We at Velory AB (“we”/”our”) appreciate the trust you place in us when you use our products and services. As part of us providing these products and services, we process personal data. This policy applies to all personal data we collect directly and indirectly from you and other sources and applies when we process your personal data for the purposes that we describe in this policy. This policy explains:

• What personal data we collect about you
• Why we collect that data
• What we do with that data
• How long we keep that data
• What control you have over your data and how you can manage your data
• The rights and choices you have regarding your personal data

Please take the time to read this policy. We’ve tried to keep it simple, but if you have any questions do not hesitate to contact us.

This policy applies to all individuals whose personal data we process as part of us providing our products and services (including all customers using our platform as well as sales representatives from partners using Velory’s platform in and outside of the European Union (“EU”) and the European Economic Area (“EEA”)).

In order to provide our products and services we need to process your personal data, as described in this policy. We collect various kinds of information about you when you buy our products and/or services, when you use our apps, portals and websites or otherwise communicate with us. We also collect information about you to improve our apps, portals and websites. Doing so enables us to deliver a better experience to you as a customer, as a sales representative and as a user of our apps, portals and websites.

We will only process personal data if we have a lawful reason for doing so.  The legal basis for processing personal data by us will be one of the following:

• the data subject (you) has given consent to the processing of personal data for one or more specific purposes (“consent”);
• the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
• the processing is necessary in order for us to comply with our legal obligations;
• the processing is necessary for the pursuit of our legitimate business interests;

4.1 Information we collect directly from you as a customer

We collect personal data directly from you when you register as a customer of Velory, when you place an order or sign up for an account on our apps, portals or websites. This kind of information that you provide us with, as well as the information on products/services and your financial information, is generally required in order for you to enter into a contractual relationship with us. This may include information such as:

• Personal and contact information – your name, email address, telephone number, date of birth, billing and shipping address
• Information on products/services – details about your orders
• Payment information – how you pay for your services
• Historical information – your purchases and payment history
• Account information – login and account information

4.2 Information we collect indirectly from you as a user of our apps, portals, websites and services

If you use our apps, portals and websites, we also collect information about how you use them, including when and how you log in or interact with content. This information includes device information, location information, usage and preference information and log information.

Device information

We collect information about your hardware device, such as:

• The hardware model
• Operating system version
• Phone number
• Device metadata
• Location of device when using our apps, portals & websites

Usage and preference information

We use various technologies to collect information about how users interact with our apps, portals and websites. This includes cookies, pixel tags, digital fingerprints and other similar technologies. To learn more about these technologies, please see Section 8 below (Cookies and other technologies).

Log information

When you use our apps, portals and websites, we collect and store information about you in our server logs. This includes information such as:

• The date and time of your login
• Your IP address
• Information about device events, such as crashes
• System settings
• System activity
• Hardware settings

Interactions with our portals and websites

When you visit our portal or any of our websites we collect information regarding how you interact with them. This applies to both customers and sales representatives for any of our partner brands. We use this information in order to improve the user experience and to evaluate the use of the individual elements. We collect this information to administrate, protect, operate and maintain our websites, system administration and security and to collect statistics about the site usage, purchases and to improve understanding of our customers preferences. This includes information such as:

• Page navigation
• Viewed pages
• Viewed categories
• Viewed products
• Interaction/clicks and searches
• Products added to cart

Information about how you use your personal hardware

If Velory provides your company with Mobile Device Management (MDM) we will collect data regarding your hardware device in order to manage mobile devices, tablets and computers. We need to collect this data in order to be able to deliver the MDM support service. This data includes information such as:

• IP address
• Location of the device
• Which Apps are installed on the device
• Which network the device is connected to
• We may require certain security measures (such as implementing password requirements or resetting the device in case of loss)
• We may also make restrictions for specific Apps, downloads and content for a device

We cannot access information stored on the device such as Internet history, Images, text documents, pdf files, contacts etc. We also cannot access or store communication history such as phone calls, SMS or Emails.

4.3 Information we collect from third party sources

We may collect information about you from third party sources. We may combine that information with other information that we collect from you directly or indirectly. For example, we may collect data from credit checks as required by some of the brands for which UA is a reseller. We do this on contractual grounds in the interest of the brands we represent.

4.3.1 Information we collect from your employer

If you are a user of Velory through your employer, we collect information about your hardware devices and software licenses tied to you as an employee. We might also store information about the history of these devices.

