Privacy Policy

Last Updated: February 23, 2017

We value your privacy and desire to ensure that your experience with Max2TM and all of our websites and related or associated subdomains (the "Sites") and all of our products, mobile applications, including VeeaTM ("Veea"), Veea Connect and Veea Pay ("Veea Pay" and collectively, the "Apps"), the Veea Pay payment software, blogs, forums, channels and sharing services (collectively with the Sites and Apps, the "Services") are satisfying and safe.  In that regard, Max2 Inc. and our affiliates and subsidiaries (collectively "Max2") have established for the Sites and Services the following Privacy Policy to explain and describe what personal information is collected on our Sites and Services, how we use it and your options regarding information we may collect about you. By accepting this Privacy Policy, you expressly consent to the information handling practices described in this Policy. This Privacy Policy is a part of and incorporated into Max2's Terms of Use associated with our Sites and Services. In addition, by accepting this Privacy Policy you expressly represent that you are over the age of 18 or are not considered a minor in the jurisdiction for which you reside. Your continued use of Max2's Sites and Services or any other content, products, or other services covered by this Policy constitutes your acceptance and agreement to this Policy and any updates.

  1. What information do we gather?

We collect Personal Information, as well as non-personally identifiable information on Max2's Sites and Services. "Personal Information," as used in this Policy, is personally identifiable information, which is information that directly identifies an individual, such as first name/initial and last name, mailing address, email address, or telephone number.

We collect Personal Information in two ways. First, we collect the Personal Information you provide to us in optional, voluntary submissions, such as in registration forms, user profiles, promotional signups, sweepstakes/contest entries, requests for customer service, software and mobile applications downloads. Second, some Personal Information may be collected automatically. This is described below.

We may also obtain information, including Personal Information, from third party sources. If we directly combine information provided by third parties with Personal Information that we have collected, then we will treat the combined information as Personal Information and handle it in accordance with this Policy. In addition, please note that we may solicit third parties to collect Personal Information on our behalf and in such cases we instruct those third parties to comply with this Policy and all applicable data protection laws.

You are under no obligation to provide any requested information at any time. However, if you decline to provide information that is reasonably necessary to participate in certain activities, you may not be able to participate in those activities on certain Sites and Services.

We may use a variety of methods, including "cookies" and other technologies such as pixel tags and web beacons to collect information.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device. You can find more information about cookies at: www.allaboutcookies.org.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests.

Max2 does not require that you accept cookies and you may withdraw your consent to our use of cookies at any time by adjusting your browser's privacy settings, however, some functionality on our Sites (e.g. "functionality cookies"), our product or service check-out process, and Services may be disabled if you decline to accept cookies ( e.g. "necessary cookies").

Max2 does not give away Personal Information about our users. If you choose to provide Personal Information about yourself, we will use this information only to communicate directly with you and as otherwise expressly stated in this Policy. Max2 will not sell, rent or otherwise disclose that information to third parties unless that disclosure is necessary for the purposes set forth in this Policy, by law or a policy or notice contained or associated with a specific Site(s) and Service(s).

We may collect, use, and share (with Max2 partners, service providers and licensees) precise location data, including the real-time geographic location of your mobile or fixed location device. Where available, location-based services may use GPS, Bluetooth, and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices' approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by us and our partners and licensees to provide and improve location-based products and services.  We may use Personal Information in conjunction with geo-location data to provide you with personalized location-based products and services or location-based offers, products and services we believe would be of interest to you.

We use analytics tools and other third party technologies, such as Fabric, Testflight or Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our online Sites and Services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information.

The third-party analytics companies who collect information on our Sites and Services and other online products and services may combine the information collected with other information they have independently collected from other websites and other online or mobile products and services relating to your activities across their network of websites as well as online and mobile products and services. Many of these companies collect and use information under their own privacy policies.

In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of Max2 Sites and Services and to otherwise collect and use data about your use of Max2 Sites and Services.

  1. How do we use this information?

Generally, we use Personal Information to establish and enhance our relationship with our users through four main categories: (1) Communication; (2) Optimization; (3) Advertising; and (4) Sharing Features. Below, we provide some examples of how we use the Personal Information and other information we collect.

