Effective Date: April 10, 2019
What Information Does Velocity Collect?
Information You Provide to Us:
We receive and store any Personal Information you knowingly provide to us—either voluntarily or as required by law.
For example, we may collect the following Personal Information when you register for a ShortHop Account and as you access or use our Services:
- full legal name,
- email address,
- mobile phone number,
- proof of identity (e.g., driver’s license, passport, or government-issued identity card),
- U.S. Social Security Number or other comparable government-issued identification number,
- date of birth,
- home address,
- bank account details and/or credit card numbers, and
- other personal, commercial and/or taxpayer or government identification information (e.g., any information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (“AML”) laws).
Information Collected Automatically
We receive and record certain types of information automatically, such as whenever you interact with or access the Services. For example, we automatically receive and record information from your browser, including your IP address, your geographic location, device type and unique device identification numbers, and technical data collected through cookies (as discussed below), pixel tags and other similar technologies that identify your browser.
Cookies we place on your browser or device are called “first party cookies.” Cookies set by our partners or other third parties are called “third party cookies.” Cookies set by third parties can recognize your device when you visit the ShortHop website, as well as certain other websites or mobile applications.
Cookies can either be “session cookies” or “persistent cookies.” Session cookies are temporary: they stay on your device only while you are visiting our website or accessing our Services. “Persistent cookies”stay on your browsing device until they expire or are deleted.
We—and our affiliates and/or service providers—use the following types of cookies:
- Essential Cookies: Essential cookies allow you to navigate and use certain features of our Services. For example, certain essential cookies enable you to access secure areas of our Services. Without these cookies, some Services may be unavailable to you.
- Functional Cookies: Functional cookies allow us to record your choices and settings regarding our Services. These cookies help us personalize our content for you, greet you by name, and remember your preferences.
- Performance/Analytics Cookies: Performance/analytical cookies allow us to understand how you use our Services and website. For example, these cookies register information about the number of visitors to the website, the most frequently-viewed pages on our website and the length of time users view particular pages on our site.
If you choose to prevent or limit your device’s acceptance of cookies on your browser or device, you may not be able to use or access all of our Services. If you do not consent to the placing of cookies on your device, do not access or use our Services.
We may also collect information from publicly available sources. We do not link information obtained from Cookies to other personal information.
Information Collected From Other Sources
We work closely with third parties, including SynapseFI and the USD Custodian, who may provide certain Personal Information to us, such as:
- basic personal information (e.g., name and address) from the banks you use to transfer money, public databases, credit bureaus or our business partners;
- other personal, commercial and/or identification information (e.g., information we, in our sole discretion, deem necessary to comply with our legal obligations under various AML laws) from business partners who may use a combination of government records and other publicly available information to verify your identity; and
- your financial information (e.g., your bank account details) from the banks you use to transfer money to us.
Credit reference agencies do not provide us with any personal information about you but may be used to corroborate the information you have provided to us.
How Does Velocity Use My Personal Information?
Velocity primarily uses Personal Information to customize, develop, operate, and improve our Services, including by implementing preferences requested by our users.
We also use Personal Information gathered from our users to:
- Verify your identity and allow you to activate a ShortHop Account;
- Protect us and our proprietary materials, including the Content;
- Enhance security for our users, including by monitoring and verifying user identity as well as combatting malware, viruses or other security risks;
- Comply with applicable laws requiring us to collect certain Personal Information, including AML laws;
- Contact you and allow other users to contact you;
- Analyze your use of the Services, including to personalize content based on your usage patterns; and
- for other legitimate business purposes;
Velocity may share your information with its broker-dealer affiliate in order to facilitate the opening of a digital securities transactional account at your request.
In certain cases, we may share some Personal Information with third parties, but only as described below.
Why Is Velocity Permitted to Process My Personal Data?
We rely on the following bases to process your Personal Information:
Performance of a contract: We may need to collect and use your Personal Information to enter into an agreement with you or to perform an agreement that you have with us. When we process Personal Information on behalf of third parties, we do so in performance of agreements with such third parties.
When and With Whom Does Velocity Share My Personal Information?
Velocity may share your Personal Information with third parties who have a legitimate purpose for accessing it. We will never sell, rent or otherwise profit from your Personal Information.
We will share your information in the following circumstances:
Service Providers: We employ other companies and people to assist with parts of our business operations and perform tasks on our behalf. Where necessary, we will share your Personal Information with these service providers in order to deliver the Services to you. For example, we may provide your Personal Information to identity verification services to perform KYC and AML checks and to prevent fraud; to the custodian who provides services for and access to the Digital Asset Wallet; to bill collection, marketing, and technology services; or to financial institutions or payment processing companies to receive and process your payment information or credit card transactions.
