Privacy Policy

Revised: January 28th, 2022

Welcome to VERO, the online and mobile social networking service of Vero Labs, Inc. (“VERO,” “we,” or “us”).

VERO respects your privacy. It’s one of the core values of our social network.

The purpose of this privacy policy (“Privacy Policy”) is to help explain how we collect, use, protect, and disclose information and data when you use the VERO website (the “Site”) and any VERO mobile application (including the “VERO App”), application programming interfaces, and other services we offer (collectively the “Services”).

This Privacy Policy also explains your choices about the collection and use of your information, including opting out of certain uses of your Personal Information (defined below). This Privacy Policy applies to all users of the Site and Services.

We have tried to make this Privacy Policy clear and easy to understand, and we recommend you read it carefully. If you have any questions about this policy, please get in touch with us at [email protected] and the team will be happy to help.

 

The Short Version

The short version of the Privacy Policy is intended to be a helpful guide to the full Privacy Policy - which we encourage you to read – not a substitute for it.


1. Managing your information preferences

We provide ways for you to review, correct, update, or change your account information.


2. What information VERO collects

If you choose to create a VERO account, we collect some information directly from you in order to provide you with the Services, including your name, email address, phone number, and the type of device you are using such as the iPhone or Android model (so that we may send you push notifications, if you’ve selected this feature). We may also collect the payment information, shipping address, and billing address you’ve directly provided to us if you buy a product through our “Buy Now” feature or donate to a charity through our “Donate Now” feature.

We also collect information directly from you when you add elements to your user profile (e.g. your name, unique username, avatar/profile image etc.) or request account verification (if applicable) or contact VERO Support.

If you choose to enable VERO’s “Usage Info” functionality – which provides you with real-time information on the time you are spending in the VERO App - we automatically collect your cumulative session duration per day so we can display this information back to you, but this information is only stored on your device, your iCloud account (if on iOS), and anonymized and encrypted on our servers.

We may also receive additional information about you from third parties if you choose to connect your VERO App account to your account on third-party services.

We only use information about you:

  • to provide you the Services,

  • to communicate with you,

  • for security purposes,

  • to keep you updated about features, products, community news, and services we offer, and

  • to improve the Services.


3. How do we share the information we collect?

We may share your information with third parties under one of the following circumstances:

  • with your consent,

  • with our Service Providers who perform functions and provide services to us to help operate our Services (but always subject to obligations consistent with this Privacy Policy and anonymizing the information they receive as much as possible),

  • for security purposes (for example, to investigate issues like fraud or misconduct that may compromise the platform’s security)

  • to comply with our legal obligations, or

  • if there is a change of control at VERO.

We don’t trade Personal Information for money with anyone—period.


4. Personal Information you make public

All user profiles on the VERO App are public so your username, profile picture (avatar), and bio are visible to any VERO user. However, you may choose to make any of your posts on your profile private or public – you control who sees each post. In addition, all user profiles on the VERO App may be publicly displayed on the Site so that any visitor to the Site may see your profile. However, you can easily choose to not have your user profile displayed on the Site by making that choice in your profile privacy settings.


5. Inviting a contact to use VERO and sharing your Contact Information

You can choose to sync your contact list on your mobile device with VERO, so that you can find and connect with people you know and help others find you.

When other VERO users attempt to “Add Contacts” using their device’s contact list or by searching a name or user ID, we will identify you as an existing VERO user if your contact information is already in your friend’s contact list.


6. No Advertising

There are no ads or sponsored posts on VERO. The only content you see in your chronological feed is content from accounts you are connected to or accounts you follow. Those accounts may post content that includes links to third-party companies’ properties or you may use content from third-party companies in your own posts (e.g. posting a link to a YouTube video or tagging your photo post with a location, sourced from our third party location data provider). As such, third-party companies may collect certain anonymous information from you like your IP address or device information (as they do on other sites and platforms). We are not responsible for how these companies collect or use this information. However, if such companies use this data for advertising purposes, you may opt out of these companies’ use of your information for such purposes by visiting: www.networkadvertising.org or www.aboutads.info/choices.


7. Security

We work hard to efficiently protect your data and regularly review our information collection and storage practices in line with best industry practices to prevent unauthorized access to our systems.


8. Links

You may come across links to third party websites and services on VERO. We are not responsible for such sites or services.


