Effective date: March 1, 2025
At Vaero, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of Vaero's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Vaero website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
Privacy Policy Table of Contents
What this Privacy Policy Covers
Personal Data
- Categories of Personal Data We Collect
- Our Commercial or Business Purposes for Collecting Personal Data
- Other Permitted Purposes for Processing Personal Data
- Categories of Sources of Personal Data
How We Disclose Your Personal Data
Tracking Tools, Advertising and Opt-Out
Data Security
Personal Data of Children
California Resident Rights (“CCPA”)
Colorado Resident Rights (“CPA”)
Connecticut Resident Rights (“CTDPA”)
Montana Resident Rights (“MCDPA”)
Oregon Resident Rights (“OCPA”)
Virginia Resident Rights (“VCDPA”)
Exercising Your Rights under the State Privacy Laws
Other State Law Privacy Rights
European Union, United Kingdom, and Swiss Data Subject Rights
Contact Information
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Category of Personal Data (and Examples)
Business or Commercial Purpose(s) for Collection
Categories of Third Parties With Whom We Disclose this Personal Data
Profile or Contact Data such as first and last name, email, username and phone number.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
· Parties You Authorize, Access or Authenticate
Payment Data such as financial account information, full number of payment card, billing address, billing phone number and billing email.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers (specifically our payment processing partner, currently Stripe, Inc.)
Device/IP Data such as IP address, device ID, domain server and type of device/operating system/browser used to access the Services.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
Web Analytics such as web page interactions, referring webpage/source through which you accessed the Services, non-identifiable request IDs and statistics associated with the interaction between device or browser and the Services.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
Social Network Data such as email, phone number, user name and device ID.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
· Parties You Authorize, Access or Authenticate
Consumer Demographic Data such as age and/or date of birth, zip code and gender.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
Geolocation Data such as IP-address-based location information.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
Inferences Drawn From Other Personal Data Collected such as attributes, user behavior, and predispositions.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, and texts you send us.
· Providing, Customizing and Improving the Services
· Marketing the Services
· Corresponding with You
· Service Providers
Our Commercial or Business Purposes for Collecting Personal Data
· Providing, Customizing and Improving the Services
o Creating and managing your account or other user profiles.
o Processing orders or other transactions; billing.
o Providing you with the products, services or information you request.
o Meeting or fulfilling the reason you provided the information to us.
o Providing support and assistance for the Services.
o Improving the Services, including testing, research, internal analytics and product development.
o Personalizing the Services, website content and communications based on your preferences.
o Doing fraud protection, security and debugging.
o Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), the Colorado Privacy Act (the “CPA”), the Connecticut Data Privacy Act (the “CTDPA”), the Montana Consumer Data Privacy Act (“MCDPA”), the Oregon Consumer Privacy Act (“OCPA”), or the Virginia Consumer Data Protection Act (the “VCDPA”) (collectively, the “State Privacy Laws”).
· Marketing the Services
o Marketing and selling the Services.
· Corresponding with You
o Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Vaero or the Services.
o Sending emails and other communications according to your preferences.
Other Permitted Purposes for Processing Personal Data
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Vaero or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
· You
o When you provide such information directly to us.
§ When you create an account or use our interactive tools and Services.
§ When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
§ When you send us an email or otherwise contact us.
o When you use the Services and such information is collected automatically.
§ Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
§ If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
· Third Parties
o Third-Party Credentials
§ If you provide your third-party account credentials, such as your social network account credentials, to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
How We Use Your Google User Data
We collect your email address and personal information when you sign up or log in with Google. You may connect and import data from Gmail and/or Google Drive. If you connect and import data from Gmail and/or Google Drive, the data that you import is used by us for personalized AI model training and to develop, improve, and provide the Services. Gmail and Google Drive are trademarks of Google LLC.
How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.
Tracking Tools, Advertising, and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
· Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
· Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
· You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Session Replay Technology
We may use session replay technology in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology. If you would like to change your settings with respect to session replay technology, you can access your Cookie management settings by clicking.
Information about Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
· We retain your profile information and credentials for as long as you have an account with us.
