INTRODUCTION
Your privacy is important to us. The policy of VELARIS 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://daloras.com and other related services.
VELARIS INC. is an American 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 (such as 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 sites and services, please note that these sites and services have their own privacy policies. After following a link to any third-party content, you should read their published privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our Platform.
TERMINOLOGY AND DEFINITIONS
The following terms are used in this Privacy Policy:
"We", "us", "our" refers to VELARIS INC.
"Company" means VELARIS INC., a corporation registered under the laws of the State of Wyoming, United States of America, owning and operating the Platform.
"Platform" means the daloras.com website, 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 information services provided through the Platform.
INFORMATION WE COLLECT
Categories of collected information
The information we collect falls into one of two categories: "voluntarily provided" information and "automatically collected" information.
"Voluntarily provided" information refers to any information that you knowingly and actively provide to us when using or participating in any of our services and promotions.
"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 when you contact us — which may include one or more of the following:
- Name;
- Email;
- Social media profiles;
- Date of birth;
- Phone/mobile phone number;
- Identity documents (for verification);
- Payment information.
Sensitive information
"Sensitive information" or "special categories of data" is a subset of personal information that is provided with a higher level of protection. Types of sensitive information we may collect about you include:
- Sexual orientation;
- Health information (if provided voluntarily).
We will not collect sensitive information about you without first obtaining your explicit 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;
- Your browser type and version;
- Pages you visit;
- Time and date 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" as materials (text, images and/or video content) voluntarily provided to us by our users for the purpose of publication, processing or use on our Platform. All user content is associated with an account or email address used to submit materials.
Important to remember: any content you submit for publication will become publicly available after publication (and subsequent review or moderation process). After publication, it may be accessible to third parties not covered by this privacy policy.
Transaction data
Transaction data is data that accumulates during the normal operation of our Platform, including:
- Transaction records;
- Stored files;
- User profiles;
- Analytics data;
- Other metrics of user interactions 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 reliable cloud service providers and data processing 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 US or have appropriate certifications to work with American companies.
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 functionality.
All third-party data processors are bound by contractual obligations to protect your personal data and may only use it to provide services on our behalf in accordance with American data protection standards.
International data transfer
The personal information we collect is processed in the United States of America or where we or our partners, affiliates and third-party providers have facilities.
Countries where we store, process or transfer your personal information may have different data protection laws than the country where you originally provided the information. If we transfer your personal information to third parties in other countries:
- We will perform such transfer in accordance with applicable law requirements;
- 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 lawful basis for doing so. In this case, we collect only the personal information that is 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:
- Providing you with the core functions and services of our Platform;
- Enabling customization or personalization of Platform use;
- Communication and correspondence with you;
- Analytics, market research and business development, including operation and improvement of the Platform;
- Advertising and marketing, including sending promotional information about our products and services;
- Providing access to the Platform and related applications;
- Ensuring security and preventing fraud;
- Technical assessment, including operation and improvement of the Platform;
- Compliance with legal obligations and interaction with law enforcement agencies.
DISCLOSURE OF INFORMATION TO THIRD PARTIES
We may disclose personal information to the following categories of recipients:
- Parent, subsidiary companies or affiliates of our company;
- Third-party service providers, including IT services, hosting, analytics, payment systems, marketing and professional consulting providers;
- Our employees, contractors and related organizations;
- Law enforcement agencies when there is a lawful requirement;
- An organization that purchases or to which we transfer all or 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 in commercially acceptable ways to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.
Our security measures include:
- Data encryption during transmission and storage;
- Access control to personal data;
- Regular security audits;
- Staff training on data protection issues;
- Use of secure data processing centers.
Important to remember: no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. You are responsible for selecting any password and its general 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 in accordance with legal requirements.
Standard retention periods:
- Account data: throughout the lifetime of your account plus 12 months after its 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 required for stated purposes, we will delete it or make it anonymous 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 us with personal information, however, if you do not, it may affect your use of the Platform.
Access: You may request details about the personal information we hold about you.
Correction: If you believe that any information about you is inaccurate, outdated, incomplete or misleading, contact us. We will take reasonable steps to correct such information.
Download personal information: We provide you with the ability to download personal information you have provided through the Platform.
Unsubscribe: To unsubscribe from our email database or opt out of receiving marketing communications, use the opt-out means indicated in the message or contact us.
Data breach notification
We will comply with applicable laws regarding any data breach, including notifying affected users and relevant regulatory authorities within established 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 Usage Policy, which is an integral part of this Privacy Policy and is available on our Platform.
PRIVACY OF MINORS
We do not target any of our products or services directly at users under 18 years of age and do not knowingly collect personal information about users under 18 years of age. If we become aware that we have collected personal information from a person under 18 years of age without verifiable parental consent, we will delete such information from our files.
POLICY CHANGES
At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or changes in legislation or regulations.
If we decide to change this privacy policy, we will post the changes here at the same link where you access this policy.
If the changes are significant or if required by applicable law, we will contact you and all our registered users, providing new details and links to the updated policy.
If required by law, we will obtain your permission or provide you with the opportunity to agree or opt out of any new use of your personal information.
US LAW COMPLIANCE
Applicable law
This Privacy Policy is governed by the laws of the State of Wyoming, United States of America, in accordance with our Terms of Use.
CCPA compliance (California)
Additional rights apply to California residents under the California Consumer Privacy Act (CCPA):
Categories of personal data collected in the last 12 months:
- Identifiers (name, email, IP address, account number);
- Customer records (address, payment data);
- Demographic data (age, gender);
- Commercial information (purchase history);
- Internet activity (service interactions);
- Audio/visual data (photos, videos);
- Geolocation data;
- Inferences (preference information).
Your CCPA rights:
- Right to know: You may request information about what personal data we have collected, used, disclosed or sold in the last 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.
Interaction with law enforcement agencies
We cooperate with law enforcement agencies in accordance with applicable US law:
- Respond to lawful requests within established timeframes;
- Report suspicious activity to appropriate agencies;
- Preserve data upon official legal hold requests;
- Notify users of requests unless prohibited by law.
GDPR COMPLIANCE (for EU/UK users)
Legal basis for processing
For users from the European Union and United Kingdom, we process personal data based on the following legal bases:
Consent: When you give us explicit consent to process your personal data for specific purposes;
Contract performance: When processing is necessary for the performance of a contract with you or to take preliminary measures at your request;
Legitimate interests: When processing is necessary for our legitimate interests, provided that such interests 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 obtain 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: In 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 of your personal data in certain circumstances;
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 prior to withdrawal.
International transfers
Since our servers are located in the US, your personal data will be transferred to a country that may not provide the same level of data protection as EU/UK countries. We take appropriate safeguards to ensure the security of your data, including:
- Using standard contractual clauses approved by the European Commission;
- Ensuring that data recipients provide an adequate level of protection;
- Obtaining your explicit consent for transfer, where applicable.
Complaints
If you believe we have processed your personal data incorrectly, you have the right to lodge a complaint with the data protection supervisory authority in your country. However, we would appreciate the opportunity to address your concerns directly, so please contact us first.
CONTACT INFORMATION
If you have questions or comments regarding this Privacy Policy, or if you want to exercise any of your rights, contact us:
VELARIS INC.
Email: support@daloras.com
Postal address:
