Valid as of March 2, 2023
Visitors to our website(s), mobile applications and other online properties (“Site” or “Sites”)
Any other individual about whom Valora may obtain Personal Data
Collection of Personal Data
Valora collects Personal Data that you provide directly to us, such as your full name, email address and/or telephone number, when you use our products, browse our Site(s), register to receive newsletter requests or other information, provide feedback through surveys, or participate in any interactive features on our Sites, including contests, promotions, challenges, activities or events. We also collect Personal Data provided by job applicants or others, such as your full name, email address and physical address, on our Sites in connection with employment or consulting opportunities, which may also be subject to other Policies. We may also collect Computer Internet Protocol (IP) address, unique device identifier (“UDID”), cookies, web beacons, web server logs and other technologies and other data linked to a device, and data about usage of our Sites (Usage Data).
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.
With your consent, you may instruct Valora to access an encrypted version of your contacts' phone numbers, which you can then use to find which of your contacts are already on Valora. However, no Personal Data will be shared with anyone directly, including Valora.
Other types of information we may collect include your name, email address, username, phone number, location and any other information you choose to provide. We may use automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain automatically may include your device IP address, identifiers associated with your devices, types of devices you have connected to our services, your web browser characteristics, your usage patterns, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site.
We may also obtain your Personal Data through your use of social media, such as Facebook, Twitter or Instagram, depending on your settings or the privacy policies of these services. To change your settings on these services, please refer to their respective privacy notices.
Finally, Valora may be required by law to obtain certain information from you from time to time for purposes of meeting its know-your-customer and customer due diligence requirements specifically to comply with anti-money laundering and countering the financing of terrorism obligations.
Use of Personal Data
We use the Personal Data that we collect:
To make our products and Sites more intuitive and easier to use by using device data, cookies and other information that you may provide. This data is necessary for our legitimate interests in monitoring how our products and Sites are used to help us improve these products and Sites, and the information and tools available on these products and Sites.
To provide relevant marketing including providing you with information about events or services that may be of interest to you. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.
To consider individuals for employment and contractor opportunities and to manage onboarding processes we use job applicant data. The processing is necessary for the purpose of recruitment and onboarding.
To deliver products and services to you by verifying your identity (for example when you access your account information); processing applications for products or services; and processing transactions.
To personalize your digital and mobile experience by enhancing our Sites and Mobile Apps organization and design, and analyze data to create relevant alerts, products or services.
To detect and prevent fraud, identity theft and other risks to you or Valora.
To perform analytics concerning your use of our online services and Mobile Apps, including your responses to our emails and the pages and advertisements you view.
To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
To Allow you to use features within our Sites and Mobile Apps when you grant us access to personal information from your device such as contact lists, or geo-location when you request certain services that require such access.
How we share your information
We may share the personal information we collect from and about you as described here with:
Our affiliates and subsidiaries;
Service providers, vendors and third-party providers who have contracts with us;
Government agencies as required by applicable law;
Another company, but only in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to such company;
With your consent or at your direction; and
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
We use the following sub-processors to operate our Services:
Segment.io Inc: Site Visitor Data Platform (United States)
Google: Site Visitor Analytics (United States)
Lever, Inc.: Applicant Tracking Platform (United States)
ActiveCampaign, LLC: Visitor Tracking and Communication Platform (United States)
ipstackIP: Address Geolocation (Austria)
cLabs: Site Maintenance and General Support (United States/Germany)
Sentry: error tracking and performance monitoring (United States)
Adjust: analytics platform (United States)
CleverTap: analytics (United States)
Mixpanel: analytics platform (United States)
Statsig: analytics platform (United States)
Legal Bases For Processing (For EEA and other Users)
If you are an individual from the European Economic Area (“EEA”) or a jurisdiction with similar data protection regimes, we collect and process your Personal Data only where we have a legal basis for doing so under applicable laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your personal data only:
To operate our business, including to improve and develop our services, for fraud prevention purposes, improve user experience, or other legitimate interests;
To fulfill contractual responsibilities; and/or
As otherwise in compliance with the law.
If you have any questions about the legal basis for processing, please contact us at the address listed in the “Contact Us” section.
Transfer of Personal Data To Other Countries
We may transfer your Personal Data to countries outside of your country of residence, including, but not limited to the EEA, as well as the United States, where Valora’s office and some of its IT systems (including email) are located. Personal Data is not processed outside of the United States.
YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR DATA IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR DATA TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR DATA WITH US, OR MAKE USE OF THIS SITE.
TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING DATA IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE EEA. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.
Making Sure Your Information is Accurate and Individual Rights
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please contact us at firstname.lastname@example.org.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond effectively to your request. Requests should be directed to email@example.com.
How We Protect Your Information
Protecting your information is important to us. We maintain administrative, technical and physical safeguards designed to protect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of Personal Data.
How Long We Retain Your Information
We strive to only keep your Personal Data only for the period of time needed for legitimate business purposes. In certain circumstances, however, legal or regulatory obligations may require us to retain records for longer than we otherwise would.
Our Services are not directed to children under the age of 18. If you learn that a child under the age of 18 has provided us with Personal Data without consent, please contact us.
If you are resident in states or countries with applicable data privacy laws you have the right, subject to certain exceptions, to request a copy of the Personal Data we are processing about you; to require that any incomplete or inaccurate Personal Data is amended; to request that we delete your Personal Data (although we may not be able to delete certain data due to legal or other obligations); to object to the use of your Personal Data; or to withdraw consent. You may also contact us to address and resolve concerns you may have about our use of your Personal Data. Please contact us at firstname.lastname@example.org.
Third-Party Services, Applications, and Websites
Certain third-party services, websites, or applications (including, but not limited to, decentralized apps) you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.
We engage with customers on social media platforms such as Twitter, Instagram, Facebook, and Discord.
When interacting with official Valora social media pages, Valora’s privacy notice may apply.
We may allow certain non-affiliated third-party widgets (for example social share buttons) on our sites that enable users to easily share information on another platform, such as a social media platform. The non-affiliated third parties that own these widgets may have access to information about your browsing on pages of our Sites and Mobile Apps where these widgets are placed.
YOUR CALIFORNIA PRIVACY RIGHTS
Shine the Light Law
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