There are two types of information we may collect through your use of the Services:
- “Personal Information,” which is the type of information that specifically identifies you personally and/or can be used alone to contact you online or offline, such as your full name, email address, telephone number, photographs, precise geolocation information, gender identity, date of birth, sexual preference, credit card information and, in some cases, user names; and
- “Non-personal Information,” which is information that does not identify you and cannot be used to contact you personally, including information about you such as your date of birth, ZIP code, non-precise geolocation information (e.g., your city), and gender, as well as information about your computer and mobile device, such as your unique device ID, Internet Protocol (IP) address, or other persistent identifiers, and their hardware/software/firmware. Non-personal Information also includes “Usage Data,” which is anonymous data tied to your computer and/or device, such as the actions you take within and outside of the Services, the browser and/or device you use, the date and time of your use of the Services, particular preferences you have chosen, and the URLs you visited and/or apps you used before and after using our Services.
Personal Information, Non-personal Information and Other Information That We Collect and How We Collect It
- If you choose to open an account with us, request support, or in any other way take steps that require the submission of Personal Information or Non-personal Information, we may collect information such as your name, email address, phone number, date of birth, and/or gender.
- If you choose to connect to our Services through a third-party social network such as Facebook, we may collect Personal Information and Non-personal Information from your profile on such third-party social networks, such as your name, username, e-mail address, photograph, gender, date of birth, and time zone.
- If you choose to make use of any chat or discovery function, in order to provide such functionality, we will collect such communications, including any Personal Information you may disclose through such means.
- If you choose to submit your Personal Information to us for any other reason in any other form (e.g., customer service requests), we will collect such Personal Information and use it for the purposes for which you submitted it.
- You will be given the option to upload your contacts through the Service in order to invite any of your contacts to participate in the Services. If you send or accept any invitations to connect through the Services, whether or not you have established an account with us, the other user may have access to your e-mail address or mobile phone number because it may be displayed in the invitation or acceptance.
- From time to time, we may offer you the opportunity to participate in surveys or questionnaires seeking information or opinions from you. Your participation is completely voluntary. If you choose to participate, we will collect certain Personal Information from you such as your name and e-mail and, in certain cases, responses may allow you to submit additional Information.
- We will only collect Personal Information if you choose to submit it to us. However, we, or third party analytics services on our behalf, may collect Non-personal Information such as device IDs, IP addresses and other persistent identifiers, as well as Usage Data, whenever you use our Services. Such Non-personal Information is not combined with Personal Information unless you choose to submit Personal Information to us.
Use of the Personal Information That We Collect
We will use your Personal Information to:
- provide you with the services or functionality you have requested, including the ability to meet new people, play decks with other users and facilitate communication with other users;
- respond to any inquiries you have made through our customer service features;
- enhance the App and verify our Users. Registration Information such as your name, age, images and username may be visible to the public on your profile page. If you decide to add more information to your profile such as a bio or career and school information this will also be visible to users.
Use of the Non-personal Information That We Collect
Non-personal Information may be used by us for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Non-personal Information to:
- track your use of our Services to help us learn more about your preferences and tendencies so that we can personalize your experience, provide you with notifications that are tailored to you, and otherwise enhance your experience;
- personalize your content;
- respond to customer service inquiries;
- protect against crime or fraud, or for other security reasons;
Disclosure of the Personal Information and Non-personal Information That We Collect
- Except as described herein, we will not sell, rent or transfer your Personal Information to unaffiliated third parties outside of the Services without your prior consent. We will, of course, share any information you choose to communicate to another user in order to facilitate such user-to-user communication. We may also share your Information with affiliated companies under common control as necessary for us to provide you with the Services.
- In order to provide certain aspects of our Services, we may be required to share your Information, including Personal Information, with third parties with whom we have contracted to assist us in providing such Services. In addition, Non-Personal Information in aggregated, anonymous form may be shared with third parties who assist us with our internal operations such as administration, analytics, research, strategy and optimization. The third parties we contract with for the foregoing purposes (“Service Providers”) will be authorized to use such Information only for the purposes for which the party was engaged; however, please understand that the storage and use of your Information by such Service Providers is not in our control.
- Our Services may offer social sharing features such as “Share” or “Like” on Facebook or other third party social networking sites. If you decide to use such features, it may allow the sharing and collection of Personal Information and Non-personal Information both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information collection practices.
- In connection with any sale of our company or any line of business (including the assets relating thereto), customer information generally is one of the transferred business assets, and such customer information (including your Personal Information) will be transferred or sold to the acquirer in the event of any such sale or disposition of any or all of our business.
- At any time, including after previously agreeing to allow such disclosure, you may opt out of our disclosure of your Personal Information to third parties for direct marketing purposes by contacting us at firstname.lastname@example.org and including “Opt Out of Disclosure for Direct Marketing” in the subject line.
A Special Note about Sharing Sensitive Information
As part of the Services, you may have the ability to send comments to another user of our Services that may be of a personal nature which will be linked to you personally. While Velvet will never share your comments or photos outside of the Services without your consent, we cannot control the actions of our users. Therefore, you should consider only sending personal content to a user you know and trust.
We encourage and recommend all users to think carefully about the information you disclose about yourself. We do not recommend that users put email addresses, contact information, drivers license details, or any other sensitive information on your profile which is open to abuse and misuse. Please also be careful about posting sensitive details about yourself on your public profile such as health details and religious beliefs.
When you post information about yourself or use the chat function, the amount of personal information you share is at your own risk. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account.
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at email@example.com. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.
If you wish to opt out of further communications from us, or if you wish to review, delete and/or revise the Personal Information we have stored about you, please contact us with your specific request at firstname.lastname@example.org; provided, however, that we reserve the right to retain an archive of such Personal Information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.
You can decline to permit cookies or other tracking technologies, but in that case we cannot promise you that all features will function properly as a result.
If you use the Services, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account. If you believe that someone has access to your Velvet account or social media account, please change your password immediately and contact us if further action is desired.
Partnerships and External Sources
Children & Minors
The Services are available to users who are 18 years of age and older and we do not knowingly collect or use any Personal Information from minors under the age of 18. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Information, please contact us at email@example.com.
Velvet does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their Registration Information from Velvet. If we do delete a profile because you violated our minor rules, we may retain your email and IP address to ensure that you do not try to circumvent our rules by creating a new profile.
The paid portion of services are available to users who are 18 years of age and older and we do not knowingly collect or use any Personal Information from minors under the age of 18. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Information, please contact us at firstname.lastname@example.org.
If you are a California resident under the age of 18, and a registered user of our Services, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted by deleting your account in totality. To make such a request, please send an email with a detailed rationale for deletion to email@example.com and include “CA Removal Request” in the subject line. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
We and/or our third-party partners have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security, and correctly use the Personal Information collected through the Services. We take, or obligate applicable third parties to take, reasonable precautions to protect our customers’ Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. We cannot ensure or warrant the security of any information you transmit to us by email and you do so at your own risk.
Your California Privacy Rights
Under certain circumstances, California Civil Code Section 1798.83 requires that, upon receipt of a request by a California customer, a business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or that give customers a free mechanism to opt out of having their personal information disclosed to third parties for their direct marketing purposes. California users may request further information about our approach to this law by writing to us at firstname.lastname@example.org, using the subject line “CA Request for Information,” and requesting further information.
California Do Not Track Disclosures: because we respect your privacy, we will abide by any “do not track” technology that you may choose to utilize, although, as described above with cookies, such technology may negatively affect the functionality of the Services.