Privacy Notice

Velocent Analytics Ltd. ("Velocent," "we," "us," or "our") is committed to protecting your privacy. This Privacy Notice explains how we collect, use, store, share, and safeguard personal data when you interact with our websites, platforms, analytics tools, marketing channels, or other services under our control (collectively, the "Services"). Our Services are designed for businesses and professionals, not for personal or household use. As such, we process personal data primarily in the context of business-related activities.

By using our Services, you acknowledge that you have read and understood this Privacy Notice. If you do not agree with the practices described, please do not use our Services or provide us with any personal data.

If you have questions or concerns about our privacy practices, please contact us at contact@velocent.co.

1. Scope of This Privacy Notice

This Privacy Notice applies to personal data we collect when you:

• Visit our website (velocent.co) or other linked platforms;
• Engage with our analytics tools or services;
• Interact with our marketing campaigns, emails, or advertisements;
• Attend our events, webinars, or other promotional activities; or
• Contact us directly for support or inquiries.

"Personal data" refers to any information that can identify an individual, either directly or indirectly, such as name, email address, or IP address. It does not include anonymized or aggregated data that cannot be linked to an individual.

2. Types of Data We Collect

We collect the following categories of personal data, depending on your interaction with our Services:

a. Business Contact Data

Who: Representatives of our business customers, account administrators, billing contacts, or other authorized users ("Users").

What: Name, business email, phone number, job title, company name, and other professional details.

How Collected: Provided directly by you when creating an account, contacting us, or engaging with our Services.

b. Prospect Data

Who: Visitors to our website, attendees of our events, or individuals who interact with our marketing content ("Prospects").

What: Contact details (e.g., name, email), engagement data (e.g., website interactions, event registrations), and inferred preferences based on your interactions.

How Collected: Collected automatically via website forms, cookies, or during event registrations.

c. Usage and Technical Data

Who: All users and visitors to our Services.

What: IP address, browser type, device information, operating system, geolocation (derived from IP address), browsing behavior, and interaction logs.

How Collected: Automatically through cookies, pixels, and analytics tools like Google Analytics.

d. Customer-Provided Data

Who: Our business customers who use our analytics platform.

What: Data uploaded or processed through our Services, which may include personal data about your customers or employees, as instructed by you.

How Collected: Provided by customers through integrations or uploads to our platform. We process this data as a "data processor" under your instructions, as outlined in our Data Processing Agreement (DPA).

3. How We Use Your Personal Data

We use personal data for the following purposes, based on lawful bases under applicable data protection laws:

If consent is required under applicable law (e.g., for marketing emails in certain jurisdictions), we will obtain it before processing your data. You may withdraw consent at any time by contacting us at contact@velocent.co.

4. Data Sharing and Disclosure

We may share personal data in the following circumstances:

• Service Providers: We work with trusted third parties (e.g., cloud hosting, payment processors, analytics providers) to deliver our Services. These providers are contractually obligated to protect your data and only use it for specified purposes.
• Business Partners: We may share limited data (e.g., contact details) with partners for co-marketing or event purposes, with your consent where required.
• Third-Party Integrations: If you connect our Services to third-party platforms (e.g., CRM or advertising tools), relevant data may be shared to enable the integration. We do not store your third-party account passwords.
• Legal Compliance: We may disclose data to comply with legal obligations, such as responding to subpoenas or regulatory requests, or to protect our rights, safety, or property.
• Corporate Transactions: In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the involved parties, subject to confidentiality agreements.

We do not sell personal data for monetary consideration. However, under laws like the CCPA, certain data sharing (e.g., with analytics providers for targeted advertising) may be considered a "sale" or "sharing." See Section 8 for opt-out options.

