Veezy may also receive Personal Information from its partners (“Partners”), the sites, programs, products or services that you use (for example, from Veezy advertisers). In such a situation the transfer of Personal Information is possible only in cases established by applicable law and is carried out on the basis of special agreements between Veezy and each of the Partners.
Please note that the use of any of the Sites and/or Services may be subject to additional terms and conditions that may modify and/or add to this Policy and/or have special terms regarding personal information posted in the relevant sections of the documents for such Sites or Services.
2. Who processes the information
To ensure your use of the websites and services, your personal information is collected and used by Veezy, including IT Crew Limited Liability Company, a legal entity established under the laws of the Russian Federation and registered at: 199178, St. Petersburg, 17th line V.O., house 52, building 2, lit.
3. What is the purpose of this policy
Protecting your Personal Information and your privacy is extremely important to Veezy. Therefore, when you use the Sites and Services, Veezy protects and processes your personal information in strict accordance with applicable law.
In keeping with our responsibility to protect your personal information, we would like to be as transparent as possible in this policy about the following:
• Why and how Veezy collects and uses (“processes") your Personal Information when you use the Sites and/or Services
• What are the roles and responsibilities of Veezy as the legal entity that decides why and how we process your Personal Information
• What tools you can use to reduce the amount of Personal Information Veezy collects about you
• What are your rights in relation to the processing of Personal Information
4. What Personal Information Veezy collects about you
Veezy may collect the following categories of Personal Information about you when you use the Sites and Services:
• Personal information provided by you when registering (creating an account), such as your name, phone number, address and age;
• electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information);
• date and time of access to the Sites and/or Services;
• information about your activity while using the Sites and/or Services (for example, search history, email addresses of those with whom you correspond, email content and attachments, and files stored on Veezy systems);
• geolocation information;
• other information about you required for processing in accordance with the terms governing the use of specific Veezy Sites or Services;
• information about you that we receive from our Partners in accordance with the terms of agreements entered into between you and the relevant Partner and agreements entered into between Veezy and the Partner.
Veezy does not purposefully collect sensitive personal information (such as racial origin, political opinions, health information and biometric data). Veezy does not collect data for the purpose of creating a “personal profile” of a user to the extent that this may materially affect your rights and freedoms under applicable law.
5. What is the legal basis and purposes of processing your Personal Information
Veezy may not process your Personal Information without a reasonable legal basis. Therefore, Veezy will only process your Personal Information if:
• the processing is necessary to fulfill Veezy’s contractual obligations to you, including to operate the Sites and Services
• processing is necessary for compliance with statutory obligations
• when it is required by applicable law, processing is necessary for the legitimate interests of Veezy, unless such processing materially affects your interests, your fundamental rights and freedoms. Please note that when processing your personal information on these grounds, Veezy will always strive to maintain a balance between its legitimate interests and the protection of your privacy.
Veezy processes your Personal Information for its legitimate interests, for example, in the following cases:
• to better understand how you interact with our Sites and/or Services
• to improve, change, personalize or otherwise improve the Sites and Services for the benefit of all users
• to offer you other products and services of Veezy or other companies that we think you may be interested in (i.e. show you ads tailored to your interests)
• for specific purposes or as required by applicable law, we may request your separate consent to process your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, your use of the Veezy Sites and/or Services constitutes your consent to such processing. We hereby inform you and you acknowledge that you have no obligation to provide us with any Personal Information when you use the Sites or Services and is based solely on your free will. However, you acknowledge that without providing Personal Information, we will not be able to provide you with the opportunity to use the Services and your use of the Sites will be limited.
Veezy will always process your Personal Information for specific purposes and only Personal Information relevant to those purposes. In particular, we process your Personal Information for the following purposes:
• providing you with access to the Sites and/or Services
• providing access to your account if you are registered in the relevant Services
• to communicate with you to send you notices, requests and information related to the operation of the Sites and Services, to fulfill agreements with you and to process your requests and applications;
• personalization of ads and offers based on your preferences, search history and other personal information about you available to Veezy
• improve the user experience of the Sites and Services, including providing more personalized Sites and Services, and to improve other Veezy products, applications and Services;
• creation of new Veezy products, utilities and offerings
• protect your rights and the rights of Veezy
• collection, processing and presentation of statistical data, big data and other research.
6. How Veezy Protects Your Personal Information
In most cases Personal Information is processed automatically without access to it by any Veezy employee. Should such access be required, it may only be granted to those Veezy employees who need it to perform their tasks. To protect and maintain data privacy, all employees must comply with internal policies and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures which act to protect your Personal Information.
Veezy has also put in place reasonable technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access or other unlawful forms of processing. These security measures have been implemented taking into account the actual level of technique, the cost of their implementation, the risks associated with the processing and nature of Personal Information.
7. Who else has access to your Personal Information and to whom it may be shared
7.1 Within Veezy projects
Veezy may share your Personal Information with its employees (to the extent specified in Section 6 of this Policy). Veezy may also share your Personal Information with its affiliates. Please note that the level of protection of Personal Information in some countries may not match the level established in your jurisdiction, and by using the Veezy Services, you consent to such transfer.
7.2 Outside Veezy projects
Veezy may also share Personal Information with third parties outside of Veezy projects in order to achieve the purposes set out in Section 5 of this Policy. Please note that the level of protection of Personal Information in some countries may not match the level established in your jurisdiction, and by using the Veezy Services, you consent to such transfer.
