INTRODUCTION
Your privacy is important to us. The policy of Velaris International Inc. is to respect your privacy and comply with all applicable laws and regulations regarding any personal information we may collect about you, including on our Platform https://lollihub.com and other related services.
Velaris International Inc. is a U.S. corporation registered in the state of Wyoming, USA, and all data processing operations are carried out in accordance with the laws of the United States of America.
Personal information is any information about you that can be used to identify you. This includes information about you as an individual (for example, name, address, and date of birth), your devices, payment details, and even information about how you use the Platform or online services.
If our Platform contains links to third-party websites and services, please note that these websites and services have their own privacy policies. By clicking on a link to any third-party content, you should read the privacy information they provide about how they collect and use personal information. This Privacy Policy does not apply to any of your actions once you leave our Platform.
TERMINOLOGY AND DEFINITIONS
The following terms are used in this Privacy Policy:
"We", "us", "our" refers to Velaris International Inc.
"Company" means Velaris International Inc., a corporation registered under the laws of the State of Wyoming, United States of America, owning and operating the Platform.
"Platform" means the website lollihub.com, mobile applications, software, systems, and related services and offerings provided by our Company.
"User" means any individual or legal entity using the Platform, including but not limited to Models, Agencies, and Subscribers.
"Personal information" means any information relating to an identified or identifiable natural person.
"Processing" means any operation or set of operations performed on personal data, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
"Services" means advertising and informational services provided through the Platform.
INFORMATION WE COLLECT
Categories of collected information
The information we collect falls into two categories: “voluntarily provided” information and “automatically collected” information.
“Voluntarily provided” information refers to any information you consciously and actively provide us when using or participating in any of our services and promotional activities.
“Automatically collected” information refers to any information automatically sent by your devices when accessing our products and services.
Personal information
We may request personal information — for example, when you register an account or contact us — which may include one or more of the following:
- Name;
- Email;
- Social media profiles;
- Date of birth;
- Phone/mobile number;
- Identity documents (for verification);
- Payment information.
Sensitive information
“Sensitive information” or “special categories of data” is a subset of personal information afforded a higher level of protection. Types of sensitive information we may collect about you include:
- Sexual orientation;
- Health information (if voluntarily provided).
We will not collect sensitive information about you without obtaining your explicit prior consent.
Log data
When you visit our Platform, our servers may automatically record standard data provided by your web browser, including:
- Your device’s Internet Protocol (IP) address;
- Browser type and version;
- Pages you visit;
- Date and time of your visit;
- Time spent on each page;
- Other details about your visit.
Device data
When you visit our Platform or interact with our services, we may automatically collect data about your device, such as:
- Device type;
- Operating system;
- Unique device identifiers;
- Device settings;
- Geolocation data.
User-generated content
We consider “user content” to be materials (text, images, and/or video content) voluntarily provided by our users for publication, processing, or use on our Platform. All user content is linked to the account or email address used to submit the materials.
Important to remember: any content you submit for publication will become publicly available after publication (and any subsequent review or moderation). After publication, it may be:
- Copied by third parties;
- Reposted on other resources;
- Indexed by search engines (e.g., Google, Bing, etc.);
- Stored in web archives and third-party caches;
- Saved as screenshots or mirrors by third parties.
We cannot guarantee complete removal of such content from all external sources if it is distributed by third parties.
Transaction data
Transaction data are data accumulated during normal operation of our Platform, including:
- Transaction records;
- Stored files;
- User profiles;
- Analytics data;
- Other metrics of user interaction with our services.
DATA PROCESSING AND LOCATION
Server location
Your personal data is processed and stored on servers located in the United States of America. We use trusted cloud service providers and data centers that meet high security standards and comply with applicable data protection laws.
Third-party data processors
We may use third-party service providers to process your personal data on our behalf. All our service providers are companies registered in the USA or have appropriate certifications to work with U.S. companies.
The third parties we currently use include:
- PostHog – for analytics and user behavior tracking;
- Stripe – for payment processing;
- SendGrid – for sending email notifications;
- MailChimp – for email marketing;
- Google Analytics – for web traffic analysis;
- Other technical service providers necessary for Platform operation.
All third-party data processors are contractually bound to protect your personal data and may use it only to provide services on our behalf according to U.S. data protection standards.
International data transfers
The personal information we collect is processed in the United States of America or where we, our partners, affiliates, and third-party providers have facilities.
The countries where we store, process, or transfer your personal information may have different data protection laws than the country where you initially provided the information. If we transfer your personal information to third parties in other countries:
- We will perform such transfers in accordance with applicable law;
- We will protect the transferred personal information in accordance with this Privacy Policy.
USE OF COLLECTED INFORMATION
Legal basis for processing
We collect and use your personal information only when we have a legal basis for doing so. We collect only the personal information reasonably necessary to provide you with our services.
Purposes of collection and use
We may collect, store, use, and disclose information for the following purposes:
- To provide you with core features and services of our Platform;
- To enable customization or personalization of the Platform experience;
- To communicate with you;
- For analytics, market research, and business development, including Platform operation and improvement;
- For advertising and marketing, including sending promotional information about our products and services;
- To provide access to the Platform and related applications;
- To ensure security and prevent fraud;
- For technical assessment, including Platform operation and enhancement;
- To comply with legal obligations and cooperate with law enforcement.
DISCLOSURE OF INFORMATION TO THIRD PARTIES
We may disclose personal information to the following categories of recipients:
- Parent, subsidiary, or affiliated companies of our Company;
- Third-party service providers, including IT services, hosting, analytics, payment processors, marketing, and professional consultants;
- Our employees, contractors, and affiliated organizations;
- Law enforcement authorities upon lawful request;
- An entity acquiring or to which we transfer substantially all of our assets and business;
- Third parties with your consent or at your direction.
