2) Information We Collect

Personal Information

“Personal Information" is any information about one of our users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as a username and password, an email address, a real name, an Internet protocol (IP) address, and a photograph are examples of “Personal Information.” We collect the following categories and types of Personal Information when you interact with us:

• Contact Information you provide: your first and last name, phone number, email address, shipping address and billing address. We only collect your shipping and billing information if you choose to use our “Buy Now” feature or “Donate Now” feature; however, this information is passed to our payment processor, Stripe (who then shares it with the vendor or charitable organization you are buying from or donating to). We do not access or store your credit card information or shipping information. Stripe’s use of your personal information is governed by their privacy policy. To view Stripe’s privacy policy, please click here;

• Other Identifiers: such as IP address and third-party social media handles (if you opt in to cross-posting to other social media services, post it on your VERO App account, or if you provide this information in support of your request to verify your VERO App account);

• Identity Verification Information: If you choose to verify your VERO app account, we rely on an independent third-party identity verification provider, Yoti, that requires our users to provide their identity verification information on the provider’s own site or service. If you choose to verify your identity with our third-party identity verification provider, the provider’s processing of personal information, including biometric information, will be subject to the provider’s own terms and privacy policy (which will be presented to the customer during the verification process). To view Yoti’s privacy policy, please click here.

  As part of the identity verification process, you may be asked to submit your name, phone number, email address, date of birth, government identification number and copies of government identification documents, along with a selfie image and/or video. The provider may use a combination of machine learning tools and optical scans to authenticate your identity document and conduct a “liveness” check, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." In this circumstance, the provider may retain a copy of your selfie image, video, and/or government ID (as well as the biometric facial geometry extracted from the images) for the purposes and length of time described in that provider’s privacy policy, including for the purpose of streamlining future identity verification attempts using that provider’s identity verification platform. Please review the provider’s privacy policy closely to understand how your personal information, including biometric information, will be used, disclosed and retained by the identity verification provider.

  VERO does not receive the biometric identifier generated from the images, however, for identity verification and security purposes, VERO will receive the results of the identity verification process, including the images of your ID and the results of the liveness check, as well as text extracted from the ID scan. We may use some or all of this information and associated information to verify your account.

• Payment Information: credit card and debit card numbers (if you choose to use our “Buy Now” feature or “Donate Now” feature; however, please note that we use a third party payment processor, Stripe, to process this information. As such, we do not retain any personally identifiable financial information in connection with credit or debit card payments, such as credit card numbers.);

• Information about your device (e.g. iPhone or Android phone model, device identifiers) so that we may send you push notifications (if you so choose);

• Geolocation data (general geolocation data may be derived from your IP address; we may also collect your location data if you tag a post with a location);

• Internet or other electronic activity (all anonymized and not used to identify you or your individual user behavior): your browsing and click history on the VERO App (e.g. likes, clicks on posts), including information about how you navigate the VERO App and which elements of the VERO App you use the most; and

• Visual, audio, and text information: photos and videos that you post on the VERO App and any text content you’ve posted such as comments to a post, captions to your photos and videos, or chat messages exchanged through the VERO App. We “collect” this in order to store it to be shown on the VERO App to those you are sharing it with but we do not use this content for any other purpose.

You may be asked to provide us with Personal Information when you register with or use the VERO Website, the VERO App, or any of our other Services, and at other times.

In addition, we collect the following information but solely for security purposes. We make use of security tools such as anti-fraud / hacking detection and code decompile detectors in our app that are designed to further protect your data and require us to collect the following information:

• device identifiers, operating system and log data (e.g., the date/time of visit, the time spent on our Services, the electronic path taken to our Services, through our Services and when exiting our Services, and any errors that may occur during the visit to our Services); and

• IP address; and

• and general geographic location based on IP address or device location.

This data is only used for security purposes in using tools to guard against bad actors like frauds and hackers and their malicious code / bots and not for any other purpose.

Usage Info: If you opt into this feature, we also automatically collect how much time you are spending in the app (“Usage Info”), which powers the “Usage Info” feature on the VERO App. If you choose to enable it, this feature shows your time spent on the VERO App broken out by days and times to better inform you of how you use the VERO App – no other user can access this information. This information is only stored on your device, your iCloud account (if on iOS), and anonymized and encrypted on our servers.

Categories of Use

We use your Personal Information for the following purposes:

• Transactional Purposes: We use your contact information, payment information, and other identifying information you have given us to:

  • To open your account;

  • To allow you to find others and have others find you on the VERO App;

  • To facilitate transactions if you buy a product through our “Buy Now” feature or donate to a charity through our “Donate Now” feature; and/or

  • To enable you to share content with others on the VERO App (you can control the audience for each post and communication)

• Analytical Purposes: We use your anonymized internet or other electronic activity and geolocation data on the VERO App to analyze preferences, trends, and statistics to better improve the VERO App and our Services for our users and promote our Services.

