EFFECTIVE FROM SEPTEMBER 2022

Velwire Pte Ltd. (“VELWIRE”) respects your privacy and follows necessary measures for maintaining and protecting your information as detailed in this Privacy Policy. As a Technology Solutions Provider, VELWIRE has integrated a privacy-first mindset in relation to all information received through its website and ensures transparency in its system upon complying with more than just the privacy laws and regulations of the country.

Use of this website signifies your acknowledgement and consent to this Privacy Policy. Please read this Privacy Policy carefully before using this website. By using VELWIRE’s website, you signify your full consent / agreement to the terms and conditions of this Privacy Policy. We will only be able to onboard you if you agree with the terms and conditions. By using VELWIRE’s website, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy.

This Privacy Policy defines the types of information we may collect, the purposes for which we collect such information, the other parties with whom we may share it and the measures we take to protect the security of all kinds of Information received through our website. It also guides you about your rights and choices with respect to your Personal Information, and how you can contact us about our privacy practices.

1. Privacy & Security of Website
   VELWIRE is committed to protect its users’ privacy. VELWIRE understands and appreciates concerns of the visitors and users of its website about their privacy, confidentiality and security of the information that may be received from them through VELWIRE’s website.
   
   
2. Collection of Personally Identifiable Information and Other Information
   We may collect and store your personal identity information provided by you from time to time when you use our website as well as in the events you opt to leave comments, queries, feedbacks, and requests on our website. We do so to ensure you a safe, efficient, smooth, and seamless experience of using our website. This also permits us to comprehend your requirements and update our website and its features accordingly. We strive to provide for customizations on our website to ensure that your experience is always safer and easier. This requires collection of Personal Information to the extent necessary for achieving this purpose and objective.
   
   Registration is mandatory to access the cloud services offered in our website and to this end, once you register and expressly give us permission to use your personal information, we may automatically track certain information about you based upon your behavior on our website to the extent we deem fit.
   If you choose to provide information by way of messages on our message boards (as & when available) and/or chat rooms or any other message areas or if you prefer to leave feedback, we will collect that information. We collect personally identifiable information (email address, name, phone number, NID number etc.) from you when you register with us.
   
   VELWIRE, in its role as a Technology Solution Provider, may receive financial information from both natural persons and legal persons through this website. Collection of such information by VELWIRE is in consonance with applicable statutory and regulatory requirements. Further, anytime you visit this website, VELWIRE may gather certain non-personally identifiable information regarding the means you use to access our site. This information may include the type and version of your browser, your service provider, your IP address, and any search engine you may have used to locate the website etc.
   
   Personal Information We Obtain when You Apply for a Job with Us
   If you are applying for a job at VELWIRE, we may collect certain Personal Information from your job applications submitted through our website, such as your contact information (including name, postal address, email address and phone number), job history, curriculum vitae, contact details of your referees and any other Personal Information you choose to submit along with your application.
   
   
3. Use of Information
   VELWIRE may collect Information from its website, primarily to provide our visitors with a more relevant experience on this website. When doing so, VELWIRE takes every reasonable effort to avoid excessive or irrelevant collection of data. We collect information only to the extent that it is necessary for the purposes set out below:
   
   We May Use Your Information to:
   1. Provide you with more relevant and useful information while browsing our website.
   2. Enforce our terms and conditions as otherwise described to you at the time of such collection.
   3. Operate, evaluate, and improve our business, including anonymization and analytics.
   4. Process your job application.
   5. Serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by law.
   6. Learn more about you, including your preferences or other characteristics. We treat these inferences as Personal Information where required under applicable law.
   7. Where required under applicable law, we will only use your Information with your consent; as necessary to provide you with products and services; to comply with a legal obligation; or when there is a legitimate and overriding interest that necessitates the use.
   8. Identify you, use your IP address to help diagnose problems with our server, and to administer our website and to gather broad demographic information/ broad statistical data.
   9. Provide and maintain our website, including to monitor the usage of our website.
   10. Contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
   11. Provide you with news, special offers and general information about other goods, services, and events which we offer that are similar to those that you have already enquired about unless you have opted not to receive such information.
   12. Attend and manage your requests to us.
   13. Use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to
       evaluate and improve our website and your experience
       
       
4. Sharing of Your Information
   VELWIRE shall take reasonable steps to protect your Information against unauthorized disclosure. Subject to the provisions of any applicable law, your Information may be disclosed, where applicable, to the entities or parties mentioned below, whether they are located overseas or in Bangladesh.
   
