Effective Date: 01 May 2023
Orbis Blockchain Technologies Limited ("VeVe", "we", "us" or "our") operates the website www.VeVe.me ("VeVe Website"), VeVe mobile app ("VeVe App") and the VeVeVerse (together, the "VeVe Services").
We are committed to ensuring the privacy and protection of your personal information. The following privacy policy describes the processing of personal information that is collected when you access and use the VeVe Services or otherwise interact with us. This policy should be read with any other VeVe terms and conditions or policy notified to you (including the Terms of Use at
www.veve.me/terms-conditions and any other applicable policies on the VeVe Website and/or VeVe App).
Personal information, or personal data, means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
When you provide information on a third-party site or platform, the personal information you provide may be separately collected by the third-party site or platform. The personal information we collect is covered by this privacy policy, and the personal information the third-party site or platform collects is subject to the third-party site or platform's privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the personal information we have collected directly through our applications. The VeVe Services may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.
PART 1: PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect the following kinds of personal data about you:
| Identity Data |
First name, last name, username, date of birth, gender, country and any other identity information you provide as part of our Know Your Customer (KYC) process which may include address, national identification number, tax identification number, drivers licence number, your passport number and other information and photos of you in the identification documents you provide to us which may comprise biometric facial recognition data. |
| Contact Data |
Email address and any other contact information you provide to us. |
| Financial Data |
Bank account and payment card details. Please note that for in-app Gem purchases we do not hold your Financial Data as payment is made either through the App Store and Google Play Store. |
| Transaction Data |
Information about Gem purchases and withdrawals and Collectible sales and purchases. |
| Profile Data |
Your username and password, sale and purchase history, the Collectibles you hold, the amount of Gems you hold, feedback and survey responses, your favourite brands, your visual image if you choose upload a photo of you into your Profile and any other personal information you include in the Bio section of your Profile. |
| Device Data |
Information from and about the device you use when you use the VeVe Services (whether your desktop, mobile, or other devices) (including enough information to determine if you are trying to fake your current location by using a VPN, VPN app with location spoofing, or other related tools) including IP address, identifiers, battery usage, device storage, MAC address, SIM information, type, mobile carrier, browser type and language, and operating system. This may include your general (non-precise) location which may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency). |
| Usage Data |
Details of your use of the VeVe App or your visits to the VeVe Website including the content you access, the date and time of your use and the amount of time spent on the VeVe Services |
| Marketing and Communications Data |
Your preferences in receiving marketing from us and third parties and your communication preferences. |
| User Generated Content (UGC) Data |
Information you choose to post or upload when interacting with the VeVe Services, such as our Feed function and the VeVeVerse. |
| Biometric Information |
Biometric identifiers/information that you provide to us or our service provider. |
PART 2: HOW YOUR PERSONAL INFORMATION IS COLLECTED
We will collect and process the following information about you:
- Information you give us. This is information (including Identity, Contact, Financial, Marketing and Communications Data and UGC Data) you give us when you register and use the VeVe Services, enter a competition, promotion or survey, and when you report a problem with the VeVe Services. It also includes information you give us when you fill in forms on the VeVe Website or VeVe App, or by corresponding with us (for example, by email or chat). If you contact us, we will keep a record of that correspondence.
- Information we collect about you and your device. Each time you visit the VeVe Website or use the VeVe App we will automatically collect personal data including Device and Usage Data. We collect this data using cookies and other similar tracking technologies. Please see Part 13 (Cookies) for further details. We also collect information about your transactions including Collectible sales and purchases and Gem purchases and withdrawals. This also includes information in posts on the Feed function and the VeVeVerse (UGC Data).
- Information we receive from other sources. We will receive personal data about you from various third parties as set out below.
- Payment service providers: We will receive Contact, Financial and Transaction Data from our payment partners which allows your payments to be processed.
- KYC/AML providers: We will receive information about you from providers we use to carry out KYC and other processes required under anti-money laundering regulation and for identity verification purposes. This includes service providers that collect your biometric information to verify your identity
- Advertising and marketing partners: We may receive information about you from certain advertising or marketing partners. This allows us to deliver more relevant ads and marketing. This includes Device Data from analytics providers such as Google.