• Marketing Purposes: We may use your contact information and internet or other electronic activity to inform you of our new products, services, opportunities and offers. You may opt out of these messages at any time in the message itself or on the VERO App.

• Maintenance and Improvement of Site and Services: We use your contact information and internet or other electronic activity to:

  • To provide and maintain functionality of the VERO Website, the VERO App, and our other Services;

  • To improve the VERO Website, the VERO App, and our other Services and better serve our users;

  • To handle your customer services requests, including directing your questions to appropriate team members, investigate, and address any of your concerns, and improve and monitor our customer support responses; and

  • To help us diagnose technical and service problems and administer the VERO Website, the VERO App, and our other Services.

• Security and Fraud Prevention: We may use your contact information, audio and visual information, other identifying information and internet or other electronic activity to protect the VERO Website, the VERO App, and our other Services, our company and others, and for fraud detection, theft prevention, emergency response purposes, and legal compliance.

Sources of Personal Information

We collect information from the following sources:

We collect information directly from you. We collect contact and certain identifying information directly from you when you register for an account on the VERO App. Also, if you choose to cross-reference your contact list on your device with the list of users on the VERO App, your contacts’ phone numbers (though not their names) may be used and stored to allow you to: invite your contacts to the VERO App, connect with those who are also already on the VERO App, or provide you with updates if and when your contacts join the VERO App.

We collect information from your activity on the Services. We automatically collect information regarding the actions you take on the VERO App and Site (“Analytics Data”), which we use for our own analytical purposes to improve the VERO App and our other Services. All Analytics Data collected from the App is anonymized and aggregated. We do not share Analytics Data from the App with any third parties other than our Service Provider which provides us the analytics platform. Analytics Data collected from certain portions of the VERO Website may be used for advertising purposes. Please see below and the “Third-Party Data Collection and Online Advertising” sections of our Privacy Policy for more information.

Advertising and referrals. We do not display advertising on the VERO website or app, but we may collect certain identifying information (e.g. device ID, or IP address) and Internet or other electronic activity on certain portions of the VERO website passively using tools like browser cookies, SDKs, and other similar technologies through Service Providers for referral tracking. For example, if you click on one of our ads for the VERO App on another website, we may track that action and market the VERO App to you through another ad. We may also use this information for our own analytics purposes to improve the VERO app and our other Services. This activity is further described in the “Cookies and Anonymous Identifiers and “Third-Party Data Collection and Online Advertising” sections below.

3) When We Share Information with Third Parties

Our Service Providers

From time to time, we may engage other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may engage Service Providers to provide certain services, such as hosting and maintenance, data storage and management, payment processing, data enhancement services, fraud prevention, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

Our Affiliates

We may share Personal Information and Usage Data (again, anonymized) with businesses controlling, controlled by, or under common control with VERO. If VERO is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.

Law Enforcement and Courts

We cooperate with government and law enforcement officials and private parties (for example, in connection with providing information relevant to a pending lawsuit or investigation) to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third-party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

Ad Networks and Advertising Partners

We work with third-party ad networks and advertising partners to deliver advertising and personalized content promoting the VERO app on other websites and services. These parties may collect information directly from a browser or device when an individual visits our Website through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. For more information, please see the “Third-Party Data Collection and Online Advertising” section.

Cookies and Anonymous Identifiers

We may use cookies and similar technologies to store anonymous identifiers (a random string of characters) and other user information on your device to remember your settings and temporarily (until the data is removed from your device or the cookie runs out) identify you. We may also use this to collect Usage Data to analyze use of and improve the VERO Website, the VERO App, and our other Services. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Services may not work if you delete or disable cookies. Some of our Service Providers may use their own cookies, anonymous identifiers, or other tracking technology only in connection with the services they perform on our behalf to keep the Services functioning.

4) Personal Information You Make Available to Others

By using the VERO Website or the Services you may make certain of your Personal Information available to others. For example, when you post a comment or a photo on the VERO App other users may see your name, content, and other information that you choose to make available to them. Any information or content that you voluntarily disclose for posting to the VERO App becomes available to the public, as controlled by any applicable privacy settings.

You can change your privacy settings directly in the VERO App at any time by going to your profile setting. Subject to your profile and privacy settings, any user content that you make public is searchable by other users, including on the VERO Website. If you remove information that you posted to the VERO App, copies may remain viewable in cached and archived pages of the VERO App, or if other users have copied or saved that information.

In addition, we may share certain information about you, such as IP address, with your consent or direction. For example, if you search for an image using Bing, your search terms and IP address may be shared with Microsoft Corporation. In some instances, such as with your use of Bing, these third parties’ privacy practices are governed by their respective privacy policies. Bing’s privacy policy is available at https://privacy.microsoft.com/en-us/privacystatement.

