PRIVACY POLICY

Last updated: 02/05/2019

VELA TECHNOLOGY CO., LIMITED (hereinafter as “Company”, “we”, “our”, or “us”) understands the importance of protecting your privacy. This Privacy Policy (the “Agreement” or the “Policy”) explains what information of yours will be collected when you download, install, register with, access, or use this mobile application (the “Software” or “App”), and how such information will be used and shared. It also explains choices you have to control the collection, correction and/or deletion of such information. By using our Software, you consent to the Policy and to the collection, processing, disclosure and use of your information as described in this Policy.

This Policy applies only to information we collect in our App and in e-mail, text and other electronic communications sent through or in connection with our App. This Policy DOES NOT apply to information that we collect offline, information collected in other apps or websites (including third party websites you may access through the App), or information collected by any third party. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SOFTWARE AND SERVICES.

PERSONAL INFORMATION

Personal information is data that can be used to uniquely identify or contact a single person.

1.Information you give us

(1) Camera and Photos: In order to use some of the features of the App, you may voluntarily grant us the permission to access to the camera or photo album to obtain photo in your mobile device. We may collect your photos, and send them to the third party service provider to analyze the information on the photos and feedback the conclusion. For such photo, we will not use it but only save it to optimize the algorithm after the analysis. Therefore, if you don’t want us to store your photo, please do not use this feature of our App.

(2) Support Related Information. If you communicate with us via our support section or via email, we may also collect your email address, name and any information you voluntarily submitted to us in connection with such support (for example, your name, company name, and particular support query or request). Such information will only be used to provide you with support services and will not be connected with any other information collected from you on or through the Software, including, any individual User ID which automatically generate by the Software when you use the Software and Services .

Our purposes of the support related information are: (i) to take any action in case of a dispute involving you in connection with the Software and Services; (ii) to enforce the terms and conditions applicable to the Software and Services and to prevent unlawful activities and misuse thereof; (iii) to comply and satisfy any applicable law regulation, legal process or enforceable governmental request; and/or (iv) to provide you with support and handle your complaints and/or feedback.

2.Information we collect automatically

When you use the Software, for analytical, business and operational purposes , we automatically collect and store the following types of information:

(1) Technical Information. Certain technical information regarding your device, and your use of the Software and Services , including the type, name and version of operating system: (i) their interactions with the Software and Services, your configurations and settings of the Software and Services, version of the Software and Services; (ii)ISP (Internet Service Provider) , Internet protocol (IP) address, Media Access Control (MAC) address,anonymous user identifiers, device configuration and identifiers; (iii)Advertising ID (Identifier for Advertisers used in Android, such as Google advertising ID (GAID)); (iv) location; (v)Android ID;

(2) Usage Information. Certain usage related information regarding your use and interaction with your device, such as when and how you use the Software and Services, how you use your internet browser and internet search related applications, the content you visit, access and utilize; for example, offerings and advertisements that you view, use and access, how you use them and your response to them, how frequency you use them, your search queries and the time and date of your searches.

The purposes of the information that is collected automatically are: (i) to improve and customize the Software and Services; (ii) to provide you personalized content, including through the delivery of targeted interest-based advertisements from us or our partners; (iii) to maintain and improve the quality and operation of the Software and Services; (iv) to take any action in case of a dispute involving you in connection with the Software and Services; and/or (v) to enforce the terms and conditions applicable to the Software and Services and to prevent unlawful activities and misuse thereof.

NON-PERSONAL INFORMATION

Non-personal information is data in a form that does not permit direct association with any specific individual.

We may collect and use non-personal information in the following circumstances: to have a better understanding in user's behavior, solve problems in products and services, improve our products, services and advertising, we may collect non-personal information such as installed application name and package name, the data of install, frequency of use, country, equipment and channel, configuration and settings of the products and Services, ISP (Internet Service Provider), Internet protocol (IP) address, Media Access Control (MAC) address, device configuration and identifiers.

If non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

SHARING INFORMATION WITH THIRD PARTIES

We will not share any personal information that we have collected from you except for the following events:

If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of the Company’s users, its partners, or the general public). In the event the Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred.

We may share your information with certain third parties (including, without limitation, search engines, content providers, and advertising networks and platforms) that provide various services (such as advertising, marketing, analysis, content, and search) in connection with the Software and Services. We take appropriate measures to ensure that no user can be individually identified from the disclosure of such information, and we require these third parties (i) to keep the data secured, (ii) not to use the data for any other purpose other than to provide us with Services and (iii) to use the data solely in compliance with this Privacy Policy. If you want to delete any personal data which we have shared with the third parties, please contact our Data Protection Officer by email at:support@vela-tech.com.  We would try our best to notify the third party of deleting the relative personal data, but no warranty as to the deletion is made by us.

We may also share personal information and non-personally identifiable information with our subsidiaries, affiliated and parent companies but their use of such information must comply with this Privacy Policy.

PROTECTION OF PERSONAL INFORMATION

We take precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. We use firewalls, encryption technology and Network access designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for user’s information.

We also protect user’s privacy by seeking to minimize the amount of sensitive data and personal information. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

When you use some products, services, or post your comments, the personal information you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.

DATA RETENTION

We retain the information we collect as described in this Privacy Policy for as necessary for the provision of the Services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the Services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

INFORMATION MAY BE COLLECTED BY THIRD-PARTY

Certain Services may link to third party advertisements, websites, products and services (including search services) as well as additional means that are provided to you by third parties (collectively, "Third Party Content and Services"). The use of such Third Party Content and Services is subject to their privacy policies. You shall be aware that the use of the Third Party Content and Services may give these third parties the ability to access, collect, store, and/or share your information, both your personal information and non-personally identifiable information. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Content and Services and your access to any Third Party Content and Services is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Content and Services. You expressly relieve us from any and all liability arising from your use of such Third Party Content and Services. We recommended that you read the terms, conditions and privacy policies of such Third Party Content and Services before using or accessing any of them.

For providing customized advertisement, the third-party advertising companies may collection or use your personal information (not including your name, address, email address or telephone number) when you use the Software or Service.

OUR POLICY TOWARD CHILDREN

Our Services are not directed to children under 16 or other statutory minimum age according to the applicable laws and regulations in your country (the “Minimum Age”). We do not knowingly collect personal information from children under the Minimum Age. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

YOUR DATA RIGHTS

You have the right to access, modify, correct or delete any personal data which we may have collected.

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA. To exercise this right please contact our Data Protection Officer by email at: support@vela-tech.com.

NOTICES

If we are required to provide you with notice of a particular event or incident, we will send you such notice by mail, email or telephone.

TRANSFER OF DATA OUTSIDE YOUR TERRITORY

The Software and Services work over the Internet. We may store and process your information in various locations throughout the world. Where you located in the EEA, as required by law, you hereby provide us with your express consent to transfer your data to where may be outside of EEA once you use the Software and/or Services. You may withdraw your consent at any time.

PRIVACY QUESTIONS

If you have any questions or concerns about our Privacy Policy or data processing, please contact us at support@vela-tech.com. We may modify, update and publish this Privacy Policy in the Software from time to time. Please continue to play close attention to this Policy.