5. Data Storage and Transfers

Personal data is stored and processed primarily in the United Kingdom and the United States, with additional processing in other jurisdictions as needed to provide our Services. We ensure compliance with data protection laws through:

• Data Protection Agreements: For transfers from the EU, UK, or Switzerland to countries without an adequacy decision, we use Standard Contractual Clauses (SCCs) approved by the European Commission, UK ICO, or Swiss FDPIC.
• Data Privacy Framework (DPF): Velocent Analytics Ltd. complies with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF. We have certified our adherence to the DPF Principles for data transferred from the EU, UK, and Switzerland. Visit https://www.dataprivacyframework.gov/ for more details.

If you have questions about our data transfer practices, contact us at contact@velocent.co.

6. Data Retention

We retain personal data only as long as necessary to fulfill the purposes outlined in this Privacy Notice, comply with legal obligations, or resolve disputes. Retention periods depend on the data's nature, purpose, and legal requirements. For example:

• Business contact data is retained for the duration of our business relationship.
• Usage data may be retained for analytics purposes, anonymized where possible.
• Customer-provided data is retained as instructed by our customers or as required by law.

You may request deletion of your data (see Section 7). We may retain certain data if required by law or for legitimate business purposes.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request details about the personal data we hold about you.
• Correction: Request correction of inaccurate data.
• Deletion: Request deletion of your data, subject to legal exceptions.
• Restriction: Request restriction of data processing in certain cases.
• Portability: Request a copy of your data in a machine-readable format.
• Object: Object to processing based on legitimate interests or for direct marketing.
• Opt-Out of Sale/Sharing: Opt out of data sharing for targeted advertising (see Section 8).
• Non-Discrimination: Receive equal services and pricing regardless of exercising your rights.

To exercise these rights, contact us at contact@velocent.co or through our website's live chat. We may require verification of your identity to process your request. For DPF-related complaints, you may contact JAMS, our dispute resolution provider, at no cost. Visit https://www.jamsadr.com/ for more information.

8. Cookies and Tracking Technologies

We use cookies, pixels, and similar technologies to enhance your experience, analyze usage, and deliver targeted advertising. For details, see our Cookie Policy (available on our website).

You can manage cookie preferences via your browser settings or our "Your Privacy Choices" widget (available on velocent.co, depending on your location). You may also opt out of targeted advertising by enabling Global Privacy Control (GPC) on your browser. Note that disabling cookies may affect the functionality of our Services.

We use Google Analytics to track user behavior. To opt out, visit https://tools.google.com/dlpage/gaoptout.

9. Data Controller and Processor Roles

• Data Controller: Velocent is the data controller for Prospect Data and certain User Data processed for our own purposes (e.g., marketing, analytics).
• Data Processor: For Customer-Provided Data, we act as a data processor, processing data on behalf of our customers (the data controllers) under their instructions and our Data Processing Agreement.

Our customers are responsible for ensuring compliance with applicable laws when using our Services, including providing notice and obtaining consent where required.

10. Opt-Out of Sale/Sharing for Targeted Advertising

Under laws like the CCPA, sharing data with third-party analytics or advertising partners may be considered a "sale" or "sharing." In the past 12 months, we may have shared identifiers, internet activity, and geolocation data for analytics and advertising purposes. We do not knowingly sell or share data of individuals under 16.

To opt out:

• Use the "Your Privacy Choices" widget on our website to select "Do Not Sell or Share My Personal Information."
• Enable Global Privacy Control (GPC) in your browser.

11. Additional Information

• Updates: We may update this Privacy Notice periodically. Significant changes will be communicated via our website or email. Continued use of our Services after updates constitutes acceptance, unless consent is required by law.
• Third-Party Links: Our Services may link to third-party websites. We are not responsible for their privacy practices. Review their policies before sharing data.
• Children: Our Services are not intended for minors. We do not knowingly collect data from individuals under 16. Contact us if you believe we have such data.
• Data Protection Officer: Our DPO can be reached at contact@velocent.co.

12. Contact Us

For questions, concerns, or to exercise your rights, contact: