This privacy policy will explain how VELO.AI, INC. (“Velo”) uses the personal data we collect from you when you use our app and website. 

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Topics covered by this policy

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• What data do we collect? 
• How we collect your data 
• How we use your data 
• How we store your data 
• Access to and management of your data
• Disclosure of your data
• Marketing 
• What are cookies? 
• How do we use cookies? 
• What types of cookies do we use? 
• How to manage your cookies 
• Privacy policies of other websites 
• Changes to our privacy policy 
• How to contact us 
• California Consumer Privacy Act (CCPA) provisions

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What data do we collect? 

Velo collects the following personal information about you:

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• First and Last Name 
• E-mail Address 
• Phone Number 
• Home Address
• Credit card information for product purchases online 

We may also collect anonymous demographic information, which is not unique to you, such as your age, gender, or race.

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In addition, our device records information, including frequency of use, geolocation data about your rides, and risks you encounter during your rides (which we call incidents), and can record video of your rides (which includes data concerning use, location, and incidents). We collect information about use, location, and incidents, and you can opt to share ride video with us.

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In the future, we also may gather other personal information, anonymous demographic information, device information, or other non-personal information.

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We do not collect any personal information about you unless you provide it to us. You may be required to provide certain personal information when you elect to use certain products or services, such as (a) registering for an account; (b) sending us an email message; (c) submitting your credit card or other payment information when ordering and purchasing products and services; (d) entering a sweepstakes or contest sponsored by us or one of our partners; (e) signing up for special offers from selected third parties. 

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We will use your information for, among other things, communicating with you in relation to services and/or products you have requested from us. 

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How we collect your data 

You directly provide Velo with most of the data we collect. We collect data and process data when you: 

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• Register online or place an order for any of our products or services. 
• Log into your account, if you have one.
• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email. 
• Use or view our website via your browser’s cookies. 
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• Upload data to the Velo system.

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Velo may also receive your data indirectly from the following sources:

• Use of your device.
• Third party service providers, such as the Google geolocation API.

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How we use your data 

Velo collects your data so that we can:

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• Process your orders,
• Manage your account.
• Contact you, including to inform you of special offers on other products and services we think you might like.
• Improve our ability to detect and identify potential incidents and alert riders to the associated risks.
• Perform other activities that we believe will be useful, such as data analysis, identifying usage trends, evaluating and improving our products, services, and your experience.

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When Velo processes an order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

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Velo does not sell, rent, or lease its customer lists to third parties.

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Velo may share data it collects with service providers to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Velo, and they are required to maintain the confidentiality of your information. However, these providers collect, store, use, process, and transfer information in accordance with their Privacy Policies. 

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How we store your data 

Velo securely stores your data with cloud service providers and at onsite secure sites. The security of your data is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your data, we cannot guarantee its absolute security. 

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Velo will keep data pursuant to the following schedule:

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• Personal information, such as contact information, will be kept for as long as you are an active user of Velo’s products and services, as determined in Velo’s sole discretion.
• Non-personal information, such as anonymous demographic information, will be kept indefinitely.
• Incident data, ride videos, and associated data will be kept for as long as it is useful for allowing Velo to assess and improve its product offerings.

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Once the applicable period has expired, we delete data by securely erasing it from any storage media, via cloud service providers or at onsite secure sites.  This process is in line with industry standards for data destruction and is periodically reviewed to comply with the latest security protocols and legal requirements.

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Access to and management of your data

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

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If you believe any information that Velo has collected is inaccurate, please let us know, and we will correct it. 

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Under certain conditions, you can request that Velo erase or delete your personal data. 

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Disclosure of your data

We may disclose your data if we (a) are involved in a merger, acquisition or asset sale; (b) are required by law; or (c) believe in good faith that disclosure is necessary to comply with a legal obligation, protect and defend Velo, prevent or investigate possible wrongdoing, or protect the safety of users.

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Marketing 

Velo may use your personal data to contact you with newsletters, marketing materials, and other information that we think you might like. You can opt out of receiving these communications at any time by following the unsubscribe link or instructions provided in any email we send or by contacting us at support@velo.ai with subject line Unsubscribe.

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What are cookies? 

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information about cookies, visit www.allaboutcookies.org.

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How do we use cookies? 

Velo uses cookies in a range of ways to improve your experience on our website, our app, and our products, including: 

• Keeping you signed in 
• Understanding how you use our website 

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What types of cookies do we use? 

There are a number of different types of cookies, however, our website uses: 

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Functionality - Velo uses these cookies so that our system remembers your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

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Advertising - Velo uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Velo sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website. 

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Social media cookies: These cookies are set by a range of social media services that 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.

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Web Beacons and Anonymized Analytics Cookies - Velo and third-parties use these to track your anonymous data about your journey every time you visit our website. This way we can see how visitors use the website and improve on that basis. We use anonymized analytical cookies for:

• tracking the number of visitors to our web pages;
• tracking the amount of time each visitor spends on our web pages;
• keeping track of the order in which a visitor visits the different pages of our website;
• assessing which parts of our site need updating;
• measuring and optimizing the performance of our marketing campaigns;
• redirecting traffic from different channels.

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How to manage cookies 

You can set your browser not to accept cookies. Learn more about how to do so by visiting www.allaboutcookies.org. However, in a few cases, some of our website features may not function as a result. 

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Privacy policies of other websites 

The Velo website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. 

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Changes to our privacy policy 

Velo keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on December 14, 2023. 

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How to contact us 

If you have any questions about Velo’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at support@velo.ai  

California Consumer Privacy Act (CCPA) provisions

For purposes of the CCPA, we may collect or have collected the following categories of personal information from consumers within the last twelve (12) months:

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Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Yes

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Yes

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

No

G. Geolocation data.

Physical location or movements.

Yes

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

I. Professional or employment-related information.

Current or past job history or performance evaluations.

No

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

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Under CCPA, personal information does not include: 

• Publicly available information from government records 
• Deidentified or aggregated consumer information 
• Information excluded from the CCPA's scope, such as: 

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data 
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

We collect information from the following sources: 

• Directly from You. For example, from the forms you complete for us, preferences you express or provide to us, or purchases you make from us. 
• Indirectly from You. For example, from observing your activity on our website. 
• Automatically from You. For example, through cookies or directly from your device. 
• From Service Providers. For example, third party vendors to monitor and analyze the use of our website, third party vendors for payment processing, or other third party vendors that we use to provide service to you.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To perform analysis on device usage or video recordings as necessary to conduct typical business activities.

These examples are illustrative and not intended to be exhaustive. 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing personal information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A:         Identifiers.
Category B:         California Customer Records personal information categories.

Category E: Biometric information

Category G: Geolocation data

Category H: Sensory data

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your rights and choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

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Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at support@velo.ai 

Velo would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following: 

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• The right to restrict processing - You have the right to request that Velo restrict the processing of your personal data, under certain conditions. 
• The right to object to processing - You have the right to object to Velo’s processing of your personal data, under certain conditions. 
• The right to data portability - You have the right to request that Velo transfer the data that we have collected to another organization, or directly to you, under certain conditions. 

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If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: support@velo.ai