This Policy is designed to apply to the Velocity Career Wallet App (“App”) as available in both the Apple Store and Google’s Play Store.

Identity and contact details of the controller and Data Privacy officer

Velocity Career Labs Inc. (“Velocity” or “we” or “us” or “our”), as controller of personal data, is responsible for the processing of personal data that relates to you (“you” or “User”) under applicable data protection laws and regulations.

If you have questions regarding the processing of your personal data, please contact Velocity’s data privacy officer at DataOfficer@VelocityCareerLabs.com.

For the purposes of this Privacy Policy, “personal data” is any information about a specific individual or that identifies or may identify a specific individual. In other words, it is any piece of information than can be linked to you.

The term “process” or “processing” means any use of personal data, including but not limited to the collection, recording, organization, storing, adaptation, alteration, transferring, making available, blocking, deletion or destruction of personal data.

Information concerning identity verification by Yoti, is provided in the second half of this Policy.

IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY, PLEASE, DO NOT ACCESS THE APP.

Changes in the policy

We reserve all rights to adjust this Privacy Policy at any time and for any reason. You will be made aware of such an adjustment by reference to a change in the “Last updated” date of this Privacy Policy (referenced above). You are encouraged to periodically review this Privacy Policy to stay informed of any updates or changes. You will be deemed to have been made aware of, will be subject to, and to have accepted the changes in any revised Privacy Policy by your continued use of the App after the date such updated Privacy Policy is posted here.

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COLLECTION OF YOUR PERSONAL DATA

Types and purposes of Personal Data. We use Personal Data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. When processing personal data, we make sure that we do so by relying on one of the available legal bases under applicable data protection laws, as described herein:

• Contact Details. When you sign up on the App, we collect some information about You which may include full name, email address, and phone number. We use such information to register you, contact you (if necessary) and maintain our business records. The legal bases on which we rely are ‘performance of a contract’ and ‘pursuing our legitimate interests’ (to administer Velocity’s business).  

• Inquiries. When you contact us by any mean available, we collect your full name, email address, and any information that you decide to include in your message. We have no control over the information you decide to provide in your message, and we advise you not to share sensitive Personal Data. If you provide information about others, it is your responsibility to have their proper consent. We use such data to respond to your inquiries. The legal basis on which we rely is ‘pursuing our legitimate interests’.
• Credentials. When you (or someone on your behalf) upload to the App any Credential (as described on the Wallet Holder User Agreement), or as part of the Credential verification process, information, such as employment and educational information, licenses and certifications, ID documents (including a picture of you) and any other information you share through the App, is being collected. We have no control over the information you decide to provide us, and we advise you not to share sensitive Personal Data that is not necessary. If you provide information about others, it is your responsibility to have their proper consent. We use such data to provide you with the service. The legal bases on which we rely are ‘performance of a contract’ and ‘pursuing our legitimate interests’ (to administer Velocity’s business).
• In collaboration with third-party vendors as described below, we also collect information from the device you are using while interacting with us through our App, such as IP addresses, device details, country location data and genericized logs.

Push Notifications

We may request to send you push notifications regarding activities relating to the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

HOW WE MAY SHARE YOUR PERSONAL DATA

Velocity may share your Personal Data it has collected about you in certain situations, for the specified purposes set out above. Your Personal Data may be disclosed with third parties such as Velocity’s suppliers, including companies and suppliers outside the EU/EEA.

Part of our third-party suppliers consists of suppliers that facilitate us with the usage and performance of our App which includes monitoring of traffic and analytics within the App through the use of cookies and other similar technologies. For further information regarding the usage of cookies refer to our Velocity Career Labs Cookie Policy.

In particular, we use Google Analytics, LogRocket, Sentry and Mixpanel. For further details on the way Google uses personal information see the link “How Google uses data when you use our partners’ sites or apps”.

For further details on Mixpanel, LogRocket and Sentry review their terms and conditions here:

Terms of Use | Legal | Mixpanel

Terms of Service 1.2.0 | Sentry

LogRocket: Terms and Conditions

In the event we will transfer Personal Data to our third-party suppliers that are located outside of the EU/EEA, and if required under applicable law, Velocity will ensure the implementation of appropriate safeguards in place to provide adequate level of protection to the Personal Data in accordance with the applicable data protection laws (including the EU General Data Protection Regulation – ‘GDPR’). For example, this may include the use of EU approved Standard Contractual Clauses or such other mechanism as have been recognized or approved by the relevant authorities from time to time. We will disclose Personal Data to comply with any court order, law or legal process, including to respond to any government or regulatory request.

