Privacy Notice

Date Updated: 10/1/19

Introduction

Velocity Global is committed to maintaining your trust by protecting your personal data. This Privacy Notice explains how we collect, use, share and protect personal data.  It also describes the choices available to you regarding the use of your personal data.   For purposes of this Privacy Notice, the terms “Velocity Global, “we”, “us” and “our” shall refer to Velocity Global, LLC and its domestic and international subsidiaries.  As you review this Privacy Notice, keep in mind that it applies to all Velocity Global services that do not have a separate privacy policy or that link to this Privacy Notice, which we call the “Services.”

Velocity Global is committed to ensuring that your privacy is protected, and to the extent possible by Velocity Global, that your personal data is secure.  Velocity Global shall process your personal data in a transparent and lawful way.  Any personal data you provide when using our website located at velocityglobal.com and any other website operated by us, including from which you are accessing this Privacy Policy (each a “Site”) and our Services will only be used in accordance with this Privacy Notice.  Please read this Privacy Notice carefully to understand our policies regarding your personal data.  If you do not agree with this Privacy Notice, your choice is to not use our Site and Services.   You are responsible for ensuring we have an up-to-date, active and deliverable email address for you and for periodically visiting our Site for changes and updates.

What is Personal Data?

For individuals covered by the General Data Protection Regulation (GDPR), personal data is any information relating to an identified or identifiable natural person. For individuals not covered by GDPR, Velocity Global defines personal data as data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, government issued identification information, education information, payroll information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

Information That We Collect

Velocity Global processes your personal data to ensure the efficiency and effectiveness of our Services and products, particularly with regard to the following services, each an example of a Service:

  • International Professional Employer Organization (PEO)
  • Global Talent Acquisition
  • Global Immigration
  • Global Payroll
  • Global Consulting Services
  • Entity Setup and Support

Unless otherwise required, we do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, biometric data in order to uniquely identify a person or data concerning health or sex life and sexual orientation.

How We May Collect Personal Data

We are a US based company and all data flows back to a centralized database, managed by Velocity Global, which is located in the United States.  We and our service providers may collect personal data in a variety of ways, including:

  • Through the Services: We may collect personal data through the performance of the Services.
  • Offline: We may collect personal data from you offline, such as when you contact customer service or attend our events.
  • From Other Sources: We may receive your personal data from other sources, such as public databases, joint marketing partners, marketing subcontracts, social media platforms and from other third parties.

Data You Provide To Us

We collect and use the personal data you provide directly to us.  This data is collected in various online and physical forms and throughout our business relationship.

General and International PEO
Contact Data
Financial/Billing Data
Unique Personal Identifiers
Demographic Data
Medical for health benefits only

Global Talent Acquisition        
In addition to the above
Education
Previous Employment
Social Networking Data

Global Immigration
In addition to the above
Immigration Data

Global Payroll
In addition to the above
Payroll Data

Global Consulting Services
This type of engagement is tailored to your needs so the data collected can vary greatly.   If we collect personal data during these engagements we will use proper collection and use methods.

Other Ways You Provide Data to Us
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

When you download an e-book, checklist or other content from either our Site or another social media platform, we will collect your name and e-mail address, as well as any other content included in form, which may include FIrst Name, Last Name, Business Email, Phone Number, Company Name, Job Function, and Company Headquarters Location, in order to send you materials relating to such content.

When you participate in one of our surveys, we may collect additional profile information.

We may also collect personal data at other points in our Site that state that personal data is being collected.

We do not process the following types of data
User generated data (photos, music, text)
Legal data
Data on or about children

Data We Collect Automatically

Velocity Global and our service providers automatically collect information about you when you access our Site.  Here are examples of the ways we collection information automatically.

Tracking Technologies

Cookies  are small amounts of data that are stored in separate files within your computer’s Internet browser. Cookies are accessed and recorded by the web-sites you visit, and by the companies that show advertisements on these web sites, so that they can recognize the same browser.  For more information regarding cookies, please see our cookie policy below.

Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed.

