Veea Inc. (including its affiliates and subsidiaries)(collectively, “Veea”) is strongly committed to protecting your personal data and information in accordance with applicable laws and regulations including the General Data Protection Regulation (“GDPR”) (EU 2016/679) and its implementing laws), and laws such as the California Consumer Privacy Act and the California Privacy Rights Act (Cal. Civ. Code §§ 1798.100 – 1798.199 and its implementing regulations as and when finalized).  We value your privacy and desire to ensure that your experience with Veea Inc. and all of our websites and related or associated subdomains (the “Sites”) and all of our products, including VeeaPOS^™, vCube^™ and VeeaHub^™ and associated services (collectively “Products”), mobile applications, including Veea^â, VeeaConnect^™ (collectively, the “Apps”), and services including our VeeaPay^™ payment services, Veea Cloud Management, VeeaHub app store, blogs, forums, channels and sharing services (collectively with the Sites and Apps, the “Services”) are satisfying and safe (the Products, Apps and Services may be referred to herein collectively, as “Products”).  In that regard, Veea have established for the Sites and Products the following Privacy Policy to explain and describe what personal information is collected on our Sites and Products, how we use it and your options regarding information we may collect about you. By accepting this Privacy Policy, you expressly consent to the information handling practices described in this Policy. This Privacy Policy is a part of and incorporated into Veea’s Terms of Use associated with our Sites and Products. In addition, by accepting this Privacy Policy you expressly represent that you are over the age of 18 or are not considered a minor in the jurisdiction for which you reside. Your continued use of Veea’s Sites and Products or any other content, products, or other services covered by this Policy constitutes your acceptance and agreement to this Policy and any updates.

1. What information do we gather?

When you access our Sites and Products, we may collect Personal Information, as well as non-personally identifiable information using various means including ‘cookies’ (described further below), server logs, pixel tags, web beacons, and similar technologies. “Personal Information,” as used in this Policy, is personally identifiable information, which is information that directly identifies or can be used to identify an individual, including first name/initial and last name, mailing address, email address, telephone number, IP address, social security number, passport number, driver’s license. We may also collect financial information such as such as bank account, payment card numbers, credit reports, and other publicly available information.  Further, when you our Services to make, accept, request or record payments, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions. We may also collection information about products and services you sell (including inventory, pricing and other data) and other information you provide about you or your business.  We may also collect dates, times and location of access to our physical facilities, and Site access information such as page access, time spent on page, feature use and website flow and usage pattern information, login data, browser type, browser plug-ins, MAC Address, mobile unique device ID, operating system and devices used.  Finally, we may collect information that is provided by you including your name, employer’s name, work address, email address and telephone number.

We collect Personal Information and other information in two ways. First, we collect Personal Information and other information you provide to us in optional, voluntary submissions, such as in registration or application forms, go through our identity or account verification process, authenticate into your account, purchase our products, create user profiles, sign up for promotional signups, sweepstakes/contest entries, requests for customer service, software and mobile applications downloads. Second, some information may be collected automatically. This is described below.

We may also obtain information, including Personal Information, from third party sources such as, information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources. Also, top the extent permitted by applicable laws, we may obtain background check reports from public records of criminal convictions and arrest records. We may use your information, including your full name, government-issued identification number, and date of birth, to obtain such reports. We also may obtain information formation about you from third parties in connection with any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

If we directly combine information provided by third parties with Personal Information that we have collected, then we will treat the combined information as Personal Information and handle it in accordance with this Policy. In addition, please note that we may solicit third parties to collect Personal Information on our behalf and in such cases.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests.

Veea does not require that you accept cookies, and you may withdraw your consent to our use of cookies at any time by adjusting your browser’s privacy settings, however, some functionality on our Sites (e.g., “functionality cookies”), our product or service check-out process, and Services may be disabled if you decline to accept cookies ( e.g., “necessary cookies”).

Veea does not require that you provide any personal information.  Giving Veea some personal information may be necessary if you would like Veea to contact you, provide you with additional information on Veea Products or enable you to authenticate your identify when accessing certain Products.

Veea does not give away Personal Information about our users. If you choose to provide Personal Information and other information about yourself, we will use this information only to communicate directly with you and as otherwise expressly stated in this Policy. Veea will not sell, rent or otherwise disclose that information to third parties unless that disclosure is necessary for the purposes set forth in this Policy, by law or a policy or notice contained or associated with a specific Site(s) and Service(s).  For purposes of the GDPR, Article 6, Veea relies on multiple legal grounds for processing personal information:  (i) the need to fulfill a contract with you if you are a customer or potential customer of Veea Products, (ii) the fulfillment of a legitimate interest including security, system management,  service improvements, marketing, etc., (iii) when we are complying with a legal or regulatory obligations, or (iv) where we have your specific consent (e.g. when applying for Products).