Specifically, we provide certain Personal Information to SynapseFI in order to allow you to open a ShortHop Account. However, our contract with SynapseFI requires that it only uses your Personal Information in connection with the services they perform and for compliance with applicable law and regulation, and prohibits it from disclosing, using or selling your Personal Information except with its partner financial institution.
Unless we tell you differently, our service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
Change of Control/Transfer of Assets: If we engage in any potential business transaction, including selling our assets, we may disclose your Personal Information in an anonymized form in connection with the evaluation of such transactions. In the event of a merger, acquisition, or other corporate combination, or if we go out of business or enter bankruptcy, we may transfer or sell Personal Information to a third party. We will provide notice to you prior to any transfer of your data to another company or person through a change of control or other corporate combination.
As Required By Law: We reserve the right to access, read, preserve, and disclose any PersonalInformation to comply with law or court order, including to verify your identity, prevent and detect fraud and crime, conduct or cooperate in investigations of fraud or other illegal activity, enforce or apply our Terms, or protect the rights, property, or safety of Velocity, our employees, our users, or others.
In Anonymized Form: Velocity may use your Personal Information to create aggregated and anonymized data about our Services or the user thereof and provide such information to our partners. In anonymizing your Personal Information or aggregating usage information, we will ensure you are not identifiable as an individual.
How Does Velocity Protect My Personal Information?
Velocity takes the security of your Personal Information seriously and has implemented reasonable and commercially viable administrative, physical and technical security measures to help ensure that PersonalInformation is not lost, abused, altered or open to unauthorized use and/or disclosure. We cannot guarantee that all transmission of data over the Internet or through a blockchain network is completely secure or error-free.
Your use of and transactions in Digital Assets through our Services may not be completely anonymous and may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis and, when blockchain data is correlated to other available Personal Information, certain Personal Information, including private financial information, may be revealed. Because blockchains are decentralized or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data from such networks.
We cannot guarantee complete security of the Personal Information we hold in our records. For that reason, you acknowledge and agree that you are responsible for safeguarding, protecting—and preventing unauthorized access to—your Personal Information and your ShortHop Account. You agree to protect the password for, and any other security information related to, your ShortHop Account, to limit access to the computer(s) or device(s) you use to access the Services, and to sign out of your ShortHop Account after you have completed accessing the Services. We will not be liable for privacy violations that arise from your errors or negligent use of the Services or for processes and networks that we do not control and for unauthorized access to information by those who have gained access through unlawful means.
If you suspect that your Personal Information or your ShortHop Account has been compromised, immediately contact Velocity Customer Support at email@example.com.
What Are My Rights Relating to My Personal Information?
It is your right not to disclose Personal Information to us. However, where you fail to provide Personal Information required by law or otherwise required to open a ShortHop Account, we may not be able to register you to use or access the Services or may terminate your ShortHop Account. You have the right, through your ShortHop Account, to access and view certain Personal Information you provided to us, including your name and password, your email address, your transaction history and information relating to your use of the Services.
In addition, you have the right to determine whether we hold accurate and current Personal Information about you, to request a copy of the Personal Information we hold about you pursuant to applicable law, and to update your Personal Information. Note, however, that we may maintain a copy of the priorPersonal Information in our records.
You have the right to request that we delete certain Personal Information about you or that we delete your ShortHop Account by contacting Velocity Customer Support at firstname.lastname@example.org. Pursuant to applicable laws, including those relating to the BSA and AML, we may retain certain information about you even after you request that we delete your Personal Information or terminate your ShortHop Account.
In certain circumstances, you have the right to receive the Personal Information you have provided to us in an electronic format and to request that we transmit that Personal Information to another data controller.
Disclosures for California Users
California Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to email@example.com with “California Privacy Rights” in the subject line.You may also call us at 844-888-4089.
California Right to Object: If you are a California resident, to the extent provided under California law, you may object in writing to the sale or other sharing of your personal information, and we will refrain from doing so without an economic impact on you, except to the extent, if any, that our inability to make use of your data impacts the economic value of our business relationship.
How Long Does Velocity Keep My Personal Information?
We retain the Personal Information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods.
Privacy of Minors
Velocity does not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, do NOT attempt to access or use the Services and do NOT send any Personal Information to us. If we learn that we have collected Personal Information from a person under age 18, we will delete and/or destroy that information as quickly as reasonably possible and close any ShortHop Account associated with it. If you know that a person under the age of 18 is using our Services or provided Personal Information to us, please contact Velocity Customer Support at firstname.lastname@example.org.
Links to Other Sites
Velocity may include links to third party sites on the ShortHop website or when you are accessing the Services. The inclusion of any link does not imply that we endorse the products and services offered at such linked site. These third party sites have separate and independent privacy policies which we encourage you to review. We therefore have no responsibility or liability for the content and activities of these linked sites.