Introduction

VELERA (hereinafter, "VELERA" or "we," "us," or "our"), created this privacy policy (this "Privacy Policy") to demonstrate our firm commitment to the privacy and protection of your information. This policy covers how VELERA and its subsidiaries manage information that may be used to identify you directly or indirectly ("Personal Information") that you submit, or that we collect and receive on our website at www.Velera.com, together with any other websites and mobile applications owned, operated, or controlled by us (referred to herein individually and collectively as the "Website"). We provide access to the Website and any online services (referred to herein, individually and collectively, as the "Services") to you, subject to the following conditions and other agreed-upon terms related to the relevant Services.

For the purposes of this Privacy Policy, VELERA is a controller (i.e., responsible party) for the practices described in this Privacy Policy. Additionally, this Privacy Policy does not apply to the extent we process Personal Information in the role of a processor or service provider, as applicable, on behalf of our business customers. For information about the privacy practices of a VELERA business customer (or its affiliates), please visit the respective business customer's website or contact the business customer directly. We are not responsible for the privacy or data security practices of our business customers, which may differ from those set forth in this Privacy Policy.

Our U.S. Consumer Privacy Notice describes how we share non-public personal information with our affiliates and third parties.

California Consumer Notice of Collection and Consumer Notice of Collection in US States with Comprehensive Privacy Laws (collectively, "States")

This Notice of Collection is provided to all California and U.S. States’ consumers subject to this Privacy Policy. You can access the specific topics, as follows, within this Privacy Policy:

Information Collection and Usage
Sources of Personal Information
How We Use Your Personal Information
Information Sharing and Disclosure
How We Protect Your Personal Information
Email Security
Cookies and Other Tracking Technologies
Linked Third-Party Sites
Data Retention
Rights Related to Your Personal Information
Children
Privacy Policy Changes
Contact Information

Information Collection and Usage

The types of Personal Information that we may collect depend on which of our Services you are utilizing and how you interact with us. We may collect, or have collected in the preceding twelve months, the following categories and specific types of Personal Information:

Contact Information/Identifiers, including name, email address, postal address, phone number, username, business contact information and alias.
Government Identifiers, including driver's license number, passport number and social security number (in certain instances, government identifiers may be considered sensitive Personal Information).
Information Specific to the Services, including, in certain instances, your financial account information, your username and password used to access our services, and any related questions and answers to obtain account access.
Demographic Information, including age, gender, race, ethnicity and household information, some of which may include characteristics of protected classifications under state or federal law.
Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address or similar unique identifiers.
Internet or Other Network Activity, including information regarding your interactions with our websites, mobile applications, emails or advertisements.
Geolocation Data, including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
Payment Information, including credit or debit card number, or other financial information.
Inferences, including inferences drawn from or created based on any of the information identified in this section.
Sensitive Personal Information (where permitted and in accordance with applicable law), of the information listed above, social security number and/or username and password may also constitute Sensitive Personal Information.

The provision of the Sensitive Personal Information listed above is voluntary. In certain instances, we will not be able to provide access to our Services without the requested Personal Information.

Sources of Personal Information

We may collect, or have collected in the preceding twelve months, your Personal Information in the following ways, in accordance with applicable law:

Directly From You, when you use our Services, register for an account, contact us, provide us with feedback, or sign up to receive emails, text messages and/or postal mailings.
Through Our Use of Cookies and Other Automatic Data Collection Technologies, when you visit our websites, use our mobile applications, open or click on emails we send you, or interact with our advertisements. We or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see the "Cookies and Similar Tracking Technologies" section below.
From Our Third-Party Partners, including from third parties that we have partnered with to provide you the Services that you have requested from us, such as when we work with our partners to verify information you have provided to us for your account registration or to complete transactions initiated by you.
Other Sources, including data analytics providers or publicly available sources.

How We Use Your Personal Information

We may collect, or have collected in the preceding twelve months, your Personal Information for the following purposes:

Providing Our Services

To provide you the Services, administer your account and provide you with Services requested by you.
To verify your identity, process your transactions, determine and confirm your transaction limit and send notifications to you related to your account.
To enable you to access and use our Website or Services.

Communicating With You

To communicate with you, such as to provide you with information about your account, and to respond to your requests, questions, comments and other inquiries.
To understand what partner resources you use, if any, and to connect you to additional resources at your request.
To send marketing and promotional materials, including information relating to our products, Services, sales or promotions or those of a third party.