   VELWIRE May Share Your Information with:
   1. Service providers acting on our behalf.
   2. Third parties whose feature you use in connection with our services or with your consent.
   3. Other entities as required under applicable law or in the event of a sale or transfer of our business or assets.
   4. Law enforcement authority upon such requests.
   5. Third party rights owners or others in good faith that such disclosure is reasonably necessary to: enforce our Terms or Privacy Policy; respond to claims that an advertisement, posting, or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public.
   6. Third parties if required to do so by law or in good faith that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal processes.
   7. Another business entity should we (or our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Such other business entity (or the new combined entity) shall be required to follow this Privacy Policy with respect to your personal information.
   8. Third parties when we act as a service provider for them.
   9. Our service providers who perform services on our behalf for the purposes described in this Privacy Policy (or in the applicable program specific Privacy Policy).
      ***Disclaimer: We require these service providers by contract to only process Personal Information in accordance with our instructions and as necessary to perform services on our behalf in compliance with the applicable laws. We also require them to safeguard the security and confidentiality of the Personal Information they process on our behalf by implementing appropriate technical and organizational security measures and confidentiality obligations binding those employees who have access to such Personal Information.
   10. Third parties whose features (e.g., third-party cookies, widgets, plug-ins) are integrated in our services.
   11. Social media networks when you directly engage with those platforms.
   12. Other third parties with your consent.
   13. Appropriate authority as required under applicable law or legal process, or when we believe disclosure is necessary to protect individuals’ vital interests, to enforce our Terms of Use, prevent our website against harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
   14. VELWIRE’s related corporations.
   15. Companies providing services related to insurance to VELWIRE as well as agents, contractors or third-party service providers who provide operational services to VELWIRE, such as courier services, telecommunications, information technology, payment, printing, billing, technical services, training, market research, call center, security or other services to VELWIRE.
   16. Vendors or third-party service providers in connection with marketing promotions and services offered by VELWIRE.
   17. Our merchant partners.
   18. Any business partner, investor, assignee, or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale).
   19. Our professional advisers such as consultants, auditors, and lawyers.
   20. Relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
   21. Any other party to whom you authorize us to disclose your Personal Information to.
       ***Disclaimer: We do not disclose Personal Information we collect about you, except as described in this Privacy Policy, as disclosed to you at the time of data collection. Also note that, we do not sell Personal Information we collect about you.
       
       
5. Your Rights and Choices
   You may have the following rights or choices to:
   1. Opt out of some collection or uses of your Information, including the use of cookies and similar technologies, the use of your Information for marketing purposes, and the
      anonymization of your Information for data analyses.
   2. Receive the Personal Information you provided to us to transmit it to another company.
      You can exercise your rights by submitting a request to info@velwire.com or as described in the “How to Contact Us” section below.
      
      
6. Retention of Information
   VELWIRE is an ISO 270001 certified company. Therefore, as a Technology Solutions Provider, VELWIRE maintains the records and information in a safe and secured manner as per international standards developed and published by the International Organization for Standardization (ISO), its policy and in compliance with the statutory provisions and directions for the period required by it and as permitted by applicable laws and rules etc., as detailed hereunder:
   1. VELWIRE will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws) and enforce our legal agreements and policies.
   2. VELWIRE will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website, or VELWIRE is legally obligated to retain this data for longer time periods.
   3. All Information is stored in paper and electronic files within VELWIRE’s premises, and approved archives. VELWIRE does not allow any unauthorized access to the information stored by it in any form whatsoever. The Information is securely stored, and access is restricted to authorized personnel only. VELWIRE incorporates confidentiality clause in non-disclosure agreement with entities having business with VELWIRE to keep personal information secure and confidential and not to disclose the personal information to others, unless required by law or by an order of a court or by written instruction by VELWIRE. Such non-disclosure agreements stipulate that all Personal Information obtained by other party from the arrangement with VELWIRE will be returned or destroyed on termination/expiry of the non-disclosure agreement.
      