· We retain your payment data for as long as we need to process your purchase or subscription.
· We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at hello@vaero.co.
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@vaero.co.
Access
You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information in the past 12 months:
· The categories of Personal Data that we have collected about you.
· The categories of sources from which that Personal Data was collected.
· The business or commercial purpose for collecting or selling your Personal Data.
· The categories of third parties with whom we have shared your Personal Data.
· The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You may request the above information beyond the 12-month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Personal Data Sales and Shares Opt-Out
We do not currently sell or share your Personal Data as defined under the CCPA.
To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.
Limit the Use of Sensitive Personal Information
Consumers have certain rights over the processing of their Sensitive Personal Information. However, we do not collect Sensitive Personal Information.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Colorado Resident Rights
If you are a Colorado resident, you have the rights set forth under the Colorado Privacy Act (“CPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Colorado resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@vaero.co.
Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access and request a copy of your Personal Data in a machine-readable format, to the extent technically feasible, twice within a calendar year.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Deletion
You have the right to delete Personal Data concerning you.
Personal Data Sales and Targeted Advertising Opt-Out
We do not currently sell or share your Personal Data as defined under the CPA.
We do not sell or process for the purposes of targeted advertising the Personal Data of minors under 13 years of age.
Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the CPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements. ‘Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the CPA that concern you.
Consent or “Opt-in” Required and How to Withdraw
We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, 2) Personal Data from a known child under 13 years of age, 3) to sell, or process Personal Data for Targeted Advertising or Profiling after you exercise your right to opt-out, or 4) Personal Data for Secondary Use.
If you would like to withdraw your consent, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.
We Will Not Discriminate Against You
We will not process your personal data in violation of state and federal laws that prohibit unlawful discrimination against consumers.
Connecticut Resident Rights
If you are a Connecticut resident, you have the rights set forth under the Connecticut Data Privacy Act (“CTDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Connecticut resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@vaero.co.
Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Deletion
You have the right to delete Personal Data you have provided to us or we have obtained about you.
Portability
You have the right to request a copy of your Personal Data that is processed automatically in a machine-readable format, to the extent technically feasible.
Personal Data Sales and Targeted Advertising Opt-Out
We do not currently sell or share your Personal Data as defined under the CTDPA.
We do not sell or process for the purposes of targeted advertising the Personal Data of minors under 13 years of age.
Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ as defined under the CTDPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Consent or “Opt-in” Required and How to Withdraw
We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, 2) Sensitive Data from a known child under 13 years of age, or 3) to sell, or process Personal Data for Targeted Advertising, if you are at least 13 years old but younger than 16 years old.
However, we currently do not collect or process Personal data as described above.
We Will Not Discriminate Against You for Exercising Your Rights Under the CTDPA
We will not discriminate against you for exercising your rights under the CTDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CTDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CTDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Montana Resident Rights
If you are a Montana resident, you have the rights set forth under the Montana Consumer Data Privacy Act (“MCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Montana resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@vaero.co.
Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
Deletion
You have the right to delete Personal Data you have provided to us or we have obtained about you.
Personal Data Sales and Targeted Advertising Opt-Out
We do not currently sell or share your Personal Data as defined under the MCDPA.
We do not sell or process for the purposes of targeted advertising the Personal Data of minors under 13 years of age.
Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the MCDPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic circumstances, health, personal preferences, interests, reliability, behavior, location or movements. ‘Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the MCDPA that concern you.
Consent or “Opt-in” Required and How to Withdraw
We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, 2) Sensitive Data from a known child under 13 years of age, or 3) to sell, or process Personal Data for Targeted Advertising or Profiling of a consumer age 13 to 15 years old.
However, we currently do not collect or process Personal data as described above.
We Will Not Discriminate Against You for Exercising Your Rights Under the MCDPA
We will not discriminate against you for exercising your rights under the MCDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the MCDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the MCDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Oregon Resident Rights
If you are an Oregon resident, you have the rights set forth under the Oregon Consumer Privacy Act (“OCPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are an Oregon resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@vaero.co.
Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access and request a copy of your Personal Data, including a list of specific third parties, other than natural persons, to which we have disclosed your Personal Data or any Personal Data, in a machine-readable format, to the extent technically feasible, twice within a calendar year.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
Deletion
You have the right to delete Personal Data you have provided to us or we have obtained about you.
Personal Data Sales and Targeted Advertising Opt-Out
We do not currently sell or share your Personal Data as defined under the OCPA.
We do not sell or process for the purposes of targeted advertising the Personal Data of minors under 13 years of age.
Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the OCPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic circumstances, health, personal preferences, interests, reliability, behavior, location or movements. ‘Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the OCPA that concern you.
Consent or “Opt-in” Required and How to Withdraw
We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, 2) Sensitive Data from a known child under 13 years of age, or 3) to sell, or process Personal Data for Targeted Advertising or Profiling of a consumer age 13 to 15 years old.
However, we currently do not collect or process Personal data as described above.
We Will Not Discriminate Against You
We will not discriminate against you for exercising your rights under the OCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the OCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the OCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Virginia Resident Rights
If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@vaero.co.
Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
Deletion
You have the right to delete Personal Data you have provided to us or we have obtained about you.
Consent or “Opt-in” Required and How to Withdraw
We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, or 2) Sensitive Data from a known child under 13 years of age.
However, we currently do not collect or process Personal data as described above.
Opt-Out of Certain Processing Activities
· Targeted Advertising: You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We process your Personal Data for targeted advertising purposes.
· Sale of Personal Data: We do not currently sell your Personal Data as defined under the VDCPA.
· Processing for Profiling Purposes: We do not currently process your Personal Data for the purposes of profiling.
To exercise any of your rights for these certain processing activities, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.
We Will Not Discriminate Against You for Exercising Your Rights Under the VCDPA
We will not discriminate against you for exercising your rights under the VCDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the VCDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the VCDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Exercising Your Rights under the State Privacy Laws
To exercise the rights described in this Privacy Policy, you or, if you are a California, Colorado, Connecticut, Montana or Oregon resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (including login information), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
Request to Opt-Out of [Sale, ]Share and/or Targeted Advertising
You may opt-out from any [“sales”, ]“shares” or targeted advertising, by using the following methods:
Request to Withdraw Consent to Certain Processing Activities
If you are a Colorado resident, you may withdraw your consent allowing us: 1) to process your Sensitive Data (including Sensitive Data Inferences), 2) to process your Personal Data if you are a known child under 13 years of age, 3) to sell, or process your Personal Data for Targeted Advertising or Profiling after you have exercised your right to opt-out, or 4) to process your Personal Data for Secondary Use, by using the following methods:
· Email us at hello@vaero.co
Request to Access, Delete, or Correct
You may submit a Valid Request for any other rights afforded to you in this Privacy Policy by using the following methods:
· Email us at: hello@vaero.co
If you are a California, Colorado, Connecticut, Montana or Oregon resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Appealing a Denial
If you are a Colorado, Connecticut, Montana, Oregon or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods:
· Email us at: hello@vaero.co (title must include “[STATE OF RESIDENCE] Appeal”)
If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Montana, Oregon and Virginia.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at hello@vaero.co.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at hello@vaero.co with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
European Union and United Kingdom Data Subject Rights
EU and UK Residents
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Vaero will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at hello@vaero.co. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
· Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
o Profile or Contact Data
o Payment Data
o Device / IP Data
o Web Analytics
o Social Network Data
o Consumer Demographic Data
o Geolocation Data
o Inferences Drawn form Other Personal Data Collected
· Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
o Profile or Contact Data
o Payment Data
o Device / IP Data
o Web Analytics
o Social Network Data
o Consumer Demographic Data
o Geolocation Data
o Inferences Drawn form Other Personal Data Collected
o We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
o Providing, customizing and improving the Services.
o Marketing the Services.
o Corresponding with you.
o Meeting legal requirements and enforcing legal terms.
o Completing corporate transactions.
· Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
· Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Disclosing Personal Data
The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.
EU, UK and Swiss Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at hello@vaero.co. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Vaero and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Vaero in the U.S. and will be hosted on U.S. servers, and you authorize Vaero to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: