Privacy Policy

1. Scope and consent.

Signing up, using or having access to products, services, content, opportunities, technologies and functions offered by our website or the related websites, applications and services (hereinafter together referred to as Velespay services), you agree with provisions of this Privacy policy. The Privacy policy defines an order of use of Velespay services by our users (including but not limited to those who use Velespay services within their trading or another type of business activity) if otherwise isn't provided by the agreement. We have right to make changes to this Privacy policy by publication of its new version on our website any time at our own discretion. The new version of the Privacy policy comes into force in the day specified in its text. Besides, when making essential changes to the Policy, we will notify you on the forthcoming changes not less than in 30 days. After the 30-day period from the moment of such notification you will be considered unconditionally accepting all the changes in the Privacy policy.

2. Collection of personal data.

We collect personal data for the purpose of providing Velespay services and also to make our work more personalized and high-quality.

Automatically collected data. When you use Velespay services, we collect the data obtained from your computer, mobile phone or other device. The data we receive include the following information but not limited to: data on the web pages you visit, your IP address, your device ID, type of your device, your geolocation data, data about your computer and connection, data about mobile network, statistics of views for pages, incoming and outcoming traffic to the nodes, the URL address from which the transition to our website was made, data about advertizing and standard web log data and any other data. We also collect anonymous data via cookie files and web beacons.

Data provided to us. We can collect and store the data provided by you during the use of Velespay services, including the data specified in web forms, when you add or update your account information, participate in discussions in social networks, communicate in chats, solve the disputes and also the data received within other way of exchange of information with us concerning the use of Velespay services.

We collect data about your operations and actions when you use Velespay services. Besides, during creation of Velespay account or use of Velespay services we can also collect the following data:

Contact information, for example, full name, address, phone number, e-mail and also other similar information.
Financial data, for example, full bank account numbers and/or the credit cards attached to your Velespay account or provided to us when using Velespay services.
Detailed personal data, for example, date of birth or your personal ID number.

We can also collect the information about you received personally from you or from other resources, for example, during your communication with us, including communication with Customer support; from results of surveys; during interaction with Velespay group team or with other companies' staff (taking into account their privacy policies and applicable legislation) and also from other which as we have a reason to believe also belong to you (partially or completely). Besides, for quality control and training or for protection of Velespay system we can carry out monitoring or recording of all phone conversation with you or with other persons acting under your name. When communicating with us, you realize that your conversation can be listened, traced or recorded without any prior notices or warnings.

The data received from other resources. Also we can obtain information about you from the third parties, for example, the credit bureau or personality identification organizations.

You can provide us with access to a certain personal data which is stored at the third parties' resources such as social networks (for example, Facebook or Twitter). The amount and type of data we receive depend on the particular website and are controlled by this website. When you attach your Velespay account to any other system account controlled by the third party and allowing Velespay to get access to such data, you agree that Velespay can collect, store and use this data according to provisions of this Privacy policy.

Verification and detection of fraud. To protect you from fraudulent actions and unauthorized use of your personal data, we can collect information about you and your interaction within Velespay system. We can also carry out audit of your computer, mobile phone or other device for detection of the malicious software or other activity.

Use of mobile devices. We can offer you access to Velespay services by means of our mobile application or via the mobile version of our website. Provisions of this Privacy policy are applied to all technologies you might use, including mobile devices.

When downloading or using our mobile applications or getting access to one of the mobile website versions we can collect data about your current location and your mobile device, including its unique ID. We can use the received data for provision of services taking into account location, for example, advertizing, search results and other personal content. The majority of mobile devices allow you to adjust or turn off geolocation in the device settings. If you have any questions about how to turn off tracking of your device, we recommend you to contact your mobile services operator or your device manufacturer.

You hereby provide Veles Financial Services Ltd., a system operator registered under the laws of Canada, with its location at: 319 W Hastings St, #400 Vancouver BC V6B 1H6, Canada and also to affiliates and the third parties which are carrying out identification, simplified identification or procedures and services of personal data verification, your consent to processing (collecting, recording, systematization, accumulation, storage, checking (updating and modification), extraction, use, transfer (including distribution, disclosure, granting and access provision), depersonification, access blocking, removal or destruction) of your personal data collected by us, affiliates or the third parties which are carrying out identification, simplified identification or procedures and services of personal data verification according to this Privacy policy. Hereby you confirm that you have been notified and you give your direct and unconditional consent to transfer your personal data to the foreign states territory and to the third parties as it is fully described in this Privacy policy.

3. Use of the collected personal data.

Our main goal of collecting your personal data is ensuring safe, free, effective service adjusted for each user. Your personal data can be used for the following purposes:

provision of Velespay services and customer support;
processing of operations and sending notices on operations;
personal data verification, including during the creation of an account and resetting the password;
disputes resolution, commissions collection and problems elimination;
risk management, detection, prevention and/or compensation of fraudulent situations or other potentially forbidden or illegal actions;
detection, prevention or compensation of violations of policies or applicable agreements with the user;
improvement of Velespay services by increasing the quality of working with users;
measurement of Velespay services effectiveness and improvement of their content and design;
improvement and protection of our IT infrastructure;
provision of target marketing and advertizing, notification on updates and advertizing offers based on your communicative preferences;
communication with you by any phone number via voice call or texting (SMS) or e-mail according to terms of the Agreement;
credibility and solvency verification, confirmation of data for ensuring its accuracy, reconcillation with data from the third parties.