      
7. Use of Cookies
   VELWIRE may use a browser feature known as a “cookie.”
   1. Cookies are small files placed on your hard drive that assist in providing a user with a customized browsing experience. Cookies provide convenience to the user using the website to access the same from the place where it was last accessed if it is abandoned mid-way.
   2. When a user visits VELWIRE’s website, the website administrator may use cookies to monitor the usage and collect statistics from the browser(s) used by users, including and not restricting the information about the time and date when a user accessed the site, the pages user visited, the Internet domain and IP address from which the user has accessed the website and information on the browsing software the user has used to access the website. However, no attempt is made to gather or keep personal details to identify users except, in an unlikely event of an investigation, where a law enforcement agency may exercise a power to inspect activity logs.
      
      
8. Protection of Information
   VELWIRE on best effort basis follow appropriate operational, physical, electronic, procedural, and technical safeguards against any unauthorized access or breach of data security to avoid any loss or damage to the owners of confidential information. However, VELWIRE shall not be made liable for the same in any manner whatsoever for any default. Some of the salient features of information security system are as under:
   1. Use of firewalls, encryption, and data leakage prevention technologies to protect information
   2. Execution of non-disclosure agreements with all service providers before availing their services.
   3. Continuous monitoring of VELWIRE’s physical and technical environment for vulnerabilities and potential intrusions and implementation of controls to identify and address any concern related to protection of data.
      
      
9. Breach of Privacy Policy
   Without prejudice to VELWIRE’s other rights under these terms and conditions, if you breach any terms and conditions in any way of this Privacy Policy, VELWIRE may take such action as VELWIRE deems appropriate to deal with the breach, including suspending your access to the website, prohibiting you from accessing the website, blocking computers using your IP address from accessing the website, contacting your internet service provider to request that they block your access to the website and/or bringing court proceedings against you.
   
   
10. Data Transfers
    We adhere to the data protection laws of the land. We may transfer your Personal Information to the third parties, if required, only with your consent. However, we may transfer your Personal Information without your consent if so, required by the appropriate law enforcing authority in accordance with laws of the land.
    
    
11. Security Precautions
    Our website has stringent security measures in place to protect the loss, misuse, and alteration of the Information under our control and follows the best practices in the industry in this regard. Whenever you change or access your account information, it is through secured channels. Once your Information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.
    
    We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period.
    
    
12. Features and Links to Other Websites
    Our website may include links to other third-party websites, social media tools, widgets, or plugins, permitting sharing web content including IP address, with third parties and social media providers. These social media providers may learn of your visit even if you are not logged in to your social media account or if you do not have an account with them. To the extent any linked websites or features you visit, or use are not owned or controlled by VELWIRE, we suggest that you review their own privacy policies.
    
    
13. Updates/Change to this Privacy Policy
    This Privacy Policy is subject to change from time-to-time. This may be updated periodically to reflect changes in our privacy practices. We will post a prominent notice on our website to notify you of any significant or material changes to our Privacy Policy prior to them being effective and indicate at the top of the Notice when it was most recently updated. If we update our Privacy Notice, in certain circumstances, we may seek your consent. You are advised to review the policies periodically for any upgradation and/or changes.
    
    
14. Your Consent
    By using the website and/ or by providing your information, you consent to the collection and use of the information you disclose on the app in accordance with this Privacy Policy, including but not limited to your consent for sharing your personal information as per this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we may collect, how we use it, and under what circumstances we may disclose it.
    
    
15. Email
    Email correspondence sent to VELWIRE is treated as record and will be retained as required by law. The name and address details of senders are neither added to a mailing list nor disclosed to third parties without consent of the sender unless required by law. Email messages may be monitored by website support staff of VELWIRE for system trouble shooting and maintenance purposes.
    
    
16. How to Contact Us
    Please contact us if you have any questions, comments or complaints regarding this policy, or would like to update your privacy preferences, at info@velwire.com or write to us at: 105 Cecil Street #18-00, The Octagon, Singapore 069534