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this application, to prepare reports on its activities and share them with other Google services.  Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Google AdWords conversion tracking is an analytics service provided by Google that connects data from the Google AdWords advertising network with actions performed on this Application.

To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

Cookie Policy

Our Site uses cookies to distinguish you from other users of our Site. A cookie is a small file of letters and numbers that we will put on your computer if you agree. This helps us provide you with a good experience when you browse our Site, and also allows us to improve our Site and Services.

We use cookies:

  • which are essential to make our Site work; and
  • help us to improve it by giving us some insight into how the Site is being used.

We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.  Persistent cookies can be removed by following Internet browser help file directions.

By clicking on “Accept” on the cookie banner, you agree that we can place cookies on your computer or device. If you do not consent, you may continue to use our Site, but it may not function correctly. You may withdraw your consent at any time by using your browser settings to delete your cookies.

Use Of Data

Marketing

We collect and use personal data to ensure we provide you with informative and timely sales and marketing material.

  • Some information is collected for Velocity Global’s internal use and to improve our operations. Some of this information is collected with legitimate interest. We will obtain consent from users before collecting any information that we do not have a legitimate interest to collect and process.
  • When you download an e-book, checklist or other content from either our Site or another social media platform, the download is part of a series of information and it is in our legitimate interest to provide you with additional emails and marketing materials pertaining to the downloaded materials so that you have the most accurate and up to date information. If you choose not to continue to receive such information, we make it very easy for you to opt-out of these emails.
  • If you register for one of our webinars, we may share your personal data with the co-presenter(s) of the webinar as stated in the registration form of the webinar.
  • In some cases, we use sub-processors to process your personal data.
  • We also use an outside third party to combine the data that we collect from you with publically available industry standard data such as the following: industry, sub-industry, revenue information, primary SIC, primary NAICS, employee count, annual sales.
External Employees

During our engagements, we collect personal data so that we fulfil our obligations of the Services.

  • The personal data we collect during the onboarding process for the External Employees (EE) is used to fulfil the contractual obligations of the services for which the EE applied.
  • Any personal data collected to assist with the immigration process is obtained as necessary to fulfil contractual and legal obligations.
  • The payroll data collected is used to comply with all tax and legal obligations and is processed directly by Velocity Global or through a sub-processor.
  • When you apply for an EE position with us, we will keep your resume on file because we have a legitimate interest in being able to help you find the perfect position.
  • We may transfer your personal data to third party employment and HR support parties who serve as a sub-process to Velocity Global.
Clients
  • As a client, we collect from you your company information, contact information plus the manager, supervisor, and approver information.
  • Additional information collected by us is used to provide a service to both the Clients and the EEs. We are the conduit which ties them together and jointly have a contractual and legitimate interest in this information.
Business Development
  • We use some data based on our legitimate interest for revenue forecasting and to enhance our services capabilities.

Communication

We contact you by the email that you have on file with us.  We send transactional emails to individuals with whom we have a business relationship; these are emails regarding our services and you may not opt-out of these emails.  These types of emails provide information to you about any changes that we make that will affect you.   We send marketing emails which contain promotional material about our services and you may opt-out of these emails.  These emails provide valuable information about how we can better serve you or new features that can help you.  If there is a concern regarding your personal data, we will contact you when required to do so by law. To do this, we will use the email address on file for you.

If for any reason you think there is a problem, please let us know by either contacting your Account Manager or by email Privacy@VelocityGlobal.com.

Third Party Sharing

General Sharing

We may share information internally within our family of companies or with third parties for purposes described in this policy. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this policy. We utilize standard contract clauses approved by the European Commission, adopt other means under European Union law, and ensure there is a legal basis to process the personal data to legitimize data transfers from the EEA to the United States and other countries.

Sub Processors

We transfer information to vendors, service providers, and other partners who globally support our business, such as providing technical infrastructure services, analyzing how our Services are used, measuring the effectiveness of ads and services, providing customer service, facilitating payments, or conducting academic research and surveys. These partners must adhere to strict confidentiality obligations in a way that is consistent with this Privacy Notice and the agreements we enter into with them.  Here are examples of some of the ways we use sub processors to process your personal data.