We may collect, use, and share (with Veea partners, service providers and licensees) precise location data, including the real-time geographic location of your mobile or fixed location device. Where available, location-based services may use GPS, Bluetooth, and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by us and our partners and licensees to provide and improve location-based products and services.  We may use information, including Personal Information, in conjunction with geo-location data to provide you with personalized location-based products and services or location-based offers, products and services we believe would be of interest to you.

In order to provide certain Services, we may require access to location information, including precise geolocation information collected from your device. If you do not consent to collection of this information, certain Services will not function properly, and you will not be able to use those Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications will no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove all Veea mobile applications from your device.

We use analytics tools and other third party technologies, such as Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our online Sites and Products.

The third-party analytics companies who collect information on our Sites and Products and other online products and services may combine the information collected with other information they have independently collected from other websites and other online or mobile products and services relating to your activities across their network of websites as well as online and mobile products and services. Many of these companies collect and use information under their own privacy policies.

In addition to our use of technologies as described herein, we may permit certain third-party companies to help us tailor advertising that we think may be of interest to you based on your use of Veea Sites and Products and to otherwise collect and use data about your use of Veea Sites and Products.

2. How do we use this information?

Generally, we use information, including Personal Information, to establish and enhance our relationship with our users through four main categories: (1) Communication; (2) Optimization; (3) Advertising; and (4) Sharing Features. Below, we provide some examples of how we use the information we collect, including Personal Information.

Communication and Responding to Requests

We use your information, including Personal Information to provide you with customer support, process transactions, respond to users’ requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and promote Veea Sites and Products, as well as products and services of our partners and licensees.

Optimization

We use your information, including Personal Information, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our Sites and Products, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.

Advertising

We use your information, including Personal Information, behavioral metrics, geo-location data, demographic data and marketing preferences to personalize, display and transmit advertisements, promotions and other content to you and to process contest, sweepstake, or other promotion entries and fulfill any related award.  We also use information to market our Services by communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners.  If we send you marketing emails, each email will contain instructions permitting you to “opt out” of receiving future marketing or other communications.

Sharing Features

We use your information, including Personal Information and any other information you submit directly or through passive means to provide you with various ways to communicate and share content (e.g., web content, user generated content, text, drawings, media, tools, services and other products) with third parties. For example, we may provide you with the opportunity to email a link to certain content to another person. To use this feature, we may require you to provide certain Personal Information including your email address and the email address of each person to whom you send the link.

We also may allow you to share links to content with users of various third party services (e.g., social networking, search and sharing services). When sharing links using one of these third-party services, if you are not already logged in to the third-party service, you will need to supply login credentials for it. If you are not a registered user of the third-party service, you will need to sign up for it. You are supplying the registration information or login credentials for the third-party service directly to that third party, and not to us. By using any of these third-party services to share links to content, you permit us to access, use and disclose any information relating to your account on each third-party service (such as your username and profile information) that is available to us through the third-party service, including through its application programming interface (API) pursuant to this Policy.

3. Will we disclose your Personal Information to third parties?

We do not disclose Personal Information with third parties except in the limited circumstances described in this Policy. We are interested in maintaining your privacy and creating a valuable resource for you to use.

Service Providers

We may provide Personal Information to service providers so that they may perform services on our behalf, such as internal business functions (e.g., payment processing, customer service, maintenance, security, data analysis, email transmission, beta testing, or data hosting).  Additionally, some third-party service providers may collect information, including Personal Information, on our behalf. Whenever possible, we require third-parties to only collect and use Personal Information in accordance with this Policy, to maintain the confidentiality, security, and integrity of Personal Information, and for no purpose other than providing us with our requested services.

Partners

When you visit or use a part of any website, mobile application, or other consumer product that is co-branded or that is a part of or relates to a joint promotion involving Veea and one or more third parties (each a “Co-Branded Party”), unless stated otherwise in connection with the joint promotion, you are providing and consenting to provide and are transmitting your Personal Information and other information provided to, or collected, or obtained by Veea and any Co-Branded Parties involved, to Veea and each of the Co-Branded Parties without any other notice or further consent. Please note that we may not control any Co-Branded Parties’ use or treatment of information you provide to them and you should consult each of their privacy policies or any separate Co-Branded privacy policy posted on or linked from the Co-Branded site to determine your rights with respect to their use and treatment of your information. You will need to communicate with us and each Co-Branded Party directly, as applicable, if you decide you no longer wish to receive communications or if you wish to change any information you have supplied.