PART 3: HOW YOUR PERSONAL INFORMATION WILL BE USED
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered 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 or regulatory obligation
The table below sets out how your personal information will be used. For residents of the UK and EU we are required to specify the lawful basis for the processing of your personal information. See Part 12 for this information.
| Purpose/activity |
Type of data |
| To register you as a new VeVe user |
Identity
Contact
Financial
Device |
| To process Collectible listings, sales and purchases and Gem purchases and withdrawals (including the processing of payments) |
Identity
Contact
Financial
Transaction
Device |
| To deliver the other services that are part of the VeVe Services (including your use of the Showroom and Feed functions and the VeVeVerse) |
Identity
Contact
Device
Profile
Usage
UGC |
| To understand, diagnose, troubleshoot, and fix issues with the VeVe Services including through communications with our customer support team. |
Identity
Contact
Financial
Device
Transaction
Profile
Usage
UGC |
| To evaluate and develop new features, technologies, and other improvements to the VeVe Services |
Identity
Contact
Device
Profile
Usage
UGC |
| To manage our relationship with you including notifying you of changes to the VeVe Services |
Identity
Contact
Financial
Profile
Marketing and Communications |
| To enable you to participate in a prize draw, competition or complete a survey |
Identity
Contact
Device
Profile
Marketing and Communications |
| To operate effective security measures for the VeVe Service including security software and processes to detect and prevent bots and other automated threats |
Identity
Contact
Transaction
Device |
| To operate effective security measures for your Account |
Identity
Contact
Biometric |
| To carry out KYC and meet our other obligations under anti-money laundering regulations (including transaction monitoring and reporting) and for identity verification purposes |
Identity
Contact
Financial
Transaction
Biometric |
| To take appropriate action in relation to intellectual property infringement and inappropriate content (for example inappropriate posts on the Feed function or the VeVeVerse).
|
Identity
Contact
Transaction
Profile
Device
Usage
UGC |
| To comply with legal obligations and law enforcement requests. |
Identity
Contact
Financial
Transaction
Profile
Device
Usage
Marketing and Communications
UGC |
| To establish, exercise, or defend legal claims |
Identity
Contact
Financial
Transaction
Profile
Device
Usage
Marketing and Communications
UGC |
| To detect and prevent fraud, including fraudulent payments and fraudulent use of the VeVe Services. |
Identity
Contact
Financial
Transaction
Profile
Device
Usage
UGC |
| To conduct business planning, reporting, and forecasting. |
Transaction
Usage |
| For marketing, promotion, and advertising purposes. |
Contact
Marketing and Communications
Usage (see Part 13: Cookies for more information)
We may enrich the personal information we hold with the personal information from third parties where this is permitted under relevant law. |
| To provide you with recommendations and information within the VeVe App and VeVe Website based on the preferences you select in your Profile and past activity within the VeVe App and VeVe Website. |
Transaction
Profile
Usage
UGC |
We also collect, use and share aggregated data such as statistical or demographic data for any purpose ("Aggregated Data"). Biometric Data is not included in or used to generate Aggregate Data.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the VeVe Services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
PART 4: SHARING YOUR PERSONAL INFORMATION
Your username will be shown in your Market or Auction listings and in any bid you make in an Auction.
Your Profile is set to private by default. If you set your Profile to public, the number of Collectibles you hold, the information you include in the Bio in your Profile, your Profile picture and the Collectibles you have chosen for your Profile will all be able to be seen by other VeVe users.
All information, images and other content you include in posts in the Feed, the VeVeVerse or elsewhere on the VeVe Service will be able to be seen by other VeVe users.
Biometric Data: we do not share your Biometric Data with any third party, except where necessary to verify your identity.
We may disclose your personal information to the following categories of recipients:
Third Party Service Providers and Business Partners: We may share your personal information with our third party service providers (such as those who provide IT (such as data streaming and cloud services), analytics, payment processing, or customer support), third party business partners who otherwise process personal information for purposes that are described in this privacy policy (such as advertising partners) or who are otherwise notified to you when we collect your personal information. Where permitted under applicable law, our advertising partners may combine the personal data we share with them with other data they collect about you (e.g. your use of their services). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you.
Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts or other Third Parties: We may share your personal information with competent law enforcement bodies, regulators, our insurers, external legal advisors, government agencies, courts or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise, establish or defend our legal rights (including to collect amounts owed to us); (iii) to protect your rights or vital interests or those or any other person; or (iv) to detect, prevent or otherwise address security, fraud or technical issues.
Potential Buyers (and their agents and advisors): We may share your personal information with actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, provided that we inform the buyer or transferee that it must use your personal information only for the purposes disclosed in this Privacy Policy.
Social Media Platforms: We share some (hashed) email addresses with social media platforms for the purposes of targeted promotions and communications but this would only be conducted if you have permitted this through your relevant social media platform settings. We also have fan pages on certain social media sites and use some social media plug ins which may involve the provision of certain personal information to that social media platforms in accordance with their own privacy policy and terms of use.
PART 5: YOUR RIGHTS
Consent: If we have collected and process your personal information with your consent, then you can withdraw your consent at any time by contacting us using the details provided under
How To Contact Us. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Our communications to you: We may send marketing communications for purposes notified to you (including as specified in Part 3 above) and, where required by applicable law, with your consent. You can unsubscribe from electronic marketing communications at any time by following the unsubscribe instructions in our emails to you or by contacting us using the details provided under the
How To Contact Us. We will process your request within a reasonable time after receipt, in accordance with applicable laws.
