Velvet Verify Privacy Policy and Statement

Velvet Verify is committed to protecting your (“Your” or “You”) information that Velvet Verify may collect from or which You may submit to or through the App or mobile applications that directly link to this privacy statement. Velvet Verify herein also referred to a “Company,” “we,” “us,” or “our”, or collectively, the App. And you, the individual, herein also referred to as “User,” “you,” or “your”).

This privacy statement (the “Privacy Statement”), together with Velvet Verify END USER AGREEMENT, WAIVER OF LIABILITY, AND CONSENT, describes how We may use Your information and how that information may be used or disclosed by Us.

Please read the following carefully to understand Our views and practices regarding Your information and how We will treat it.

This Privacy Statement does not apply to information that is considered Protected Health information, as defined by Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). As explained in the END USER AGREEMENT, WAIVER OF LIABILITY, AND CONSENT, the App is neither a Covered Entity nor a Business Associate under HIPAA. For more information on the use and disclosure of information collected about or from residents of California and Virginia, please see our California and Virginia Privacy Policy. The California and Virginia Privacy Policy supplements this Privacy Statement. If there is any conflict between this Privacy Statement and the California and Virginia Privacy Policy, the California and Virginia Privacy Policy will control solely with respect to information relating to residents of California and Virginia. If you are a resident of California or Virginia, You acknowledge our California and Virginia Privacy Policy.

This Privacy Statement applies only to information collected on the App. It does not apply to information collected on any third-party site that may link to or be accessible to the App over which We have no influence or control. The use of other sites, or the submission of information to other third-party sites is at Your own risk and is subject to their privacy statements and policies.

Collecting Your Information

Generally, You can visit the App without revealing who You are and without disclosing any of Your information. However, there may be times when We require information about You or Your device, or when You wish to disclose such information to Us. Such information is obtained when You use our App or it is submitted by You, and is subject to the provisions set out in this Privacy Statement.

We collect and process the following information:

Unique identifiers, such as Your name, online identifier, email address, account name, or other similar personal identifiers.
Protected classification characteristics under applicable laws, such as Your age (40 years or older), race, ancestry, national origin, medical condition, physical or mental disability, sex (including gender, pregnancy and related medical conditions), genetic information (including familial genetic information).
Commercial information, such as records of products or services purchased or obtained, or correspondence from You.
Usage information and other similar network activity, such as browsing history, device ID, search history, Internet Protocol address, information on Your interaction with a App, device geolocation, application type and version, or advertisements placed and ad interactions.

We obtain the information listed above:

Directly from You, such as from documents or forms You provide to Us, or preferences You express or provide when accessing our services;
Indirectly from You, such as by observing Your activity when receiving, using, or accessing our services;
Automatically from You, such as through the use of tracking technologies and other cookies as You use our digital services, including Our Apps and mobile applications; or
From third-parties, such as to monitor and analyze the use of our Apps, mobile applications, for payment processing, or other third-party vendors that We use to provide services to You, including Apps and mobile applications through the course of providing services to You or jointly with Us.

Where required by law, We may ask for Your additional explicit consent to collect information considered to be sensitive personal information (such as information about Your ethnicity or health information). You may withdraw such consent at any time by contacting Us at the details below.

We do not ask You to provide personal health care information to Us through our general App.* We obtain personally identifying information about You only if You voluntarily choose to provide such information through the App. Feedback forms used in Velvet Verify correspondence specifically request that You not include personal information such as user names, passwords, social security numbers, and private health information.

Correspondence conducted via Velvet Verify feedback forms is stored on a third-party server and then downloaded by Velvet Verify personnel.

If You are a user of the Velvet Verify Patient mobile application, You may be asked to grant access to Your device’s file storage to store and retrieve data in order to view PDF files in the application.

Various Velvet Verify webpages and programs give users the option to make electronic payment for services. Information from these bill payment links is not tracked or recorded but may be transmitted to independent third parties for payment processing.

We may be required by law to collect certain personal information about You or as a consequence of any contractual relationship We have with You. Failure to provide this information may prevent or delay the fulfillment of these obligations.