Legal Requirements

We may disclose your information, including Personal Information, if we have a good-faith belief that doing so is required by a subpoena, warrant, or other judicial or administrative order or otherwise required by law. Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of our Terms of Use; take precautions against liability; protect our rights, property, or safety, or those of a partner, any individual or the general public; maintain and protect the security and integrity of our Sites and Products or infrastructure; protect ourselves and our Sites and Products from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government regulatory agencies.

Change of Ownership

Information about our users, including Personal Information, may be disclosed as part of any actual or potential bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction. If a transaction occurs in which your Personal Information would be transferred to a third party, we will make reasonable efforts to notify you. For example, we will post a notice of the transfer of Personal Information on our Sites and Products and, if we have your email address, we will send notice of the transfer of Personal Information to that email address.

Interactive Features

If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through any of our Sites and Products, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any.  Therefore, you should avoid posting any personal information within such an interactive feature. To request removal of your personal information from our blog, sharing service or community forum, for example, contact us as provided for in this Policy. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

4. How is your Personal Information secured by us?

Your information is stored on secure web servers that are protected against unauthorized access by third parties through reasonable methods. However, while we take efforts to ensure the integrity and security of our network and systems, we cannot absolutely guarantee that our security measures will prevent third-party “hackers” or other malfeasants from illegally obtaining this information.

Commercially reasonable physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your Personal Information, for example, encryption (SSL) of all information you send us when requesting a quotation online and user access controls designed to ensure that your Personal Information is accessible only by our designated employees and only for purposes intended by the submitter of the information. To protect the security of information exchanged with you, you will be provided with usernames and passwords to access your information. All information that is exchanged while accessing your customer specific portion of our website is encrypted.

We may permit users with accounts on certain third party services, including but not limited to, social networking, search, sharing, and other services delivered by third-parties, to bypass the standard applicable registration process. If you connect through an authorized third-party service, you will be able to use your third-party login information to log in to your Veea account or access Veea content, Sites and Products. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third-party services that may be triggered by using these third-party login services. Please review their terms of service and privacy policies carefully before using third party login functionality to access any Veea Sites and Products.

By using any third-party services to log in to your Veea account or access Veea Sites and Products, you permit us to access, store and use all information related to your third-party account that may be accessible to us through the third-party service, including through its application programming interface (API), pursuant to this Policy.

The length of time Veea may store your information may vary depending on our use of your Personal Information.  Unless otherwise required by law, Veea will not maintain your information for longer than is reasonably necessary for the purposes for which information was collected.

5. How do we respond to Internet browser “Do Not Track” requests?

We do not treat browsers sending “Do Not Track” signals any differently than those that do not. We use affiliates to support this website. Therefore, this website may not comply with “Do Not Track” settings on your browser.

6. Can we change our Privacy Policy?

Yes, we may update or amend this Policy from time to time to reflect changes in our practices or changes in applicable law. If we do, we will update the “effective date” at the top of the Policy.  We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information. Your continued use of our Sites and Products or any other content, products or other services covered by this Policy constitutes your agreement to this Policy and any updates.

7. How do we treat information of children under 13?

The Sites and Products are not intended for children under the age of 18.  We take special care to protect the privacy needs of children under the age of 13 and encourage parents to be an active participant in their child’s online activities. We abide by the requirements of the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. Our Sites and Products do not target and are not intended for children under the age of 13, and we will not knowingly collect any personal information from them. If we discover personal data from a child under 13 is gathered through our Sites or Services, then we will eliminate that data.

8. How can you access the Personal Information you share with us?

Under certain circumstances, you may have the legal right to: (i) Request access to your Personal Information, (ii) Request correction of the Personal Information we may hold about you, (iii) Require erasure of your Personal Information, (iv) Object to the processing of your Personal Information, (v) Request that we stop processing your Personal Information, (vi) Request the transfer of your Personal Information in a structured format, and (vii) You may withdraw your consent.  If you want to review or verify information which you have provided to us you can contact us, per the contact information provided above, and we will respond to your request as soon as possible.   We may ask for information or documentation to authenticate your request.   There also may be instances where we will not be able to provide the information, we hold about you, if compliance with your request is too costly, in our determination, to retrieve or where we cannot disclose the requested information for legal reasons. If we are unable to provide you with access to your information, then we will explain why compliance is not possible, when the explanations are legally permitted. If you wish to have your Personal Information deleted, we may not be able to completely honor your request due to applicable laws and regulations and the storage of the information within third party services.

9. How can your Personal Information shared with us be kept accurate?

We take reasonable steps to maintain the accuracy of your information, including Personal Information ,for as long as it is being used for the purposes set out in this Policy and you play an active role in keeping us up-to-date. Prompt notification of any changes, for example to your mailing address or telephone number, will help us provide you with the best possible service. Should you discover, upon review of your information, that amendments are required, please advise us.