We may also send you certain non-promotional communications regarding the VeVe Services and, to the extent permitted by law, you will not be able to opt-out of those communications (e.g., communications regarding updates to the Terms of Use or this Privacy Policy).
If you opt-in on your device, we may occasionally send you push notifications through our VeVe App with updates, achievements and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your device.
Other rights: Depending on country you live in or where we are regulated, you may also have other rights in relation to your personal information. For example, under EU and UK and certain US state laws, additional rights are available as set out below. Please contact us using the details provided under the
How To Contact Us section below if you would like to know more or with your request. To the extent that we are required to do so under applicable law, we will process your request.
PART 6: RETENTION OF YOUR PERSONAL INFORMATION
We will retain your personal information for the length of time needed to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. In considering what periods we retain personal data for we consider various factor including contractual limitation periods and legal requirements such tax and accounting rules.
PART 7: SECURITY
We take steps to ensure that your information is treated securely and in accordance with this privacy policy. We maintain commercially reasonable safeguards designed to protect against unauthorized use, disclosure or access of personal information.
PART 8: STORAGE AND INTERNATIONAL TRANSFERS
We operate globally and may transfer your personal information to third parties in locations around the world for the purposes described in this privacy policy. For example, checkout.com (our payment provider), Amazon Web Services (our data streaming and cloud services provider), Cavrnus (our metaverse software provider), Salesforce (our marketing automation provider and our customer support software provider) are based in the United States and therefore your personal data may be transferred to the United States. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. In respect of the UK and EU, if your personal data is transferred to a country which has not been deemed to have adequate data protection rules, then these steps will include implementing standard contractual clauses where recognized by law. Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us using the details provided under the
How To Contact Us section below.
PART 9: CHILDREN
The VeVe Services are not targeted at children and we do not knowingly collect information from children. A child for this purpose is an individual under 13 years old or the minimum age required to use the VeVe Services and give valid consent to the collection and processing of personal information in your country, if lower. Please contact us using the details provided under the
How To Contact Us section below if you are aware that we may have inadvertently collected personal information from a child.
PART 10: BIOMETRIC INFORMATION
This is a supplemental notice to Illinois residents, pursuant to the Illinois Biometric Information Privacy Act ("BIPA"). Some laws require us to verify your identity. We do this by partnering with a third party service to collect your biometric data which is used to confirm your identity, by comparing the picture of your face with the picture of your photo ID.
Purpose of collection: verification of identity.
Retention and destruction of biometric information: we only retain your biometric information until the initial purpose for collecting or obtaining such information has been satisfied. In general and except as otherwise required by law or legal process, we (including our third party service providers) will destroy the biometric information as soon as practicable following the successful verification of your identity or when you terminate or close your account with us, or otherwise discontinues use of our services. In no event will your biometric information be retained for longer than three years following your last interaction with our services.
User consent: your consent is obtained prior to collecting any biometric information. No biometric information is collected without your consent.
No sale, sharing, or profiting from biometric information: we only use your biometric information to verify your identity. We do not sell your biometric information and we only share it with third parties where it is necessary to verify your identity (such as a third party service provider that completes the verification procedure). We do not share, sell, or otherwise disclose your biometric information, for profit or otherwise.
Security: we store your biometric information with reasonable standard of care and in the same manner as other confidential or sensitive information stored by us.
PART 11: CHANGES TO THIS PRIVACY POLICY
From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The effective date of this Policy is stated at the top of this document under "Effective Date". Notice may be by posting the revised Policy on the VeVe Website or VeVe App, or by other means, consistent with applicable law.
PART 12: NOTICE TO RESIDENTS OF EU AND UK
For residents of the UK and EU we are required to specify the lawful basis for the processing of your personal information. The table below sets out the lawful basis for this purpose.
