Privacy Policy

Valid as of January 12, 2023

This Privacy Policy and Cookies Statement describes how Valora Inc. and its associated websites, subdomains, mobile versions, and any associated applications and services (referred to in this document as “Valora,” “we,” “us” or “our”) collect, use, share and otherwise processes Personal Data (defined below) including:

Visitors to our website(s), mobile applications and other online properties (“Site” or “Sites”)
Any other individual about whom Valora may obtain Personal Data

In this Privacy Policy, “Personal Data” means information that (either in isolation or in combination with other information held by Valora) is capable of being associated with, or reasonably linked, directly or indirectly, with you or your household. We may collect Personal Data when you use our Sites.

Overview

Unless we specifically state otherwise, Valora is the data processor of the Personal Data we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us. Valora personnel are required to comply with this Privacy Policy and, where applicable, complete data protection training.

Collection of Personal Data

Valora collects Personal Data that you provide directly to us, such as your full name, email address and/or telephone number, when you use our products, contact our customer support services, browse our Site(s), register to receive newsletter requests or other information, provide feedback through surveys, or participate in any interactive features on our Sites, including contests, promotions, challenges, activities or events. We also collect Personal Data provided by job applicants or others, such as your full name, email address and physical address, on our Sites in connection with employment or consulting opportunities, which may also be subject to other Policies. We may also collect Computer Internet Protocol (IP) address, unique device identifier (“UDID”), cookies, web beacons, web server logs and other technologies and other data linked to a device, and data about usage of our Sites (Usage Data).

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

With your consent, you may instruct Valora to access an encrypted version of your contacts' phone numbers, which you can then use to find which of your contacts are already on Valora. However, no Personal Data will be shared with anyone directly, including Valora.

Other types of information we may collect include your name, email address, username, phone number, location and any other information you choose to provide. We may use automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain automatically may include your device IP address, identifiers associated with your devices, types of devices you have connected to our services, your web browser characteristics, your usage patterns, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site.

We may also obtain your Personal Data through your use of social media, such as Facebook, Twitter or Instagram, depending on your settings or the privacy policies of these services. To change your settings on these services, please refer to their respective privacy notices.

Finally, Valora may be required by law to obtain certain information from you from time to time for purposes of meeting its know-your-customer and customer due diligence requirements specifically to comply with anti-money laundering and countering the financing of terrorism obligations.

Use of Personal Data

We use the Personal Data that we collect:

To make our products and Sites more intuitive and easier to use by using device data, cookies and other information that you may provide. This data is necessary for our legitimate interests in monitoring how our products and Sites are used to help us improve these products and Sites, and the information and tools available on these products and Sites.
To provide relevant marketing including providing you with information about events or services that may be of interest to you. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.
To consider individuals for employment and contractor opportunities and to manage onboarding processes we use job applicant data. The processing is necessary for the purpose of recruitment and onboarding.
To deliver products, customer support, and services to you by verifying your identity (for example when you access your account information); processing applications for products or services; and processing transactions.
To personalize your digital and mobile experience by enhancing our Sites and Mobile Apps organization and design, and analyze data to create relevant alerts, products or services.
To detect and prevent fraud, identity theft and other risks to you or Valora.
To perform analytics concerning your use of our online services and Mobile Apps, including your responses to our emails and the pages and advertisements you view.
To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
To Allow you to use features within our Sites and Mobile Apps when you grant us access to personal information from your device such as contact lists, or geo-location when you request certain services that require such access.

How we share your information

We may share the personal information we collect from and about you as described here with:

Our affiliates and subsidiaries;

Service providers, vendors and third-party providers who have contracts with us;

Government agencies as required by applicable law;

Another company, but only in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to such company;

With your consent or at your direction; and

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Valora Sub-Processors

We use the following sub-processors to operate our Services:

Segment.io Inc: Site Visitor Data Platform (United States)
Google: Site Visitor Analytics (United States)
Lever, Inc.: Applicant Tracking Platform (United States)
ActiveCampaign, LLC: Visitor Tracking and Communication Platform (United States)
ipstackIP: Address Geolocation (Austria)
cLabs: Site Maintenance and General Support (United States/Germany)
Sentry: error tracking and performance monitoring (United States)
Adjust: analytics platform (United States)
CleverTap: analytics (United States)
Mixpanel: analytics platform (United States)
Statsig: analytics platform (United States)

Legal Bases For Processing (For EEA and other Users)

If you are an individual from the European Economic Area (“EEA”) or a jurisdiction with similar data protection regimes, we collect and process your Personal Data only where we have a legal basis for doing so under applicable laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your personal data only:

To operate our business, including to improve and develop our services, for fraud prevention purposes, improve user experience, or other legitimate interests;
To fulfill contractual responsibilities; and/or
As otherwise in compliance with the law.