Communication and Responding to Requests

We use your information, including Personal Information to provide you with customer support, process transactions, respond to users' requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and promote Max2 Sites and Services, as well as products and services of our partners and licensees.

Optimization

We use user information, including Personal Information, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our Sites and Services, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.

Advertising

We use user information, including Personal Information, behavioral metrics, geo-location data, demographic data and marketing preferences to personalize, display and transmit advertisements, promotions and other content to you and to process contest, sweepstake, or other promotion entries and fulfill any related award.

Sharing Features

We use your information, including Personal Information and any other information you submit directly or through passive means to provide you with various ways to communicate and share content (e.g., web content, user generated content, text, drawings, media, tools, services and other products) with third parties. For example, we may provide you with the opportunity to email a link to certain content to another person. To use this feature, we may require you to provide certain Personal Information including your email address and the email address of each person to whom you send the link.

We also may allow you to share links to content with users of various third party services (e.g., social networking, search and sharing services). When sharing links using one of these third-party services, if you are not already logged in to the third-party service, you will need to supply login credentials for it. If you are not a registered user of the third-party service, you will need to sign up for it. You are supplying the registration information or login credentials for the third-party service directly to that third party, and not to us. By using any of these third-party services to share links to content, you permit us to access, use and disclose any information relating to your account on each third-party service (such as your user name and profile information) that is available to us through the third-party service, including through its application programming interface (API) pursuant to this Policy.

  1. Will we disclose your Personal Information to third parties?

We do not disclose Personal Information with third parties except in the limited circumstances described in this Policy. We are interested in maintaining your privacy and creating a valuable resource for you to use.

Service Providers

We may provide Personal Information to service providers so that they may perform services on our behalf, such as internal business functions (e.g., payment processing, customer service, maintenance, security, data analysis, email transmission, beta testing, or data hosting).  Additionally, some third-party service providers may collect information, including Personal Information, on our behalf. Whenever possible, we require third-parties to only collect and use Personal Information in accordance with this Policy, to maintain the confidentiality, security, and integrity of Personal Information, and for no purpose other than providing us with our requested services.

Partners

When you visit or use a part of any website, mobile application, or other consumer product that is co-branded or that is a part of or relates to a joint promotion involving Max2 and one or more third parties (each a "Co-Branded Party"), unless stated otherwise in connection with the joint promotion, you are providing and consenting to provide and are transmitting your Personal Information and other information provided to, or collected, or obtained by Max2 and any Co-Branded Parties involved, to Max 2 and each of the Co-Branded Parties without any other notice or further consent. Please note that we may not control any Co-Branded Parties' use or treatment of information you provide to them and you should consult each of their privacy policies or any separate Co-Branded privacy policy posted on or linked from the Co-Branded site to determine your rights with respect to their use and treatment of your information. You will need to communicate with us and each Co-Branded Party directly, as applicable, if you decide you no longer wish to receive communications or if you wish to change any information you have supplied.

Legal Requirements

We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena, warrant, or other judicial or administrative order or otherwise required by law. Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of our Terms of Use; take precautions against liability; protect our rights, property, or safety, or those of a partner, any individual or the general public; maintain and protect the security and integrity of our Sites and Services or infrastructure; protect ourselves and our Sites and Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government regulatory agencies.

Change of Ownership

Information about our users, including Personal Information, may be disclosed as part of any actual or potential bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction. If a transaction occurs in which your Personal Information would be transferred to a third party, we will make reasonable efforts to notify you. For example, we will post a notice of the transfer of Personal Information on our Sites and Services and, if we have your email address, we will send notice of the transfer of Personal Information to that email address.

Interactive Features

If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through any of our Sites and Services, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any.  Therefore, you should avoid posting any personal information within such an interactive feature. To request removal of your personal information from our blog, sharing service or community forum, for example, contact us as provided for in this Policy. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

  1. How is your Personal Information secured by us?

Your personal information is stored on secure web servers that are protected against unauthorized access by third parties through reasonable methods. However, while we take efforts to ensure the integrity and security of our network and systems, we cannot absolutely guarantee that our security measures will prevent third-party "hackers" or other malfeasants from illegally obtaining this information.

Commercially reasonable physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your Personal Information, for example, encryption (SSL) of all information you send us when requesting a quotation online and user access controls designed to ensure that your Personal Information is accessible only by our designated employees and only for purposes intended by the submitter of the information. To protect the security of information exchanged with you, you will be provided with user names and passwords to access your information. All information that is exchanged while accessing your customer specific portion of our website is encrypted.

We may permit users with accounts on certain third party services, including but not limited to, social networking, search, sharing, and other services delivered by third-parties, to bypass the standard applicable registration process. If you connect through an authorized third party service, you will be able to use your third-party login information to log in to your Max2 account or access Max2 content, Sites and Services. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third-party services that may be triggered by using these third-party login services. Please review their terms of service and privacy policies carefully before using third party login functionality to access any Max2 Sites and Services.

By using any third-party services to log in to your Max2 account or access Max2 Sites and Services, you permit us to access, store and use all information related to your third-party account that may be accessible to us through the third-party service, including through its application programming interface (API), pursuant to this Policy.

  1. How do we respond to Internet browser "Do Not Track" requests?

We do not treat browsers sending "Do Not Track" signals any differently than those that do not. We use affiliates to support this website. Therefore, this website may not comply with "Do Not Track" settings on your browser.

  1. Can we change our Privacy Policy?

Yes, we may update this Policy from time to time. If we do, we will update the "effective date" at the top of the Policy. If we make material changes to how we use Personal Information, we will attempt to notify you of the change and to give you the opportunity to exercise choice as to how your Personal Information is used. We will post the updated Policy on the affected Sites and Service, and if we have your email address, we will send notice of the update to that email address.

We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information. Your continued use of our Sites and Services or any other content, products or other services covered by this Policy constitutes your agreement to this Policy and any updates.

  1. How do we treat information of children under 13?

The Sites and Services are not intended for children under the age of 18.  We take special care to protect the privacy needs of children under the age of 13 and encourage parents to be an active participant in their child's online activities. We abide by the requirements of the Children's Online Privacy Protection Act (COPPA) and other relevant laws. Our Sites and Services do not target and are not intended for children under the age of 13, and we will not knowingly collect any personal information from them. If we discover personal data from a child under 13 is gathered through our Sites or Services, then we will eliminate that data.

  1. How can you access the Personal Information you share with us?

If you want to review or verify Personal Information which you have provided to us you can contact us, per the contact information provided above, and we will respond to your request as soon as possible.   We may ask for information or documentation to authenticate your request.   There also may be instances where we will not be able to provide the Personal Information we hold about you, if compliance with your request is too costly, in our determination, to retrieve or where we cannot disclose the requested information for legal reasons. If we are unable to provide you with access to your Personal Information, then we will explain why compliance is not possible, when the explanations are legally permitted. If you wish to have your Personal Information deleted, we may not be able to completely honor your request due to applicable laws and regulations and the storage of the information within third party services.

  1. How can your Personal Information shared with us be kept accurate?

We take reasonable steps to maintain the accuracy of your Personal Information for as long as it is being used for the purposes set out in this Policy and you play an active role in keeping us up-to-date. Prompt notification of any changes, for example to your mailing address or telephone number, will help us provide you with the best possible service. Should you discover, upon review of your Personal Information, that amendments are required, please advise us.

  1. How do we treat information provided by customers outside of the United States?

Please note that our website is hosted in the United States. If you are using our website from outside the United States, by providing your information to us or through the Site or Services, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this Policy and our Terms of Use. You are also consenting to the application of United States law in all matters concerning our use of your information.

  1. How do we respond to California Civil Code Section 1798.83?

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Your Personal Information will not be shared with third parties for their direct marketing purposes. You can contact us per the contact information above to verify this and obtain further information.

  1. Do we guaranty error free performance of this Policy?

Max2 cannot guarantee error-free performance under this Privacy Policy. We will use reasonable efforts to comply with this Privacy Policy and will take prompt corrective action when we learn of any failure to comply with our Privacy Policy. Max2 will not be liable for any incidental, consequential or punitive damages relating to this Privacy Policy. This Privacy Policy will be governed by the laws of the State of New York and the United States, to the extent applicable.

Contacting Us:

If you have questions about this Privacy Policy, please feel free to contact us at:

Max2 Inc.

164 E. 83rd Street,

New York, New York 10028

Attention: General Counsel

privacy@max2.com

 

 

 

Max2 and Veea are trademarks of Max2 Inc.

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