Processing Operations and Instructions

Last updated: September, 2025.

14. Appendix A - Processing Operations and Instructions

A.1 The personal data is processed for the following purpose:

• Velory has developed a B2B commerce platform (the “Platform”) that unites (in a single ecosystem) resellers or distributors of goods, software licenses and services (the “Equipment”) with potential buyers of said goods, software licenses and services. The Platform consists of various software modules with differentiated functionality and interfaces. Personal data is processed when users buy products and/or services, use Velory´s apps, portals and websites or otherwise communicate with Velory. Velory also collect information about users to improve apps, portals and websites. Velory process data to keep track of users´ purchases of Equipment.
• Assist Velory Platform users in the administration of user accounts, sales, leasing and shipments of products and services over the Velory platform. Assist a company in setting up Velory to onboard users, devices and spaces. Assist customers and end-users in curating the portfolio of products shown in Velory Platform. 
• Nature of processing measures are:
  
  • Adding users based on personal data such as email addresses, names and unique electronic devices
  • Assisting users in placing orders
  • Answering questions from users
  • Assess the needs of Company by reading data on device usage and the expiration of leasing contracts
  • Distribute and provide users’ hardware devices with apps, new installations and security measures (applicable for MDM)

A.2 Data Subjects 

The personal data processed concerns the following categories of data subjects: 

• Employee data 
• Customer contact details 

A.3 Categories of data

The personal data transferred concern the following categories of data:

• Name
• Address
• Employment (title, employer, workplace)
• Telephone number
• Email address
• IP address
• Device identification number (serial or IMEI number)

A.4 Special categories of data (if appropriate)

The personal data transferred concern the following special categories of data:

N/A‍

A.5 Processing operations

The personal data transferred will be subject to the following basic processing activities:

Processing, registering, accessing, reading, using, aligning, erasing, hosting, storing personal data as part of providing the services.