We can contact you by means of electronic communication devices or by e-mail for notification about your account status, search and elimination of malfunctions in your account, disputes resolution, collection of commissions and money which are subject to payment, obtaining of your opinion by surveys and questionnaires or any other manner for the purpose of maintaining your account. Besides, we can contact you to offer coupons, discounts and promo actions and for informing you about Velespay services and services of Velespay group companies. Also we can contact you if required for ensuring performance of our politicies, applicable legislation or other agreements which can be signed between Velespay and you. During communication with you by phone for improvement of the service quality we can use automatic calls or pre-recorded calls and text messages, and you hereby agree to receive those. Wherever it's applicable and authorized by the legislation, you can turn off some ways of communication with you.

4. Marketing.

We don't sell and we don't provide your personal data to the third parties for use in the marketing purposes without your obvious consent. For optimization and personalisation of Velespay services content and advertizing we can put your data together with information we get from other companies.

5.Use of cookie files and similar technologies.

When you visit our website or use Velespay services, we (including our partners) can place small files of data on your computer or other device. It can be cookie files, pixel tags, flash-cookie or other types of files supported by your browser or the accompanying applications (hereinafter together referred to as cookie files). We use these technologies for recognizing you as a client; for personalisation of Velespay services, content and advertizing; for estimation of advertizing efficiency; for security of your account; for decrease in risks and fraud prevention and also for building confidence and safety of our websites and Velespay services.

You have the right to refuse to use cookie files if your browser or its settings allow to do that, except for cases of obligatory use of cookie files for fraud prevention or security of the websites controlled by us. However, you have to take into account that refusal of cookie files use can prevent you from using our websites and Velespay services.

6. Protection and storage of personal data.

In provisions of this Privacy policy the term "personal data" is used for description of information connected with a particular person and allowing to identify this person. We don't consider personal data the information obtained from anonymous resources as it doesn't allow to identify any particular user.

Your personal data is stored and processed on the company's computers located in Russia, North America, Asia, Europe and any other country. Measures of physical, technical and administrative character aimed at prevention of loss, misuse, unauthorized access, privacy violation and change of the personal data are used to protect your data. Security measures include network firewalls and data encryption, control over physical access to our personal data center and also over access rights to personal data.

7. Provision of personal data to other Velespay users.

When you're making operations with other users, we can provide to these parties any information necessary for carrying out such operations, for example, your first and last name, account ID, contact data, invoicing address or other data necessary to ensure reliability and safety of each operation. If any operation is blocked, refused or recognized as invalid, we can also provide information on the operation that has been cancelled. To help with disputes resolution we can provide the buyer with the seller's address for return of the purchased goods. In this case the receipient isn't allowed to use this information in any purposes not connected with the particular operation, for example for direct marketing on your address if you haven't agree to that in an obvious form. Communication with users in order to provide them with undesirable or menacing content is contradicting to our politicies and makes violation of our user agreement.

When user sends funds and enters his e-mail or phone number we can provide to the sending party the recepient's first and last name specified during the creation of an account to confirm that he sends funds for the right person.

We work with the third parties, including sellers, to give them an opportunity to accept and send payments to you via Velespay. For this purpose the third party can provide us with information about you, for example, your e-mail or phone number, for sending to you notices about the payment or about attempt to pay for goods or services to the third party or seller. We use this information to confirm that you are Velespay user and that Velespay can be used for payment or for notification on the status of transaction. Besides, we will send to the third party confirmation of your Velespay user if we receive the corresponding request.

If you attach your card or gift coupon of any Velespay seller to the account, then we can transmit him the number of your card when you pay via Velespay.

You also have to take into account that sellers and users from whom you buy goods or whom you communicate with might have their own privacy policy. In spite of the fact that the user agreement forbids other party to use this information for any purposes other than Velespay services provison, we won't bear responsibility for their actions, including their information protection methods.

In any case, we undertake not to give your credit card number bank account number to other party of payment in Velespay system or to the third parties offering or using Velespay services except for cases when you obviously agree to that or when we are forced to make it for observance of instructions of credit cards usage, in the presence of court order or when taking other measures within the legal proceedings.