| Purpose/activity |
Type of data |
Lawful basis for processing |
| To register you as a new VeVe user |
Identity
Contact
Financial
Device |
Performance of a contract with you |
| To process Collectible listings, sales and purchases and Gem purchases and withdrawals (including the processing of payments) |
Identity
Contact
Financial
Transaction
Device |
Your consent
Performance of a contract with you
Legitimate interests (to receive payments owed to us) |
| To process Collectible listings, sales and purchases and Gem purchases and withdrawals (including the processing of payments)
To deliver the other services that are part of the VeVe Services (including your use of the Showroom and Feed functions and the VeVeVerse)
|
Identity
Contact
Device
Profile
Usage
UGC |
Performance of a contract with you |
| To understand, diagnose, troubleshoot, and fix issues with the VeVe Services including through communications with our customer support team. |
Identity
Contact
Financial
Device
Transaction
Profile
Usage
UGC |
Legitimate Interest (for the ongoing operation of the VeVe Services) |
| To evaluate and develop new features, technologies, and other improvements to the VeVe Services |
Identity
Contact
Device
Profile
Usage
UGC |
Legitimate Interest (to develop and improve the VeVe Services and grow our business) |
| To manage our relationship with you including notifying you of changes to the VeVe Services |
Identity
Contact
Financial
Profile
Marketing and Communications |
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To enable you to participate in a prize draw, competition or complete a survey |
Identity
Contact
Device
Profile
Marketing and Communications |
Performance of a contract with you
Legitimate interests (survey results are used to improve the VeVe Services) |
| To operate effective security measures for the VeVe Service including security software and processes to detect and prevent bots and other automated threats |
Identity
Contact
Transaction
Device |
Legitimate interests (for network security and to be able to offer an experience which is fair for all legitimate users) |
| To operate effective security measures for your Account |
Identity
Contact
Biometric |
Legitimate interests (ensure the security of VeVe users' accounts)
Consent for the use of biometric data for facial recognition |
| To carry out KYC and meet our other obligations under anti-money laundering regulations (including transaction monitoring and reporting) |
Identity
Contact
Financial
Transaction
Biometric |
Compliance with legal obligations (under anti-money laundering regulation)
Consent for the use of biometric data for facial recognition |
| To take appropriate action in relation to intellectual property infringement and inappropriate content (for example inappropriate posts on the Feed function or the VeVeVerse) |
Identity
Contact
Transaction
Profile
Device
Usage
UGC |
Legitimate interests (prevent infringement of our and our partners' intellectual property rights and our platform from being used in an inappropriate way)
Compliance with legal obligations |
| To comply with legal obligations and law enforcement requests. |
Identity
Contact
Financial
Transaction
Profile
Device
Usage
Marketing and Communications
UGC |
Compliance with legal obligations
Legitimate interest (to ensure we operate our business in a legally compliant way) |
| To establish, exercise, or defend legal claims |
Identity
Contact
Financial
Transaction
Profile
Device
Usage
Marketing and Communications
UGC |
Legitimate interests (to be able to establish, exercise, or defend legal claims) |
| To detect and prevent fraud, including fraudulent payments and fraudulent use of the VeVe Services. |
Identity
Contact
Financial
Transaction
Profile
Device
Usage
UGC |
Legitimate interests (to detect and prevent fraud) |
| To conduct business planning, reporting, and forecasting. |
Transaction
Usage |
Legitimate interests (to manage and grow our business)
|
| For marketing, promotion, and advertising purposes. |
Contact
Marketing and Communications
Usage (see Part 13: Cookies for more information)
We may enrich the personal information we hold with the personal information from third parties where this is permitted under relevant law.
|
Legitimate interests (to grow our business) |
| To provide you with recommendations and information within the VeVe App and VeVe Website based on the preferences you select in your Profile and past activity within the VeVe App and VeVe Website. |
Transaction
Profile
Usage
UGC |
Legitimate interests (to provide a better experience for our customers and grow our business) |
You have a right to lodge a complaint with your local Data Protection Supervisory Authority if you believe we have not complied with applicable data protection laws.
PART 13: COOKIES
We use cookies for analytics, Service functionality, performance and for advertising. By using the term "cookies" we also encompass any other similar technology such as pixels and web beacons.
We provide details of the types of cookies we use and the different purposes in our cookie preference centre. This is displayed to you when you first visit our Services and is otherwise available at any time by clicking the cookie icon at the bottom left hand corner of the VeVe Website. You can use the cookie preference centre to set and change your preferences around any non-essential cookies or you can use your browser settings and controls to do this. Some cookies are essential for the running of our Services and so can't be rejected or changed.
You can also learn more about interest-based advertising and opt out of interest-based advertising from participating online advertising companies at the following links:
Network Advertising Initiative (NAI) –
https://optout.networkadvertising.org/
Digital Advertising Alliance (DAA) –
https://optout.aboutads.info/
Digital Advertising Alliance EU (EDAA) –
https://www.youronlinechoices.com/
DAA Veve AppChoices page –
https://youradchoices.com/appchoices
Please note that opting out of personalized advertising does not mean you will no longer be served advertising. You will continue to receive generic ads. Other websites may use different cookies from those we use. You acknowledge and agree that We are not responsible for any third party websites or applications and you access third party websites and applications at your own risk. Please understand other websites and applications are independent from us so you must inform yourself of their separate cookie policies.
PART 14: HOW TO CONTACT US
For privacy queries, we can be contacted by emailing
privacy@veve.me.
We have establishments for the purposes of data protection laws in various countries including the UK and the EU.