How We Will Use Your Information

We use Your information for one or more of the following purposes:

We DO NOT sell user information.
To fulfill or meet the reason for which the information is provided, including to process payments and other financial transactions.
To provide You with information, products, or services that You request from Us.
To provide You with electronic messages consisting of alerts, reminders, event registrations and other notices concerning Our products or services, events, or news that may be of interest to You.
To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us.
To improve Our App and present its contents to You.
For testing, research, analysis, and product development.
As necessary or appropriate to protect the rights, property or safety of Us or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your information directly or as otherwise set forth under applicable law.

When we use Your contact information to communicate to You about new services and products that may be of interest to You, You will be given the option of receiving periodic informational/promotional mail or email from Us. You choose whether or not to receive correspondence when You provide this information or by changing Your preferences within Your registration profile or by following the instructions provided in the email at any time.

If You do not want Us to use Your information in this way, please contact Us at the details below.

Third Parties Disclosures

We may share Your Personal Information with agents, contractors, or partners of Velvet Verify in connection with services that these individuals or entities perform for, or with, Velvet Verify. We may, for example, provide Your information to agents, contractors, or partners for hosting Our databases, for data processing services, or so that they can mail You information that You requested.

Velvet Verify will disclose Your information in response to duly authorized information requests of any law enforcement agency, court, regulator, government authority, or other third party, where We believe such disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect Our rights or the rights of any third party, including to identity or locate anyone for the prevention or detection of crime or the apprehension or prosecution of o`enders. You waive and hold Us harmless from any claims resulting from such disclosures and from any actions taken as a consequence of investigations by either Us or law enforcement authorities.

We will also transfer your information to a third party in connection with the sale, assignment, or other transfer of Our business to which the information relates.

We also share aggregate, non-personal information about App usage with a`iliated and una`iliated third parties.

Information Security and Storage

We reserve the right to take any appropriate legal action, including referral to law enforcement, for any illegal or unauthorized use of this App. We also reserve the right take any action to prevent the unauthorized use of Our intellectual property.

The Retention of Your Information

We will retain and use Your information to the extent and for a period permitted under applicable law, including as necessary to comply with our legal obligations, resolve disputes, enforce our legal agreements and policies, and protect Our property.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the App, or We are legally obligated to retain this data for longer time periods.

The Safety and Security of Your Personal Information Also Depends on You

If You choose or are given a user identification code, password or any other information as part of Our security procedures for one of the registration-only sections of the App, You are responsible for maintaining the confidentiality of Your password and user name for the App and You are responsible for all activities that are carried out under them.

We will not be liable where Your password or user name is used by someone else. You agree to notify Us immediately at the contact information provided below of any unauthorized use of Your password or user name of which You become aware. We have the right to disable any user identification code or password, whether chosen by You or allocated by Us, at any time to safeguard your account and data.

Please be aware that while We take appropriate steps to safeguard the security of Your Personal Information, the transmission of information over the Internet is not completely secure and therefore You do this at Your own risk.

Financial information and payment data, including credit card numbers, that You provide to Us via the Velvet Verify internet bill payment link is encrypted. This information will be accessed only by Velvet Verify agents and employees and third-party vendors who support Velvet Verify’s billing operations.

We implement technical and organizational measures to maintain a level of security appropriate to the risk to the Personal Information We process.

To request that Your Personal Information be deleted from Our databases, please see below for more information.

Cookies and Our Use of Tracking Technologies

Velvet Verify tracks visitors to our App by collecting usage data using various methods, tools, and technologies to store or collect information about Your use of and access to our App (“tracking technologies”). Tracking technologies may set, change, alter or modify settings or configurations on your device. A few of the tracking technologies we may use include the following (and subsequent technology and methods later developed):

Cookies. A cookie is a unique data file placed on a device when it is used to visit our App. Cookies help enable Your preferred web experience, allowing Our App to
recognize your device and preferences, and to track Your use of and interest in di`erent parts of our App.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our App’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including to count visitors to the App, to monitor how users navigate the App, or to identify particular articles or links actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about Your interactions with the App, such as the links You click on. The code is temporarily downloaded onto Your device from our web server or a third-party, is active only while You are connected to the App and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from Your browser used on Your device, such as Your browser type, version, operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and di`erent ETag is assigned. Used in this manner, ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about devices, users, and activities on the App (e.g., that a user of multiple devices is the same user), including session and event recorders, voice to text recognition, etc.).