If you have any questions about the legal basis for processing, please contact us at the address listed in the “Contact Us” section.

Transfer of Personal Data To Other Countries

We may transfer your Personal Data to countries outside of your country of residence, including, but not limited to the EEA, as well as the United States, where Valora’s office and some of its IT systems (including email) are located. Personal Data is not processed outside of the United States.

The laws of some countries may not provide the same levels of protection of personal data as your home country, particularly if you are resident in the EEA. By submitting data, you agree to the collection, transfer, storage, use and processing of data about you for the purposes described in this Privacy Policy. When you provide personal data to us or our service providers or vendors, you consent to the processing of your data in the United States as the Site is operated in the United States. We will take reasonable steps to ensure that data about you is treated securely in accordance with this Privacy Policy and that all data you provide to us is stored on our secure servers or those of our service providers.

YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR DATA IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR DATA TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR DATA WITH US, OR MAKE USE OF THIS SITE.

TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING DATA IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE EEA. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.

Making Sure Your Information is Accurate and Individual Rights

Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please contact us at support@valoraapp.com.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond effectively to your request. Requests should be directed to support@valoraapp.com.

How We Protect Your Information

Protecting your information is important to us. We maintain administrative, technical and physical safeguards designed to protect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of Personal Data.

How Long We Retain Your Information

We strive to only keep your Personal Data only for the period of time needed for legitimate business purposes. In certain circumstances, however, legal or regulatory obligations may require us to retain records for longer than we otherwise would.

Children’s Information

Our Services are not directed to children under the age of 18. If you learn that a child under the age of 18 has provided us with Personal Data without consent, please contact us.

Your Rights

If you are resident in states or countries with applicable data privacy laws you have the right, subject to certain exceptions, to request a copy of the Personal Data we are processing about you; to require that any incomplete or inaccurate Personal Data is amended; to request that we delete your Personal Data (although we may not be able to delete certain data due to legal or other obligations); to object to the use of your Personal Data; or to withdraw consent. You may also contact us to address and resolve concerns you may have about our use of your Personal Data. Please contact us at support@valoraapp.com.

Changes To This Privacy Policy

We reserve the right to change and update this Privacy Policy from time to time. If we make changes, you will be notified of the change by the “Valid as of” date at the top of this Privacy Policy, which will reflect the last date updated.

Third-Party Services, Applications, and Websites

Certain third-party services, websites, or applications (including, but not limited to, decentralized apps) you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.

Social Media

We engage with customers on social media platforms such as Twitter, Instagram, Facebook, and Discord.

Any content you post on official Valora-managed social media pages, such as pictures, information, opinions or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms.

When interacting with official Valora social media pages, Valora’s privacy notice may apply.

Please review the privacy policy for the specific social media service you are using to better understand your rights and obligations with regard to such content.

We may allow certain non-affiliated third-party widgets (for example social share buttons) on our sites that enable users to easily share information on another platform, such as a social media platform. The non-affiliated third parties that own these widgets may have access to information about your browsing on pages of our Sites and Mobile Apps where these widgets are placed.

YOUR CALIFORNIA PRIVACY RIGHTS

Shine the Light Law

A California privacy law that went into effect on January 1, 2005, the “Shine the Light” law, allows California residents to obtain a list of third parties to whom a business has disclosed personal data if it shares such information with third parties for their direct marketing purposes. However, if a business adopts and discloses in its privacy policy a policy of not disclosing customers’ personal data to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal data and by providing a cost-free means to exercise that right.

As stated earlier in this Privacy Policy, Personal Data submitted at the time of registration or submission may be used for marketing and promotional purposes only with the user’s permission. Whenever a user agrees to allow us to collect Personal Data, we provide the user with an option to prevent such data from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time by sending an email to support@valoraapp.com.