DATA SECURITY
When we collect and process personal information, we protect it using commercially acceptable means to prevent loss, theft, and unauthorized access, disclosure, copying, use, or modification.
Our security measures include:
- Encryption of data in transit and at rest;
- Access control to personal data;
- Regular security audits;
- Staff training on data protection;
- Use of secure data centers.
Important to remember: no electronic transmission or storage method is 100% secure, and no one can guarantee absolute data security. You are responsible for choosing any password and its overall strength, ensuring the security of your own information within our services.
DATA RETENTION
We retain your personal information only as long as necessary for the purposes for which it was collected or as required by law.
Standard retention periods:
- Account data: for the lifetime of your account plus 12 months after closure;
- User content: 6 months after deletion;
- Activity logs: 90 days;
- Financial records: 7 years (in accordance with legal requirements);
- Data for law enforcement purposes: according to official requests or legal requirements.
If your personal information is no longer needed for the stated purposes, we will delete or anonymize it by removing all data that identifies you.
YOUR RIGHTS AND CONTROL
General rights
Your choice: By providing us with personal information, you understand that we will collect, store, use, and disclose your personal information in accordance with this Privacy Policy. You are not required to provide personal information; however, if you do not, it may affect your ability to use the Platform.
Access: You may request detailed information about the personal information we hold about you.
Correction: If you believe any information about you is inaccurate, outdated, incomplete, or misleading, please contact us. We will take reasonable steps to correct such information.
Download personal information: We provide you with the option to download personal information you have provided via the Platform.
Opt-out: To unsubscribe from our email database or stop receiving marketing messages, use the unsubscribe options provided in the message or contact us.
Data breach notification
We will comply with applicable laws regarding any data breaches, including notifying affected users and relevant regulatory authorities within required timeframes.
USE OF COOKIES AND TRACKING
Detailed information about the use of cookies, tracking pixels, and analytics services is set out in our separate Cookie Policy, which is an integral part of this Privacy Policy and is available on our Platform.
MINORS’ PRIVACY
We do not target any of our products or services directly at users under 18 years old and do not knowingly collect personal information from users under 18. The user’s age is verified through a KYC (Know Your Customer) procedure carried out by a trusted third-party verification provider. As part of such KYC procedure, you may be required to provide identity documents and agree to transfer necessary data to this third-party provider for verification purposes.
If we become aware that we have collected personal information from a person under 18 without verifiable parental consent, we will delete such information from our files.
CHANGES TO THE POLICY
At our discretion, we may change our Privacy Policy to reflect updates to our business processes, current acceptable practices, or changes in laws or regulations.
If we decide to change this Privacy Policy, we will post the changes here at the same link through which you access this policy.
If the changes are material or required by law, we will notify you and all registered users, providing new details and links to the updated policy.
If required by law, we will obtain your consent or provide you with an option to agree or refuse any new use of your personal information.
COMPLIANCE WITH U.S. LAW
Applicable law
This Privacy Policy is governed by the laws of the State of Wyoming, United States of America, pursuant to our Terms of Use.
Compliance with CCPA (California)
Additional rights apply to California residents under the California Consumer Privacy Act (CCPA):
Categories of personal data collected in the past 12 months:
- Identifiers (name, email, IP address, account number);
- Customer records (address, payment details);
- Demographic data (age, gender);
- Commercial information (purchase history);
- Internet activity (service interactions);
- Audio/visual data (photos, videos);
- Geolocation data;
- Inferences (preference information).
Your rights under CCPA:
- Right to know: You may request information about the personal data we have collected, used, disclosed, or sold in the past 12 months;
- Right to delete: You may request deletion of your personal data;
- Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights.
To exercise these rights, contact us using the contact information below.
Cooperation with law enforcement
We cooperate with law enforcement agencies in accordance with applicable U.S. laws:
- Responding to lawful requests within required timeframes;
- Reporting suspicious activity to relevant agencies;
- Preserving data per official legal hold requests;
- Notifying users about requests unless prohibited by law.
COMPLIANCE WITH GDPR (for EU/UK users)
Legal grounds for processing
For users from the European Union and the United Kingdom, we process personal data based on the following legal grounds:
Consent: When you give us explicit consent to process your personal data for specific purposes;
Contract performance: When processing is necessary to fulfill a contract with you or to take pre-contractual steps;
Legitimate interests: When processing is necessary for our legitimate interests, provided these are not overridden by your rights and freedoms;
Legal obligations: When processing is necessary to comply with legal obligations.
Your rights under GDPR
Right of access: You have the right to receive a copy of the personal data we process about you;
Right to rectification: You have the right to request correction of inaccurate personal data;
Right to erasure: Under certain circumstances, you have the right to request deletion of your personal data;
Right to restrict processing: You have the right to request restriction of processing in certain situations;
Right to object: You have the right to object to processing based on legitimate interests;
Right to data portability: You have the right to receive your personal data in a structured, commonly used format;
Right to withdraw consent: You may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.
International transfers
Since our servers are located in the USA, your personal data will be transferred to a country that may not provide the same level of data protection as the EU/UK. We take appropriate safeguards to secure your data, including:
- Use of standard contractual clauses approved by the European Commission;
- Ensuring that recipients provide adequate data protection;
- Obtaining your explicit consent to transfers where applicable.
Complaints
If you believe we have processed your personal data improperly, you have the right to lodge a complaint with the data protection supervisory authority in your country. However, we would appreciate the opportunity to resolve your concerns directly, so please contact us first.
CONTACT INFORMATION
For exercising GDPR and CCPA rights, or any inquiries related to the privacy policy, please contact us by email at: support@lollihub.com.