Finally, if we ever sell Velocity, or participate in a merger or consolidation, Personal Data may be transferred. When you share personal data with third parties (e.g., Issuers, Relying Parties, etc.) (“Third Parties”), as described in the Wallet Holder User Agreement, processing of such personal data will be subject also to the third parties’ privacy policies.

HOW LONG WILL VELOCITY KEEP THE PERSONAL DATA?

Velocity will retain Personal Data only for as long as needed for the purposes described above. After this period, Velocity will only process Personal Data as may be required to comply with local legal obligations or to satisfy any legal requirements in the event of an actual, threatened or anticipated dispute or claim.

YOUR DATA PROTECTION RIGHTS

You may be entitled, where provided for under applicable data protection laws and regulations, to:

• Request access to the Personal Data Velocity processes about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of the specific pieces and categories of personal data.
• Request a rectification of your Personal Data: this right entitles you to have your Personal Data corrected if it is inaccurate or incomplete.
• Object to the processing of your Personal Data: this right entitles you to request that Velocity no longer process your Personal Data.
• In certain situations, as it may be applied in the applicable data protection law, and when you wish to terminate your account, you can request the erasure or deletion of your Personal Data: this right entitles you to request the erasure or deletion of your Personal Data.
• Request the restriction of the processing of your Personal Data: this right entitles you to request that Velocity processes your Personal Data only in limited circumstances.

• Request portability of your Personal Data: this right entitles you to receive a copy (in a portable and, if technically feasible, readily usable format) of your Personal Data.
• In the event that our processing of your Personal Data or part thereof is based on your consent: to withdraw at any time your consent, in which case Velocity will cease any further processing activities of your Personal Data or the relevant part thereof (however such withdrawal will not affect the legality of the data processing activities prior to the withdrawal). Please note that Velocity may not always be obliged to comply with a request of deletion, restriction, objection or data portability. Assessment may be made on a case-by-case basis of Velocity’s legal obligations and the exception to such rights.
• You also have the right to lodge any complaints you may have regarding Velocity’s processing of your Personal Data to a supervisory authority. For more information about these rights and how to exercise them, please contact the Velocity Privacy Officer via the contact details set out above.

HOW DOES VELOCITY SAFEGUARD THE PERSONAL DATA

Velocity utilizes appropriate and reasonable legal, technical and organizational security measures, including information technology security and physical security measures, to adequately protect the Personal Data.

These measures are appropriate to the risks posed by the processing of the Personal Data and to the sensitivity of the Personal Data and take into account the requirements of applicable local law. In addition, the measures are continuously improved in line with the development of available security products and services.

Velocity requires all persons to abide by applicable security policies related to personal data when using Velocity systems. 

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at: hello@velocitycareerlabs.com.  

YOTI IDENTITY VERIFICATION

In order to use the App identity needs to be verified. This is done by Yoti a digital identity company. If you live in the USA then Yoti (USA) Inc (a company registered in the state of California) verifies your identity, and if you live outside of the USA, then Yoti Limited (a company registered in England and Wales) is verifying your identity.

HOW YOTI USES YOUR INFORMATION

Yoti collects an image of your government issued identity document and your facial image. Yoti then performs the following checks:

1. An automatic ‘liveness’ test to check if the image captured is of a real person, or if it is a photo or a screen being displayed to the camera.

2. An automatic face match test to compare the selfie image against the photo in the government issued identity document.

3. Extraction of data from the government issued identity document, either through a chip read of the document or by automatically reading the data on the document.

4. A manual authentication inspection of the government issued identity document to check for signs of tampering or fraud.

Yoti does these checks to verify your identity before you can receive and share credentials through the App. Yoti does not use your personal data for any other purposes.

YOTI’S RETENTION PERIOD

If you pass the verification checks then Yoti provides your data to the App. Yoti deletes the data from its own systems automatically within 7 days.