5) Inviting a contact to use VERO from the “Add Contacts” feature; Sharing your Contact Information; Finding contacts on VERO

We provide three features in the VERO App for you to expand your network on VERO: “Invite Friends,” “Add Contacts,” and in-app discovery.

Our “Invite Friends” enables you to invite others onto the VERO App. You can also find people you know on the VERO App through our “Add Contacts” feature or by searching names and usernames on the VERO App. “Add Contacts” allows you to find contacts either through the contact list on your mobile device or through a search of names and usernames on the VERO App. When you register for an account you have the option to notify other VERO Users in your contact list that you have joined the Service.

If you choose to use any of these features, you will be asked to grant us permission to access and collect only the phone numbers from your contact list on your mobile device and such information. Note that we do not collect the names or any other information associated with these phone numbers. You may turn off this access at any time in your profile settings so that we no longer can access your contact list.

Additionally regarding the “Invite Friends” feature, you understand that you are directly sending a text or email from your own phone or e-mail accounts. In addition, you understand and agree that normal carrier charges apply to communications sent from your phone. Since this invitation is coming directly from your email or phone, we do not have access to or control this communication.

If you choose to add your contacts through a search of names or usernames, then simply type a name to search and see if that name or username appears on the VERO App.

Similarly, when other VERO App users use the “Add Contacts” feature on the VERO App, we will identify you as a VERO App user to that user if your contact information is already in their contact list.

6) Third-Party Data Collection and Online Advertising

We do not display third party advertising on the VERO Website, the VERO App, or our other Services. We may, however, allow third-party companies to collect certain information for advertising purposes on certain portions of the VERO Website, or when you interact with ads for our products and services on third party sites (such as by clicking on the ad or downloading our app), in the contexts described further below.

Specifically, we permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of the VERO Website over time so that they may play or display ads for our products and services on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the VERO Websites, AdID, and other similar information. If permitted by your device settings, they may also collect location data through GPS, Wi-Fi or other methods. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms.

 We may engage in the following:

•  Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, Pinterest, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. They may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

• Third Party Partners.  We work with certain third-party partners to provide advertising-related services, including on specific portions of the VERO Website. We do this to promote VERO on third party websites. For example, we use Google Analytics to recognize you and link the devices you use when you visit specific portions of the VERO Website on your browser or mobile device or otherwise engage with us.  We share a unique identifier with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, “How Google uses data when you use our partners’ sites or apps” located at http://www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.

 We may also utilize certain forms of display advertising and other advanced features through Google Analytics to advertise our Services to you on third party websites. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Google Ads advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at  https://google.com/ads/preferences, or by visiting NAI’s online resources at  http://www.networkadvertising.org/choices.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at http://www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).  You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us.  It means that the online ads that you do see from DAA program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

7) Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the VERO Website or Services, we cannot and do not guarantee the security of any information you transmit on or through the VERO Website or Services, and you do so at your own risk.

8) Links

Our Site and Services may contain links to other websites or services or allow others to send you such links. A link to a third-party’s website or service does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites or services. You access such third-party websites or services, or the content on them, at your own risk. You should always read the privacy policy of a third-party website or service before providing any information to that website or service.

9) Children’s Privacy

The VERO Website, the VERO App, and our other Services are intended for users who are 13 years old or older. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13 without verification of parental consent, we will delete such information from our records. California users under the age of 18 may request the removal of their content or information publicly posted on the Vero Website or Services by emailing us at [email protected].

10) Location of Processing

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. We store and process the information that we collect in the United States in accordance with this Privacy Policy though our Service Providers may store and process data outside the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the VERO Website or Services, you agree that the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States. If you are located in the EU, UK or Switzerland, please see the “Additional EU, UK and Switzerland Privacy Disclosures” for additional information about how your personal information may be transferred internationally.

11) EU, UK and Switzerland Residents

If you are located in EU, UK, or Switzerland, please see the “Additional EU, UK and Switzerland Privacy Disclosures” for additional EU, UK and Switzerland -specific privacy disclosures.

12) How Long Does VERO Keep Information About Me

Following termination or deactivation of your account, we may retain your profile information and user content for a commercially reasonable amount of time for backup, archival, or audit purposes, but in no event for longer than is allowed under applicable data protection laws. For individuals based in the EU, UK or Switzerland please see the “Additional EU, UK and Switzerland Privacy Disclosures”.

13) U.S. State Privacy Rights

If you are a resident of the States of California, Colorado, Connecticut, Nevada, Utah and Virginia, you have additional rights regarding your Personal Information. Please see the “Additional U.S. State Privacy Disclosures” below for additional information.

14) Privacy Policy Changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the VERO Website. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the VERO Website or Services, you are consenting to the revised Privacy Policy.

15) Contact Us

If you have any questions about this Privacy Policy or the Services, please contact us at any time at [email protected].