Such third parties may include:
• Partners such as site and app owners, ad networks and other partners who provide services to Veezy related to the placement and display of advertising on sites, programs, products or services owned or controlled by such partners
• advertisers or other Partners who display advertisements for you on the Veezy sites and/or Services, and Partners such as information service providers or consultants
• third parties in respect of which the assignment of rights or obligations has been made, or novation under the relevant agreement
• any national and/or international regulator, law enforcement agency, central or local executive authority, other official or government agency or court for which Veezy is required to provide information under applicable law upon request
• to third parties, if you have expressed your consent to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to fulfill a certain agreement or contract concluded with you
• to any third party for Veezy’s or third parties’ legal defense if you violate the Veezy Services User Agreement, this Policy or the terms governing the use of individual Services or where there is a threat of such violation.
8. Where your Personal Information is stored and processed
Your Personal Information will be stored in the Russian Federation and/or the EEA.
For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, Veezy has taken appropriate steps to ensure that such transfers are made in accordance with applicable EU data protection regulations.
In particular, Veezy is guided by the Standard Contractual Clauses approved by the European Commission to provide an adequate level of protection for your Personal Information transferred to Russia. A copy of these Standard Contractual Clauses is available upon request.
If you are located in a territory where the transfer of your Personal Information to another jurisdiction requires your consent, then by using the Sites or Services, you give Veezy your express and unequivocal consent to such transfer or storage and / or processing of information in other specified jurisdictions, including Russia.
9. How long do we keep your Personal Information
Veezy will retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory requirements. Unless otherwise required by law or agreement with you.
If you wish to have any of your Personal Information removed from Veezy’s databases, you may remove the necessary Personal Information yourself using your account or through the interface of the Sites and/or Services (where applicable).
10. Your rights
10.1 What rights you have
Where required by applicable law, you have the right to access your Personal Information processed by Veezy in accordance with this Policy.
If you believe that any of the information Veezy holds about you is incorrect or incomplete, you can log into your account and correct your Personal Information yourself.
If provided by applicable law, you have the right to:
– request the deletion of your Personal Information or part of it as well as withdraw consent to the processing of your personal information
– require restrictions on the processing of your Personal Information
– request a copy of the Standard Contractual Clauses that permit the transfer of your Personal Information to Russia and are set out in Section 8 of this Policy
– object to the processing of your Personal Information if required by applicable law.
Veezy will comply with such requests in accordance with applicable law. To the extent permitted by applicable law you may also have other rights not listed above.
10.2 How you can exercise your rights
To exercise the above rights, please log in to your account and if there is no special function in the interface, contact Veezy (see section 13 of this Policy).
If you are not satisfied with the way Veezy handles your Personal Information, please let us know and we will look into your complaint. If you are not satisfied with Veezy’s response, you have the right to file a complaint with the competent authority.
11.1 What cookies are and what Veezy uses them for
Cookies are small text files placed on the device you use to access the Sites. They contain information that is collected from your device and sent back to the Sites each time you visit them in order to remember your actions and preferences over time.
The Sites use the following types of cookies:
Strictly Necessary Cookies/Technical Cookies: these cookies are essential for the operation of the Sites and provision of the Services to you; among other things, they allow Veezy to identify your hardware and software, including your browser type;
statistical / analytical cookies: these cookies allow us to recognize users, count their number and collect information such as the activities you have performed on the Sites and Services, including information about the web pages you visit and the content you receive;
technical cookies: these cookies collect information about how users interact with the Sites and/or Services, which allows us to identify errors and test new features to improve the performance of the Sites and Services;
functional cookies: these cookies allow certain features to be provided to make your use of the Sites easier, for example by storing your preferences (such as language and location);
(Third Party) Tracking / Advertising Cookies: These cookies collect information about users, traffic sources, pages visited and ads displayed to you as well as the one that led you to the advertised page. They allow you to display advertisements that may be of interest to you based on an analysis of the Personal Information collected about you. They are also used for statistical and research purposes.
11.2 How long cookies are stored on your device
Veezy uses the information contained in cookies only for the above purposes, after which the collected data will be stored on your device for a period that may depend on the corresponding type of cookies, but no longer than necessary to achieve their purpose after which they will be automatically removed from your system.
11.3 Who else has access to information contained in cookies
Personal information collected through cookies placed on your device may be transferred and available to Veezy and/or the third parties identified in Section 7 of this Policy. Use of Personal Information outside of the Sites for promotional purposes, if any, may be subject to separate user agreements available on third party websites. Veezy and/or third parties may also provide you with the option to opt out of ad personalization, which may be subject to the laws and regulations applicable to such products and offerings.
Veezy may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:
• identifying your activities on the Sites and while using the Services by accessing and using cookies stored on your device;
• collection of statistical information related to the operation of the Sites, Services or Veezy products, utilities and offerings.
12. Updates to this Policy
This Policy may be subject to change. Veezy reserves the right to make changes in its sole discretion, including but not limited to cases when such changes are related to changes in applicable law and also when such changes are related to changes in the operation of the Sites and Services.
Veezy will not make material changes or impose additional encumbrances or restrictions on your rights under this Policy without you being notified of these changes. Appropriate notices may be displayed on the Site or Services (for example, through a pop-up window or banner) before such changes become effective or may be sent to you through other communication channels (for example, by e-mail if you have provided us with your Contact details).
13. Questions and suggestions
Veezy welcomes your questions and suggestions regarding the implementation or modification of this Policy. You can use this address email@example.com to make inquiries about the exercise of your rights or complaints about the incorrectness of your Personal Information or the illegality of its processing.