10. How do we treat information provided by customers outside of the United States?

Please note that our headquarters is located, and our website is hosted in the United States. If you are using our website from outside the United States, by providing your information to us or through the Site or Services, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this Policy and our Terms of Use. You are also consenting to the application of United States law in all matters concerning our use of your information.  We may transfer personal information to the United States only with your consent, to perform a contract with you, or pursuant to a compelling legitimate interest that does not outweigh your rights and freedoms. 

11. How do we respond to California Privacy Laws?

Certain California Privacy Laws  require that  certain businesses must  respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Your Personal Information will not be shared with third parties for their direct marketing purposes. You can contact us to request a list of the categories of information that we share with third parties and the purpose of any such sharing.  In some cases, you may request that we delete your personal information (although some exceptions apply).

12. Do we guaranty error free performance of this Policy?

Veea maintains physical, technical and administrative safeguards designed to protect the privacy of any data and Personal Information that you transmit to and through the Sites.  These safeguards include on-going testing and updating of security technology and restricting access to such information to those with a legitimate need to know.  We also train our employees on the importance of confidentiality and maintaining the privacy and security of your information.   Notwithstanding the foregoing, Veea cannot guarantee error-free performance under this Privacy Policy. Under no circumstances will Veea be liable for any information it merely transmits and does not collect from you during your use of the Products.  We will use reasonable efforts to comply with this Privacy Policy and will take prompt corrective action when we learn of any failure to comply with our Privacy Policy. Veea will not be liable for any incidental, consequential or punitive damages relating to this Privacy Policy. This Privacy Policy will be governed by the laws of the State of New York and the United States, to the extent applicable.

13.  When Veea is acting as a Data Processor for other entities:

In some cases, Veea may act as a Data Processor (as the term is defined in applicable law) for its Customers and clients who are Data Controllers (as the term is defined in applicable law as the person or entity who or that determines the purpose and means of the processing of Personal Information), for example, a Customer who is reselling Veea Products.  This Privacy and Data Processing Policy forms a part of all written or electronic agreements by and between Veea and its Customer (collectively, “Agreement”). 

Customer will only disclose Personal Information to Veea to process as necessary to perform a valid business purpose set forth in the applicable Agreement and as set forth by applicable law.  Veea shall have no liability for any claim arising from or related to Veea’s processing of Personal Information under this Policy pursuant to Customer’s instructions.

Customer hereby represents to Veea that all Personal Information provided or made available by or on behalf of Customer to Veea for processing in connection with the Agreement was collected by Customer and is transmitted to Veea in accordance with applicable law.  Customer has obtained all necessary authorizations from each data subject required under data protection law to enable Veea to process the Personal Information pursuant to the Agreement and to exercise its rights and fulfil its obligations under this Agreement. 

Unless restricted by applicable law, Veea shall inform Customer if, in Veea’s reasonable judgment, processing of Personal Information pursuant to the Agreement or Customer’s instruction conflicts or is inconsistent with Veea’s legal obligations or any data protection laws.

Veea shall provide Customer with reasonable assistance with data protection impact assessments or prior consultations with a supervisory authority (as such term is defined in GDPR) that Customer is required to carry out under any data protection laws.

Veea shall implement reasonable and appropriate administrative, physical and technical safeguards in relation to the processing of Personal Information that are intended to facilitate the ongoing confidentiality, integrity, availability and  resilience of processing systems and a procedure for regularly testing, assessing and evaluating the effectiveness of its administrative, physical and technical safeguards.

Veea shall timely notify Customer if Veea receives any valid requests or notices regarding its processing of the Personal Information.  To the extent that Veea is required to undertake an investigation or take any action relative to the processing of the Personal Information, Customer will pay Veea’s reasonable costs for any assistance unless such costs are incurred due to Veea’s material breach of its obligations under the Agreement.

Customer shall pay Veea’s reasonable costs for Veea’s assistance with an audit or inspection or other work undertaken pursuant to Veea’s obligations under this Policy unless such costs are incurred due to Veea’s material breach of its obligations under this Addendum

Upon expiration or any earlier termination of the Agreement, Veea shall, as set forth in the Agreement or upon Customer’s written request, delete or return to Customer all Personal Information in Veea’s possession; provided, however, that Veea may retain Personal Information as permitted or required to meet its obligations under applicable law. 

14. Contacting Us

If you have questions about this Privacy and Data Protection Policy, please feel free to contact us at:

Veea Inc.
164 E. 83rd Street,
New York, New York 10028
Attention: General Counsel
privacy@veea.com