Privacy Policy
Last Modified: 12/17/2019
Introduction
Welcome to Velocity REOs, Inc.’s (
"Company," "we," "us," or “our”) Privacy Policy.
Company respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit www.bpophotoflow.com (the "Web site"), whether as a guest or a registered user, and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how Company collects and processes your personal data through your use of this Web site, including any data you may provide when you sign up for an account.
The Web site is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Controller
Velocity REOS is the controller and responsible for your personal data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
Velocity REOs, Inc.
P.O. Box 110425
Lakewood Ranch, FL 34211
Or you may message us by using contact form:
Contact Us
Changes to the Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review and we may revise and update this Privacy Policy from time to time in our sole discretion.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
The Web site may include links to third-party web sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party web sites and are not responsible for their privacy statements. When you leave our web site, we encourage you to read the Privacy Policy of every web site you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, and date of birth.
- Contact Data includes billing address, email address, and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Web site or App.
- Profile Dataincludesyour username and password, preferences, feedback, and survey responses regarding our platform.
- Communications Data includes your communication preferences.
We do not collect any
Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel an account or service you have with us but we will notify you if this is the case at the time.
Financial Data
Financial Data includes bank account and payment card details. We do not collect any Financial Data about you. All payments are conducted through Stripe and Company does not retain any of this information.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- create an account on our Web site;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our Web site, we will automatically collect Technical Data about your equipment. We collect this data by using cookies and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- analytics providers such as Google Analytics;
- search information providers such as Google.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer |
(a) Identity
(b) Contact
|
Performance of a contract with you |
To process your account and provide services:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us |
(a) Identity
(b) Contact
(c) Transaction
(d) Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or Privacy Policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|
| To enable you to complete a survey |
(a) Identity
(b) Contact
(c) Profile
(d) Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|
| To administer and protect our business and this web site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
| To deliver relevant web site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity
(b) Contact
(c) Profile
(e) Communications
(f) Technical
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Web site, our App, products/services, marketing, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our web site updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity
(b) Contact
(c) Technical
(e) Profile
(f) Communications
|
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Emails from us
You will receive communications from us if you have requested information from us, signed up for an account, or purchased a Service from us and you have not opted out of receiving these communications.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when web sites set or access cookies. If you disable or refuse cookies, please note that some parts of our Web site may become inaccessible or not function properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External Third Parties as set out in the Glossary below.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
Third parties have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. To review your legal rights, see the section below.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You may have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.