Analytics and Administration of Website

To administer, maintain, evaluate, and improve our Website and Services, and to develop new products and Services.
To conduct research and analytics related to our Website and Services, which may include combining any or all of the information that we collect or obtain.
For other business purposes such as trouble-shooting problems, data analysis, identifying usage trends, determining the effectiveness of our Services and to enhance or customize our features, products and Services.

Core Business Functions

To manage our business operations, perform our obligations and exercise our rights under any agreement that your financial institution has with us.
For other purposes with your consent, or as otherwise permitted or required by applicable law.

Legal Obligations

We use Personal Information to comply with our legal or regulatory obligations, agreements and policies, to establish or exercise our rights and to defend against any legal claims.
To enforce our agreed-upon terms for our Services.

Security and Fraud Prevention

We use Personal Information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies and procedures, security incidents, and harm to the rights, property or safety of VELERA and our users, customers, employees, end-users or others.

Use of Your Sensitive Personal Information

With regard to Sensitive Personal Information, we only use your Sensitive Personal Information to provide you with the requested Services and to administer your account.

If you are no longer using our Services, we may continue to store and protect your Personal Information pursuant to this Privacy Policy, and as required or permitted by applicable law.

Information Sharing and Disclosure

We may disclose, or in the past twelve months have disclosed, the Personal Information described above in the following limited circumstances for business purposes:

Affiliated Companies and Financial Institutions. We may disclose Personal Information to companies that are affiliated with us (for example, companies that control, are controlled by, or are under common control with us). We may also disclose Personal Information that is collected between Websites/Services that we, or our affiliates, control. We may also disclose your Personal Information (including sensitive Personal Information) to our client financial institutions, where appropriate. The Personal Information shared with these financial institutions typically includes Personal Information to verify accounts, confirm transactions, and to coordinate and improve the Services provided to you.
Organizations that Provide Services. We may disclose your Personal Information to companies that perform services for us, such as credit, product development and data processing vendors. The information shared with these companies typically includes Personal Information to provide the Services, process transactions on your behalf, conduct our operations, follow your instructions as you authorize, and/or protect the security of our financial records. We may also disclose your Personal Information with third parties described below in the Cookies and Other Tracking Technologies section.
Business Transactions. In the event that we go through a business transition, such as a merger, if another company acquires us or our affiliates, or we sell a portion of our assets, your Personal Information may be part of the assets transferred.
Other Parties. We may disclose your Personal Information to third parties to comply with a legal obligation; to protect the legal rights of (or otherwise participate in a legal process pertaining to) our company, our employees, our agents, our clients and our affiliates; to protect the safety and security of our visitors, or to protect against fraud; or otherwise with your consent or as allowed by applicable law.
De-identified or Aggregate Information. We may aggregate and anonymize information you provide to us in such a way as to ensure it will no longer be identifiable to you. This data is generally not considered Personal Information and may be used for statistical, analytic and administrative purposes, including analyzing our Website traffic and trends, tailoring our Services, or conducting product analysis. We may share anonymized or aggregated data at our discretion, in accordance with applicable laws.

We do not sell, rent, lease or "share" (as the term is defined in applicable law) your Personal Information to third parties except if you consent to such disclosure or as described in this Privacy Policy.

We reserve the right to disclose Personal Information about you or your use of the Website/Services without your prior permission if we have a good faith belief that such action is necessary to: (i) protect and defend the rights, property or safety of us, our affiliates, other users of this Website or the public; (ii) enforce the terms for our Services; or (iii) respond to claims that any content violates any law or the rights of third parties.

Our U.S. Consumer Privacy Notice describes how we share non-public personal information with our affiliates and third parties.

How We Protect Your Personal Information

We have reasonable and appropriate technical and organizational measures in place to protect against the loss, misuse and alteration of your Personal Information under our control. We have taken reasonable steps to confirm the Personal Information is retained in secure facilities and that reasonable measures have been implemented for protection from unauthorized access. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. For instance, this Website utilizes the latest industry-standard encryption technology to protect Personal Information.

While we strive to use industry-standard means to protect your Personal Information, no method of transmission over the internet is 100% secure. We ask that you do your part by maintaining any usernames and passwords you use to access the internet or this Website as strictly confidential.