  • We use third party Software-as-a-Service (SaaS) and other vendors to help us process personal data.
  • We use third party email hosting services to send email.
  • We use third party customer relationship management tools to help with management of business related data.
  • We use third party billing and credit card merchant systems to process payments.
  • We use third party ticketing and help systems to support our customers.
  • We use third parties in certain instances for payroll support services.

We make no promises regarding the policies or business practices of other third-party websites and encourage you to familiarize yourself with their privacy policies before providing them with your personal data.

  • We may disclose your personal data to our agents or sub processes for the purposes identified above. In such cases, the agent or sub processors will be obligated to use that personal data in accordance with the terms of this Privacy Notice.
  • We will not sell, distribute or lease your personal data to third parties unless we have your permission or are required by law to do so.
  • We may disclose your personal data without your permission to the extent that it is required to do so by United States, European Union or National law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.

Data Subject Rights – Your Choice

Access to Personal Data

If we receive a Data Subject Request from an individual whose data we process on behalf of another party, we will inform them of such a request and work with both the third party and the individual to complete the request.

After we’ve confirmed your relationship with us and have the proper authorization, we will provide you with information about whether we hold any of your personal data. You have the right to access the personal data we have about you and you may request that it be corrected, amended, not processed, or deleted by following the directions in this Subject Access Request Policy by emailing Privacy@VelocityGlobal.com with the subject of Access Request.  We require all our requests to be in writing.  We will respond to your access request within a reasonable time, under 30 days. We may require additional information from you to allow us to confirm your identity or find your personal data.

If you believe that any personal data we are holding on you is incorrect, incomplete or shouldn’t be processed, please contact us as soon as possible, at the contact information below and we will promptly take the appropriate action.

You have the right to withdraw your consent for any marketing or sales material.  To do this, please sending an email to marketing@VelocityGlobal.com.

Profiling

We will not use your personal data for decisions based solely on automated processing if the decision produces legal effects concerning you or significantly affects you, unless you gave your explicit consent for this processing.

Security

We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical and organizational measures to safeguard and secure the personal data we process.  No system is 100% secure and your personal data cannot be guaranteed.  You must ensure you protect your username and password and do not share it with others.  If, despite all our efforts, a data breach does occur, we shall do everything in our power to limit the damage. In case of a data breach which is likely to result in a high risk, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage. We always inform the relevant data controller, supervisory authority or authorities without undue delay.

Data Retention

We will not store your personal data longer than necessary for the purpose for which we have processed your personal data including our legal requirements to retain data after completion of the Services. How long we retain your personal data depends on the type of data, the purpose for which we process it and the laws governing such data.

Changes To Our Privacy Notice

It is our policy to post any changes we make to our Privacy Notice on this page.  In some cases, we provide additional notice of changes.  If we make material changes to how we treat your personal data, we will notify you by email to the email address specified in your account and/or through a notice in the application or on the Site.  The date the Privacy Notice was last revised is listed at the top of this page.  The effective date of this statement is 10/01/2019.  Velocity Global may change this statement from time to time by updating this page.

Complaints

If you have a complaint with how we have handled a SAR please let us know and we will try to fix it.  You can email the Data Protection Officer (DPO) at Privacy@VelocityGlobal.com or by calling +1 (303) 309-2894.

If you are dissatisfied with Velocity Global ’s handling of any privacy complaints, if you do not receive timely acknowledgement of your complaint, or your complaint is not satisfactorily addressed please contact the Information Commissioner’s Office in England at https://ico.org.uk/concerns/

Special Notification for California Residents
Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one (1) request each year by emailing us at privacy@velocityglobal.com or writing us at:

Marketing Department
3858 Walnut St, Suite 101
Denver, CO 80205

Such requests must include the reference Request for California Privacy Information in the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response.  This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.

Further Information

If you have any questions about this privacy notice or questions or complaints about the processing of your personal data by Velocity Global, please contact:

Controller:
Data Protection Officer
3858 Walnut St, Suite 101
Denver, CO 80205
303-309-2894
Privacy@VelocityGlobal.com