These tracking technologies are used to (1) enable certain functions and tools on the App,

(2) assist in the navigation of the App, (3) track resources and data used on the App, (4) promote Velvet Verify’s products and services, and (5) remember computer settings. Velvet Verify also collects other forms of usage data, such as information on browsers used to access our App, search terms used to find the App, and tra`ic referrals and links to our App. This usage data may not be permanently maintained within our tracking system.

Velvet Verify also uses the services of Google Analytics and other similar software to analyze tra`ic to the various Velvet Verify webpages. Data collected regarding site usage is compiled

in aggregate to improve the performance of the site, create a profile of uses, and improve our marketing and advertisements. By accessing our App, You expressly consent to the use of these tracking technologies, and this data collection and use.

If You do not wish Your information to be included in aggregated data through Google Analytics, You can download and install Google’s “Google Analytics Opt-out Browser Add-on” available here. If You wish to prevent the use of cookies or for Your information to be included in aggregated data through Google Analytics, You must modify the properties on Your web browser for both as described above.

We are giving You notice of the tracking technologies and Your available choices regarding them so that your consent is meaningfully informed. You are responsible for managing any preference changes on your device or browser. Generally, certain tracking technologies may be rejected, disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser You use will need to be set separately and di`erent browsers o`er di`erent functionality and options in this regard.

Please be aware that if You disable or remove these tracking technologies some parts of our App may not work and when You revisit Our App your ability to limit browser-based tracking technologies is subject to Your browser settings and limitations.

Various third parties are developing or have developed signals or other mechanisms known as “do not track signals.” For instance, some browsers may have such signal options, although they di`er as to if the signal is set as default or must be turned on by the user. Further, there is currently no standard as to what sites and app operators should do with regard to these signals. Currently, we do not monitor or take any action with respect to these signals or other mechanisms, although we may consider doing so if an understandable and practical standard is developed and widely adopted.

Internet Links

The Velvet Verify App may contain links to a number of sites that may provide useful information. Links contained on the Velvet Verify App that transfer You to a non-Velvet Verify site are not maintained by Velvet Verify and may contain di`erent information and/or di`erent privacy policies from those of our Company. You may review the privacy policies of these Apps and/or receive specific information regarding that site's privacy policies and procedures after leaving the Velvet Verify site. Velvet Verify is not responsible for the content or privacy practices of a non-Velvet Verify App. Velvet Verify does not control, or have any input into, whether our business partners or internet-linked sites, use or accept cookies on their sites.

Updates and Changes

We may update this Privacy Statement from time to time. When We do update it, for Your convenience, We will make the updated Privacy Statement available on this page. Changes and additions to the Privacy Statement are e`ective from the date on which they are posted. Please review the Privacy Statement from time to time to check whether We have made any changes to the way in which We use Your Personal Information.

Children's Privacy

You should be aware that this Site is not intended for, or designed to attract, individuals under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with personal information, please contact Us.

Your Rights over Your Personal Information

You may have certain rights regarding Your personal information, subject to local law. These may include the right to:

access Your personal information;
rectify the information We hold about You;
erase Your personal information;
restrict Our use of Your personal information;
object to Our use of Your personal information;
receive Your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
lodge a complaint with Your local data protection authority if one exists in Your country.

We encourage You to contact Us to update or correct Your personal information if it changes or if the information We hold about You is inaccurate. Please note that We will likely require additional information from You in order to honor Your requests.

You may request that Your personal information be deleted, You may continue to receive materials for a short period while We are updating Our lists. Your records will then be permanently deleted from Our systems.

How to Contact Us

Email us at support@velvetverifyapp.com

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California and Virginia Privacy Policy Addendum

This California and Virginia Privacy Policy (the “Policy”) applies solely to California and Virginia residents and their Personal Information covered under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). This Policy describes how Velvet Verify and its subsidiaries (collectively “the App”, “We”, “Us” or “Our”) may use and disclose California and Virginia residents’ (“Consumers”, “You” or “Your”) Personal Information. Under the CCPA and VCDPA, personal information is any information that identifies or is reasonably capable of being associated with You or Your household (“Personal Information”).

