you may contact us at privacy@vee24.com.