Veil International Privacy Statement

Last Updated January 14, 2019

This Privacy Statement explains how Veil International, Ltd. ("Veil") collects, uses, and discloses information about you through its websites, including web applications, mobile applications, and other online products and services (collectively, the "Services") or when you otherwise interact with us.

We may change this Privacy Statement from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Statement and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of Information

Information You Provide to Us

When you sign up to use the Services or participate in any interactive features of the Services, we may ask you to provide certain information such as your Digital Wallet information, your name, your mailing address, date of birth, and your email. We also collect information about you when you fill out a form, participate in promotional, incentive, or other platform program, make a purchase, apply for a job, communicate with us via third-party social media sites, request customer support or otherwise communicate with us, or any other information you choose to provide to us. In some instances, we may request that you provide a copy of your passport or government-issued ID. For purposes of this Privacy Statement, "Digital Wallet" means an application or software that a Trading Member or Trading Member applicant uses to secure their private keys and send blockchain transactions. "Trading Member" means a person that Veil has approved to trade directly without intermediation by a third-party broker on the Veil Platform. "Veil Platform" means the Veil International decentralized exchange platform.

Additionally, when you apply for access to Veil and its Services, you may be required to provide certain personal information for purposes of know-your-customer, prevention of potential money laundering activities, or other compliance purposes. In addition, we will verify your ownership of the email address you provided and will ask you to submit a cryptographic signature using your Ethereum private key, which we will use to verify your ownership of the Ethereum Address you provide to us. "Ethereum Address" means the unique public key cryptocurrency identifier that points to an Ethereum-compatible wallet to which Ether may be sent or stored.

Automatically Collected Information

When you access or use our Services, we automatically collect information about you, including:

  • Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see "Your Choices" below.

Information We Collect from Other Sources

We may obtain information from other sources, including third parties, and combine that with information we collect through our Services.

Use of Information

We use the information we collect to provide, maintain, and improve our services. We may also use the information we collect to:

  • Confirm or re-confirm your identity and/or User ID;
  • Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
  • Communicate with you about products, services, offers, and events offered by Veil and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Veil and others;
  • Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests; and
  • Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Statement:

  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with our Rulebook, user agreements, or policies, or to protect the rights, property and safety of Veil or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among Veil and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Veil and others to, among other things, analyze and track data, determine the popularity of certain content, Services or products, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit https://www.aboutads.info/choices (or http://www.youronlinechoices.eu if you are a resident of the European Economia Area).

Security

Veil takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Data Retention

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal or regulatory obligations.

Transfer of Information to Other Countries

Veil is based in the Cayman Islands and we process and store information in the Cayman Islands and other jurisdictions. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

Residents of the European Economic Area

If you are a resident of the European Economic Area ("EEA"), you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing orders, payments, and providing any other Veil services you have requested).
  • We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
  • You have consented to the processing of your personal data for one or more specific purposes.

Data Subject Requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can contact us as indicated below.

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: https://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Your Choices

Account Information

You may update, correct or delete information about you at any time by emailing us at hello@veil.co. You may also update certain information, such as your email address and username, using the settings section of the application. Please note that we may retain cached or archived copies of information about you for a certain period of time.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications

You may opt out of receiving promotional communications from Veil by following the instructions in those communications or by emailing us at hello@veil.co. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Contact Us

If you have any questions about this Privacy Statement, please contact us at: hello@veil.co.