Collecting Your Personal Information

We collect, and have collected, Personal Information from the following categories within the last twelve (12) months, including, where necessary, certain information that may be considered sensitive (as indicated in italics below). We may use or disclose Your Personal Information for one or more of the following business purposes indicated below.

Categories of Personal Information

Identifiers, such as name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.
Personal Information as listed in the California Customer Records statute, such as name, signature, Social Security number, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information, STI Status, (some Personal Information included in this category may overlap with other categories).
Protected classification characteristics under applicable laws, such as age (40 years or older), race, ancestry, national origin, medical condition, physical or mental disability, sex (including gender, pregnancy and related medical conditions), or genetic information (including familial genetic information).
Commercial information, such as records of products or services purchased or obtained.
Biometric information, such as genetic, physiological, behavioral, and biological characteristics, health, or exercise data.
Internet or other similar network activity, such as browsing history, search history, or information on Your interaction with a website, application, or advertisement.

How We Will Use Your Personal Information

We DO NOT sell user information.
To fulfill or meet the reason for which the Personal Information is provide.
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 carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us.
To improve Our website(s) and present its contents to You.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of Us or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting your Personal Information directly or as otherwise set forth in the CCPA or VCDPA.

We obtain the categories of Personal Information listed above directly from You, such as from documents or forms you provide to Us, or indirectly from You or from third-parties, such as where we collect Personal Information through the course of providing services.

We will not use the Personal Information We collect for materially di`erent, unrelated, or incompatible purposes than those listed above without providing You notice.

Third Parties

We may share Your Personal Information with a`iliates, service providers and authorized agents for a business purpose. These third parties are restricted from using Your Personal Information in any way other than for a business purpose.

In the preceding twelve (12) months, we have shared the following categories of Personal Information with the third parties listed above for a business purpose:

Identifiers;
California Customer Records Personal Information categories;
Commercial information;
Internet or other similar network activity; and

We may also provide your Personal Information to third parties to comply with legal obligations (such as courts or law enforcement) and to protect and defend our rights and property.

If we are considering or are involved in a merger, acquisition, financing, due diligence, reorganization, bankruptcy, receivership, or sale of Company assets, or transition of service to another provider, your Personal Information may be disclosed or transferred in connection with the transaction as permitted by law and/or contract. We have not sold any Personal information in the past twelve (12) months.

Retention of Your Personal Information

We will retain Your Personal Information in accordance with applicable legal requirements and only for as long as necessary for the purposes described herein, or as long as required by law or to defend potential legal claims, and in accordance with Our data retention policies.

Your Rights over Your Personal Information

Subject to certain exceptions, You are entitled to specific rights as it relates to Your Personal Information. In particular, these rights include the right to (i) delete Your Personal Information; (ii) correct any inaccuracies in Your Personal Information; (iii) request more information on the collection and use of Your Personal Information; (iv) receive and transfer your Personal Information; and (v) not be discriminated against for exercising the above rights.

To exercise Your rights described above, please submit a request to Us by either:

Submitting a request to support@velvetverifyapp.com.
Calling us at 201-564-0255

Only You, or a person duly authorized on Your behalf, may make a request related to Your Personal Information. You may also make a request on behalf of Your minor child.

You may only make a request twice within a twelve (12) month period. Each request must provide su`icient information that allows Us to reasonably verify You are the person about whom We collected Personal Information or that you have duly authorized the person making the request on Your behalf. Your request must contain su`icient detail that allows Us to properly understand, evaluate, and respond to it. In some instances, We may not be able to comply with Your request, in which case We will respond with the reasons that prevent Us from complying.

We will not discriminate against You for exercising any of Your rights under the CCPA or VCDPA.

Updates and Changes

We may update this Policy from time to time. When We do update it, for Your convenience, We will make the updated Policy available on this page. Changes and additions to the Policy are e`ective from the date on which they are posted. Please review the Policy from time to time to check whether We have made any changes to the way in which We use Your Personal Information.

Contact Information

If You have any questions or concerns regarding the way in which Your personal information is used, please contact Us via mail at support@velvetverifyapp.com, marking Your letter for the attention of the Privacy O`ice. Our Privacy O`ice can be contacted at 201-564-0255.

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