9. Children

We don’t knowingly collect information from children under 13. If we become aware of any such collection, we will promptly delete such information from our records.


10. Location of Processing

We process the information we collect in the United States. Our Service Providers may process information in the United States and/or other locations.


11. EU and Swiss Residents

If you are a resident of an EU member state or Switzerland, you have additional rights regarding your Personal Information.


12. How Long Does VERO Keep Information About Me?

We retain your Personal Information for as long as your account is active or as needed to provide you the Services.


13. Changes to Our Privacy Statement

We will notify you of material changes to this Privacy Policy. You may also track changes to the Privacy Policy on the Site and on the VERO App.


14. California Consumer Privacy Rights

If you are a resident of California, you have additional rights regarding your Personal Information. Note that we do not sell any of the Personal Information that we collect about you.


15. Contacting VERO

Please contact us at [email protected] if you have questions about our Privacy Policy.


 

Privacy Policy (Full Version)

1) Managing Your Information Preferences

You can review, correct, update, or change your Personal Information through your account. You may receive emails from us about the Services from time to time, such as emails about the status of your account or product updates. We will only send marketing e-mails if you have consented to us sending them to you. You may unsubscribe from such messages at any time. However, there are certain communications about the Services that we need to send you, like important updates to the Terms of Use or Privacy Policy. You may not opt out of these types of messages. If you have any questions about reviewing or modifying your account information, you can contact us directly at [email protected].


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:

  • Contact Information: 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, we immediately pass this information to our payment processor (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;

  • Other identifying information: IP address, 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), and (if you provide this in support of your request to verify your VERO App account) a copy of your photo/government ID, any copies of which we will promptly delete after we verify your account (or determine your account will not be verified);

  • Payment Information: credit card and debit card numbers (if you choose to use our “Buy Now” feature or “Donate Now” feature; however, we do not store this information);

  • Your device type (e.g. iPhone or Android phone model) so that we may send you push notifications (if you so choose)

  • Geolocation data (such as if you’re tagging 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 Site, 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

  • 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.

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:

  • Open your account;

  • To let you see your daily usage of the VERO App within the VERO App if you so choose through the “Usage Info” feature – note that this Usage Info (defined herein) is stored locally on your device (and, if using iOS, your iCloud account) and may be anonymized and encrypted on our servers;

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

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

  • Permit you to share content with others on the VERO App.

  • 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:

  • Provide and maintain functionality of the Site, the VERO App, and our other Services;

  • Improve the Site, the VERO App, and our other Services and better serve our users;

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

  • Help us diagnose technical and service problems and administer the Site, 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 Site, 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 about you from third parties. We may also receive certain identifying information about you from third parties. For example, by “following,” “liking,” adding the VERO App, linking your account (such as music streaming services to listen to a music post or a third-party social network in order to cross-post) to the VERO App, a third-party may pass certain information about your use of its service to VERO. This information could include, but is not limited to, the user ID associated with your third party account (for example, your Facebook or Twitter UID), an access token necessary to access that service, any information that you have permitted the third-party to share with us, and any information you have made public in connection with that service. We only store this information locally on the device as needed to access that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the VERO App. You may also unlink your third-party account from the VERO App by adjusting your settings on the third-party service. If you unlink your third-party account, we will remove the information collected about you in connection with that service.

We collect information from your activity on the VERO App. We automatically collect and anonymize information regarding the actions you take on the VERO App (“Analytics Data”), which we use for our own analytical purposes to improve the VERO App and our other Services. All Analytics Data is anonymized and aggregated. We do not share Analytics Data with any third parties other than our Service Provider which provides us the analytics platform.

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. This feature shows your time spent on the VERO App broken out by days and times to better informed of how you use the VERO App – no other user can access this information. Note that the information shown to you under the “Usage Info” feature of the VERO App is not stored by VERO (or if we do store it on our servers, will be anonymized and encrypted) or shared with any third parties as it is stored on your own device and (if using iOS, your iCloud account).

Advertising and referrals of VERO App. We may collect certain identifying information (e.g. device ID, or IP address) and Internet or other electronic activity on the VERO App 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 section 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.