8. Provision of personal data to other parties.

We can provide your personal data to the following parties:

To the companies members of Velespay group which can produce a collaborative content, products and services (for example, registration, operations and customer support) to help in detection and prevention of potentially illegal actions and violations of our politicies, and for sending some suggestions about or products, services and communications. The companies from Velespay group can use this information to send you marketing messages only after receiving the corresponding request from you.
To financial institutions which we cooperate with for collaboration in production and promotion of the product (including Velespay card in which case we transfer information to define whether you can receive special offers on use of the Velespay card). Such financial institutions can use this information only for selling the products connected with Velespay except for cases when you have agreed to other way to use such information.
To credit bureaus and collection agencies for obtaining data on the account according to the applicable legislation.
To bank partners according to the rules of credit cards attachment which can use such information for replenishment of the cancelled sellers list (in case if you correspond to their criteria including closing of Velespay account for violation of the user agreement).
To the companies which we plan to make deal with for merge, accession, division, separation. (In such cases we will demand from the new legal entity to comply with provisions of this Privacy policy concerning your personal data. In case of threat of violation of provisions of this Policy when using your personal data you will receive the prior notice).
To law enforcement agencies and other government authorities or other parties according to the court order, court solution or other judicial process or requirement applicable to Velespay company or one of its affiliates if we are forced to make it for compliance to legislation or policy of the financial organization or if we believe (at our own discretion) that transfer of personal data is necessary for prevention of physical or financial losses, for informing on suspicion concerning illegal activity or for investigation of violations of the user agreement.
To owners of intellectual property rights, if according to their national legislation of the EU member country, they have claims to Velespay due to indisputable disclosure of information by means of Velespay services, which led to violation of their intellectual property rights (for example, but not limited to, part 19 paragraph 2 item 3 of the Law on trademarks of Germany or part 101 paragraph 2 item 3 of the Law on trademarks of Germany).
To other not affiliated third parties for:
- Fraud prevention of and risk management: for prevention of fraudulent actions and risk assessment and management. For example, if you use Velespay services for salling or purchase of goods on auctions, or other platforms, or its affiliates, we can transfer data about your account to protect your account from fraudulent actions, to notify you on tracking of such actions by your account or to estimate the financial risk.
  Within our efforts on fraud counter and risk management we can also transfer necessary data about your account to auctions and other platforms in cases of blocking of Velespay funds or other restrictions put on your account due to disputes, claims, returns or in other cases during the purchase and selling of goods. Within the actions of fraud counter and risk management we can also transfer necessary data about your account to auctions and other platforms to allow them to operate their programs for buyers and sellers audit.
- Customer service: for customer service, including maintaining accounts and disputes resolution (for example, billing or operations).
- Delivery: in connection with delivery and other services connected to shopping with use of Velespay system.
- Compliance to legal requirements: ensuring compliance to requirements for counter to money laundering and terrorist financing.
- To service providers: to let service providers to provide services under the contract of commercial activity support of the company, for example, actions for fraud prevention, accounts collection, marketing, customer service and technological services. According to terms in the contracts with such service providers, they can use your data only to provide corresponding services to us, but not for their own benefit.
To other third parties with your consent or by your instruction.

Note that these third parties can be located in other countries which laws on personal data processing can be less strict, than in your country. To provide services to Velespay, some information which we collect (as it was specified in Section 2) can be transfered to other companies from Velespay group or the third companies, including those those specified in Section 6 as payment services providers, payment operators and account owners (or connected with similar activity). Hereby you confirm that you have been notified and you give your direct and unconditional consent that to such companies laws, provisions, inquiries, investigations or others orders can be applied in accordance to local legislation which force them to provide information to the corresponding authorities of such country. Using Velespay services you confirm your consent to transfer such information so that we could provide Velespay services to you.

When creating the Velespay account on the third-party website or via an outside application, information your specify on the corresponding website or application (not directly on Velespay websites), will be provided to the owner of such third-party website or application. Such websites are guided by their own privacy policy which we recommend you to study before giving away your personal data. Velespay doesn't bear responsibility for content placed by the third parties or the principles of data use they apply.

9. Cross-border transfer of personal data.

Velespay company takes a serious view of protection of your personal data irrespective of where is it located, and also of providing appropriate protection of your personal data when it's transfered abroad, including outside of the European Economic Area.

10. Use of the Enter via Velespay option.

Enter via Velespay is an option developed for our users' convenience. Enter via Velespay allows to improve and simplify the process of account creation and login when using third-party websites and also allows you to receive the maximum advantage of use of such websites. Instead of using individual login and password for each website you visit, Enter via Velespay allows to sign in on the websites included in the program with use of the authorization data you specified for Velespay. When using Enter via Velespay option, you agree that Velespay can transfer to such website information specified on the page when using Enter via Velespay option or in your account setting for Enter via Velespay option. Information which is transferred to such websites and which you have agreed to transfer, comes under the user agreement and privacy policy of the third party which you should study.

11. Access to personal data or change of personal data.

You can look through and edit your personal data in settings and profile of your account any time. You can also close your Velespay account. In case of closing Velespay account we will change your account tage as closed in our database, but still we reserve the right to store your personal data from your account during the certain period of time for debts collection, disputes resolution, problems elimination, assistance to any sort of investigations, fraud prevention, ensuring compliance with provisions of the user agreement and also to carry out other actions as it's provided or allowed by legislation.