Email Security

If you received an email from us, (a) your e-mail address is either listed with us as someone who has expressly shared this address for the purpose of receiving communications from us in the future ("opt-in"), or (b) you have registered, have an existing relationship with us, or are using our Services. We respect your time and attention by controlling the frequency of our emails.

You may opt out of receiving marketing emails from us at any time by clicking the "Unsubscribe" link at the bottom of any marketing email you receive or by contacting us directly at marketing@Velera.com. To opt out of operational emails, please contact us directly at marketing@Velera.com.

Cookies and Other Tracking Technologies

When you visit our Website, our Website's web server automatically collects information, including, in some instances, Personal Information, through cookies, web beacons and other similar tracking technologies (collectively referred to throughout this Privacy Policy as "cookies"). Cookies are small text files that are placed on your computer or mobile device when you visit a website. Cookies help the website remember information about your visit, which can make it easier to visit the website again and make the website more useful to you. Some cookies are deleted once you close your browser (session cookies), while other cookies are retained even after you close your browser so that you can be recognized when you return to a website (persistent cookies).

Cookies on our Website are generally divided into the following categories:

Cookie Type	Description
Essential Cookies	These are cookies that Velera Websites needs in order to function and that enable users to move around a webpage and use the Website and features. Without these essential cookies, the Website will not perform as smoothly as intended, and Velera may not be able to provide the Website or certain services or features you request. Examples of where these cookies are used include: to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.
Advertising & Marketing Cookies	These cookies are used to deliver marketing communications and to track the effectiveness of our campaigns. Pardot (Salesforce Marketing Cloud Account Engagement): Used exclusively for processing information submitted via marketing/contact forms. No persistent cookies are set for general visitors; tracking is only initiated upon explicit user form submission. Salesforce: Used to manage prospect and client data following user-initiated contact or form submissions. Advertising and marketing cookies are only used after you provide information via forms.
Performance & Functionality Cookies	These cookies enhance the performance and functionality of our Website but are not essential for its use. However, without these cookies, certain functionalities may become unavailable. (Currently, Velera does not use additional performance cookies beyond analytics and essential scripts. If this changes, update this section accordingly.)
Analytics & Customization Cookies	Analytics cookies provide us with information regarding how visitors navigate and interact with our Website. Such cookies allow us to understand, for example, more about how many visitors we have to our Website, how many times they visit us and how many times a user viewed specific pages within our Site. Among other analytics cookies, we use Google Analytics cookies for these purposes. For more information about Google Analytics, please refer to "How Google Uses Information From Sites or Apps that Use Our Services," which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. To learn how to opt-out of Google Analytics, an Analytics cookie, please visit https://tools.google.com/dlpage/gaoptout. These cookies help us understand how visitors interact with our website and improve the user experience by collecting information such as page visits, click patterns, and engagement metrics. Google Analytics 4 (GA4): Collects aggregate website usage statistics and interaction data, with no persistent user or device identifiers. Hotjar: Provides heatmaps, scrollmaps, and anonymous feedback on how users interact with pages. Google Tag Manager: Orchestrates the loading of analytics and marketing scripts based on user consent. No persistent user profiling or cross-session interest tracking is currently used.

We may use the information collected through cookies for the following purposes:

To improve its performance.
To gather metrics about how you interact with our Website.
For security reasons.
To provide personalized content. For example, we may store user preferences, your default language, device and browser information, your profile information, which includes the level of your usage of the Website, which you visit, so we can identify you across devices and personalize the content you see.

Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this. If you disable cookies, your ability to use some features of the Website may be limited. For mobile devices, you may be able to manage certain cookies using your built-in mobile device settings and controls. Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset. You should check how to do this on your device(s) and operating systems.

Some cookie providers may also offer opportunities to control your preferences.

Some of these cookies may be placed by third-party service providers to help determine the effectiveness of our Website or email communications. The use of cookies by third-party service providers is within their control and not ours. We do not control their websites or their policies and practices regarding your Personal Information, and you should be aware that different rules might apply to the collection, use or disclosure of your Personal Information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet. This Privacy Policy does not cover any use of Personal Information that a third-party service provider may directly collect from you, and we do not undertake to confirm, investigate, or police their practices.