In addition, we may share (like all other services that rely on internet activity) IP addresses with third parties to provide you with features of the Service like tagging photos with location data – in that case, Foursquare Labs Inc. (“Foursquare”) and Microsoft Corporation (“Bing”) - or enabling linking to third party sites – for example, if you click on another user’s post linking to a YouTube video or an article on a third party website. Please refer to these third parties’ respective privacy policies. For example, Foursquare’s privacy policy can be found at http://foursquare.com/legal/privacy and Bing’s privacy policy at https://privacy.microsoft.com/en-us/privacystatement.

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.

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 Site, 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 Site 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 Site. 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.


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

We provide two features in the VERO App for you to expand your network on VERO: “Invite Friends” and “Add Contacts.”

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.

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 and any of the phone numbers connected to your account that we have collected will be deleted from our servers.

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 third-party social media sites, then you understand that the information these sites provided to us to conduct this type of search is governed by their privacy policies and your account settings on those sites. 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) Advertising and Online Tracking

There is no advertising on the Site, the VERO App, or our other Services. We may, however, allow third-party companies to collect certain information for advertising purposes when you interact with third parties through the Site, the VERO App, and our other Services. Examples include, when you download the VERO App from a referral advertisement on third party websites or social networks or if you click on a link to a third party website on the VERO App. These companies may use the information to provide advertisements on other websites about goods and services likely to be of interest to you. These companies typically use a cookie or pixel tag or similar technology to collect this information. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/www.aboutads.info/choices/.

Because we do not have advertising on the Site, the VERO App, or our other Services, our systems do not recognize browser “Do Not Track” signals. We will, however, provide you with tools to opt out of marketing messages from us. You can learn about this in the “Managing Your Information Preferences” section of this Privacy Policy.


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 Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site 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 Site, 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 Site 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 Site 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 European Union or other regions with laws governing data collection and use that may differ from the United States law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any Personal Information are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards, such as the Standard Contractual Clauses (SCC) Standard contractual clauses for data transfers between EU and non-EU countries.


11) EU and Switzerland Residents

If you are located in the EU or Switzerland, you have the following rights in respect of your Personal Information that we hold:

a) Right of access. The right to obtain access to your Personal Information.

b) Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.

c) Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.

d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.

e) Right to portability. The right to portability allows you to move, copy or transfer Personal Information easily from one organization to another.

f) Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

g) Right to withdraw consent. You should be aware that you are entitled to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your Personal Information, this may affect our ability to provide you with rights to use the Service.

If you wish to exercise one of these rights, please submit your request via the VERO App by going to your account profile, Settings, and tapping on “Contact Support”. Alternatively, you may contact us at [email protected].

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.


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 or Switzerland, we store Personal Information for as long as necessary to fulfill the purposes for which we collect the information (see Section 3 above), except if required otherwise by data protection laws.


13) California Consumer Privacy Rights

If you are a resident of California, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This section describes those rights and how you can exercise them with VERO.

Please note that we do not sell any of your Personal Information.

CCPA Rights Requests

Right to Know and Right to Deletion

You can request what Personal Information we have collected, used and disclosed in the preceding 12 months.

You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:

  • Transactional: to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;

  • Security: to detect data security incidents;

  • Error Correction: to debug or repair any errors;

  • Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or

  • Internal Use: to use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).

Please note that if we delete your Personal Information, many of our Services will not work the same. For example, your previous opt out requests will not be saved, you will not have an account, and saved preferences and information will no longer be available.

To submit a request to know or to delete your account, please do so directly within the VERO App (so that we may verify your identity). You will find this by going to your VERO App profile. For requests to know, you must include “California Request to Know” in the subject of your in-app message and each request must be via separate in-app message to our support team. To delete your account (which includes all the information we have for you), you may do so automatically in your VERO App profile by tapping on “Settings”, tapping on “Account” and selecting “Delete Account”.

If you no longer have the VERO App, you may alternatively submit a request to know or delete by emailing us at [email protected]. You must use “California Request to Delete” or “California Request to Know” in the subject line of your email, as appropriate. Your email will also need to include the following: the phone number and email address you registered your VERO account with, the verification code that we will send upon our receipt of your email to your registered phone number, and the date that you registered your VERO account. To verify your identity, we will match that information to the information we have on our systems. The information must match in order for us to process your emailed request.

In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized agent must submit that written proof at the time they make the request on your behalf. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA Rights.


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 Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site 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].

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.