All information is used to provide, operate and improve Velory’s services and our apps and websites. We may also use the information from existing services in order to develop new services. In addition to this, we use your information to:

• Personalize and improve your customer and user experience;
• Verify your identity;
• Communicate with you;
• Inform you about important changes;
• Maintain, secure, protect and improve our apps and websites;
• Develop new features for our apps and websites;
• Analyze usage and activity trends;
• Provide personalized services, including content and advertising;
• Distribute and provide hardware devices with apps, new installations and security measures (applicable for MDM);
• Support - to install updates and settings for devices remotely (applicable for MDM);
• In order to format stolen devices & locate the devices on a map if they are stolen or otherwise lost (applicable for MDM);

We only share your personal information for the purposes we describe in this section. We may share your information with:

• Our employees, suppliers, subcontractors and consultants who need access to such information in order to carry out work on our behalf;
• Brands which we represent as a reseller, for the performance of our contractual obligations with you;
• Brands from which you as a customer made your purchase directly, in order for the brands' performance and administration of your order. The personal data shared with such brand will be subject to the brands' privacy policies and practices;
• Subsidiaries and partners that provide services or conduct data processing on our behalf or for data centralization and/or logistics purposes;
• Competent authorities and law enforcement (when it is required by law).
• Credit reference agencies and similar providers - for the purposes of assessing your credit score on behalf of certain brands for which Velory is a reseller;
• Customers’ who are authorized processors of this data (could for example be an employer of an end user of hardware devices to which we deliver the MDM service);

If we share your data a Data Processing Agreement will be signed

If we share your data with any of our partner brands, subsidiaries or external consultants we will sign a Data Processing Agreement (DPA) with them before we hand over your data in order to ensure that your information is stored and processed securely. The DPA complies with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

We may use automated decision making based on your personal information for some services in our apps or websites. For example, automated decision making may be used to expose you to particular products or services relevant to you, based on information you have provided us with directly or indirectly, such as purchase history or website usage. You may request a manual review of the accuracy of an automated decision, see Section 9.3 below.

We may transfer your personal data to countries outside the EU or EEA, for example if one of our partner brands is located in such an area. Some of these countries may have less protective data protection laws than the EU/EEA. Where this is the case, we will take appropriate measures to protect your personal information.

We will not sell your personal details to third parties unless we have your permission to do so. We will thereby ask for your explicit consent to share any personal information.

We do not keep your personal data longer than necessary. When the data is no longer needed for the purpose for which it was once collected, it will be deleted. However, legal requirements dictate how long we have to keep some types of information, for example information about payments we have made to you or you have made to us. We do not keep that information longer than required by law. We delete all other information we have about you within 24 months after the end of your contract with us.

We use cookies and other technologies in our apps and on our websites. These technologies have several purposes, including:

• Verifying users' identities;
• Providing sales representatives with tools and information they need to complete tasks and orders;
• Remembering users' preferences and settings;
• Analysing content usage, site traffic and trends; and
• Analysing how users interact with our apps and websites.

You can read our full cookie policy here.

Your privacy rights and choices are important to us. We work hard to respond promptly to all your requests. We may reject requests that are unreasonably repetitive or that require disproportionate technical effort. We will reject requests that put the privacy of others at risk. We handle your requests for free, except where it would require a disproportionate effort.

We put a lot of effort into securing your information and protecting it from accidental or malicious destruction. Therefore, it may take us some time until we delete all residual copies of your information from our active servers and backup systems.

You have the right to request a copy of the information that we hold about you in a structured, commonly used and machine-readable format. You can correct your account information at any time via our apps or websites. If you would like a copy of some or all of your personal information, please email or write to us at the following address: [email protected] or Velory AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.

You have the right to request that we erase the personal data we have about you but please note that we must keep some of your data due to legal requirements. If you would like us to erase your personal data, please email or write to us at the following address: [email protected] or Velory AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.

Some of the features in our apps, portals and websites are based on automated decision making. You have the right to object to those automated decisions that affect you. If you would like to object to such a decision or if you would like to request a manual review of the accuracy of an automated decision that you are unhappy with, please email or write to us at the following address: [email protected] or Velory AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.

You have the right to restrict us from using your data in certain situations, for example when the data we have about you is inaccurate. If you would like to request that we not use your data, please email or write to us at the following address: [email protected] or Velory AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.

You have the right to lodge a complaint about us with the supervisory authority. The supervisory authority for Velory is the Swedish data protection authority – Integritetsskyddsmyndigheten (IMY).

You have the right to withdraw your consent for data processing. There are different ways to change your given consent, below are some approaches to managing data collection.

We collect and use some of your personal data with your consent. You have the right to withdraw this consent at any time. For example, we collect your precise location from your device if you use our apps, portals or websites with your consent. If you initially allow us to collect this information and then change your mind, you can withdraw your consent by changing the location settings on your mobile device. However, this might disable you to use all the functions of the Velory platform.

You can choose whether or not to accept cookies on our websites. Most web browsers are set to accept cookies by default, but they allow you to remove or reject browser cookies in the browser settings. Our websites may not function properly if you refuse or remove cookies and you will not be able to log in to your account if you do not accept cookies. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit https://www.youronlinechoices.eu.

We may change this policy from time to time. If we do so, we will post the updated policy here and will inform you about the changes via the email address you have provided to us. The updated version will apply to all the information we have about you at that time and will apply to new information going forward.

Velory employs a Data Protection Officer (‘DPO’) who is responsible for facilitating data protection and data privacy compliance. If you have any questions about this policy, how we use your information, or your data privacy rights, please contact our DPO at the following address:

Data Protection Officer
Velory AB
c/o WeWork
Regeringsgatan 29
111 53 Stockholm
Sweden

E-mail
[email protected]

This Privacy Policy was last updated on 1st April 2022.