Linked Third-Party Sites

We may provide links to other third-party websites through the Services solely as a convenience to you. However, such linking does not mean, and should not be interpreted to mean, that VELERA endorses, is affiliated with or makes any representations concerning such third-party websites. VELERA neither reviews, controls, nor is responsible for these third-party sites or any content therein. By using such links, you will leave the Website and will no longer be accessing the Services. If you decide to access any of the third-party sites linked to the Services, you do so entirely at your own risk. VELERA shall not be liable for any consequences arising from use of any third-party websites to which the Services link.

Data Retention

How long we retain your Personal Information depends on the context in which, and purposes for which, we collected it. We generally retain Personal Information for as long as necessary for achieving the purposes for which it was collected or processed unless a different retention period is required by applicable law.

Rights Related to Your Personal Information

Depending on where you live and the types of Personal Information at issue, you may have certain rights with respect to your Personal Information. For example, under applicable state laws, including those in the California, you may have the rights listed below. Please note that many of these rights are subject to exceptions and limitations. For example, certain laws generally do not apply to Personal Information that you provide to us while acting in your professional capacity.

Right of access and data portability: You may have the right to request access to Personal Information we hold about you. Specifically, you may have the right to request access to information about the categories of Personal Information concerned and categories of recipients to whom the Personal Information has been or will be disclosed, and the sources from which we receive that Personal Information among other information. You also may have the right to receive this Personal Information, in a structured, commonly used and machine-readable format so you can transmit this Personal Information to another entity.
Right to correction: You may have the right to request that we correct or supplement any inaccurate or incomplete Personal Information we process about you.
Right to deletion: You may have the right to request that we delete your Personal Information that we collected from you or as applicable anonymize your Personal Information.
Right to opt-out of the sale or sharing of Personal Information: We do not currently, nor have we in the preceding 12 months, sold or shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising) your Personal Information. We also do not knowingly sell or share the Personal Information of individuals under the age of 16 or as required by other applicable law.
Automated Processing: Under certain circumstances, you may have the right to object to a significant decision based solely on automated processing (i.e., without human intervention) unless that decision is required or permitted by law.
Right of Non-Discrimination/Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.
Right to opt-out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). We do not disclose Sensitive Personal Information for purposes other than those which cannot be limited under applicable law.

If you choose to assert any of these rights available under applicable laws, we will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations. If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. You may be entitled to lodge a complaint with your local data protection authority or your state Attorney General's Office.

Your rights and our responses may vary based on your state of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

We may require use of your Personal Information to provide access to the Services. Therefore, when you exercise your deletion right, in particular, you may lose access to certain aspects of the Services that require your Personal Information.

Rights Request and Verification Process

Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. If you designate an authorized agent to submit a request to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. Our verification processes may vary and, for example, could require your provision of a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

Except where otherwise provided under applicable law, you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request should:

Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Our verification process may also include a request for additional information to confirm your identity or your authorized agent's identity (such as your name, email address and date of birth) or to obtain proof that you have given your authorized agent permission to act on your behalf. If our verification process is successful, we will respond to your request within the time and in the manner required by applicable law. If we cannot validate the identity of you and/or your authorized agent or obtain proof that you have given your authorized agent permission to act on your behalf, we will attempt to contact you to inform you.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We will deliver our written response by mail or electronically, at your option. However, if you do not select an option we generally will respond by email unless required by other applicable law. You still always have the option to request a written response that can be received by U.S. Mail. Any information we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the Personal Information from one entity to another entity without hindrance, such as by electronic mail communication. Further, if you would like to appeal any decision we make about your request, you may contact us as stated in the "Contact Information" section below.

To exercise these rights, please submit a verifiable consumer request to us by either:

Calling us at 844-474-7728, or

Completing the Data Subject Request Form

Children

Our Website/Services are not directed toward children under the age of thirteen, and we do not knowingly collect any Personal Information from children under the age of thirteen. If a child provided us with Personal Information, we ask that a parent or guardian send us a written request to the address listed below and we will promptly delete the child's Personal Information from our records.

Privacy Policy Changes

VELERA is always improving our Website/Services and, as these evolve, we reserve the right to update or amend this Privacy Policy at any time for any reason.

You may learn of changes to this Privacy Policy by viewing the "Last Updated" date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy and you acknowledge you will not receive specific notice of each change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of the updates.

Contact Information

If you have any questions regarding this Privacy Policy, you may contact us via the channels provided below:

Velera
4950 Amon Carter Blvd.
Fort Worth, TX 76155

1-844-474-7728
VeleraPrivacyOffice@Velera.com

Last Update Effective: January 31, 2025