Velvet Media Privacy Policy

Velvet Media, Inc (“Velvet,” “we”, “us” or “our”) provides a platform through which video creators (“Creators”) create and deliver custom-made videos (“Task Submission”) for the purposes of third-party AI companies training artificial intelligence (“AI”) models. This Privacy Policy describes how Velvet Media, Inc processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy (including as applicable, our website located at https://velvet.video/ and social media pages and electronic communications) as well as our marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”).

This Privacy Policy applies to both our account holders and other individuals who appear in videos submitted by our account holders.

This Privacy Policy does not apply to information that we process on behalf of our business customers (such as AI companies) while providing services to them. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of our business customer, please direct your concerns to that customer with which you have a relationship.

See U.S. State Privacy Rights Notice at Collection section of this Privacy Policy for additional information if you are a U.S. resident.

This Privacy Policy does not apply to our employees or independent contractors or job candidates.

This Privacy Policy does not apply to representatives of businesses with which we have a business relationship.

Index

• Personal information we collect
• Tracking technologies
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfers
• Children and teens
• Changes to this Privacy Policy
• How to contact us
• U.S. State Privacy Rights Notice At Collection

Personal information we collect

Information you provide to us

Personal information you may provide to us through the Service includes:

• Contact data, such as your first and last name, alias, signature, salutation, email address, billing and mailing addresses, and phone number.
• Profile data, such as account name, the username and password that you may set to establish an online account on the Service, your Task Submissions, and any other information that you add to your account profile.
• Transactional data, such as information relating to or needed to complete your Task Submissions on or through the Service, including number of videos uploaded and transaction history.
• Payment data needed to complete transactions, including payment card information is directly collected from our third-party payment vendor, Stripe, as described further below. If you receive payments through the platform, you may be required to enter your bank account information directly within your account on our platform in order to facilitate payouts via our third-party payment provider, Wise.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated video/audio content data, such as when Creators film and upload videos or clips as part of “Task Submissions.” We collect the video files, associated metadata (e.g. tags, labels, descriptions, time, location if applicable, angle, orientation, and any other content or information that you generate, transmit, or otherwise make available on the Service, including associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Sensitive Personal Information, such as racial or ethnic origin.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

DATA ABOUT OTHERS. IF YOUR VIDEO INCLUDES OTHER PEOPLE — FOR EXAMPLE, THEIR FACES, VOICES, OR ANY PERSONAL INFORMATION — PLEASE MAKE SURE YOU HAVE THEIR PERMISSION BEFORE UPLOADING IT TO VELVET. YOU ARE RESPONSIBLE FOR ENSURING THAT ANYONE WHO APPEARS IN YOUR CONTENT HAS AGREED TO BE RECORDED AND TO HAVE THEIR VIDEO SHARED ON OUR PLATFORM.

Third-party sources

We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as public records, social media platforms, and other publicly available sources.

Automatic data collection

We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Location data when you authorize the Service to access your device’s location.
• Communication interaction data such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
• Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Tracking technologies

Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, credentials, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a web browser session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our service providers and other third parties place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed, clicked or forwarded.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time we collect personal information from you:

Service delivery and operations

We may use your personal information to:

• provide and operate the Service (e.g., enable video uploads);
• process your requests, Task Submissions and transactions;
• enable security features of the Service;
• personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• establish and maintain your user profile on the Service;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, user-to-user communications, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications;
• provide support for the Service, and respond to your requests, questions and feedback; and
• fraud prevention and security.

Research and development

We may use your personal information (including Task Submissions) for research and development purposes, including to develop, analyze and improve our products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information. We may use this anonymous or de-identified data and share it with third parties for any lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Marketing

We may collect and use your personal information to send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section.

Compliance and protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent

In some cases, we may specifically ask for your consent to collect, use, or share your personal information for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected.

Cookies and similar technologies

In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including the volume and demographics of users, which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout.

Data sharing in the context of corporate transactions

We may share certain personal information in the context of actual or prospective corporate transactions – for more information, see How we share your personal information, below.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as cloud hosting providers, internet service providers, information technology, customer support, email delivery, marketing, consumer research and website/data analytics).
• Affiliates. In some cases, our corporate parent, subsidiaries, and affiliates might have access to personal information.
• Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account on the third-party service.
• Sponsor Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe may use your payment data in accordance with its privacy policy, available at https://stripe.com/privacy. If you receive payments through the Service, your bank account information may be collected and processed in connection with facilitating payouts via our third-party payment provider, Wise. Wise may process your payment information in accordance with its privacy policy, available at https://wise.com/privacy-policy.
• Third-party AI companies. We may share your personal information with third parties where you have instructed us or provided your consent to do so. Creators’ Task Submissions may be made available to AI companies. When licensing, we may provide relevant metadata (e.g. tags, descriptions, device/angle info) as part of the data offering. These third parties may use Task Submissions to train AI.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Velvet, financing of Velvet, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Velvet or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the choices available to you.

• Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.
• Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.
• Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.
• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children and Teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

How to contact us

Email: support@velvet.video

U.S. State Privacy Rights Notice At Collection

Except as otherwise provided, this section applies to residents of Colorado and Connecticut and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (together the “State Privacy Laws”).

This State Privacy Rights Notice At Collection is part of our full Privacy Policy.

This section describes how we collect, retain, use, disclose, sell and share for the purposes of targeted advertising personal information of residents of these states and the rights these users may have with respect to their personal information. Please note that not all rights listed below may be afforded to all individuals and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term “personal information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device.

We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Your privacy rights

You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law. We may decline to honor your request where an exception applies.

Right to know

You can request to know whether we process your personal information.

You can request the following information about how we have collected and used your personal information during the past 12 months and how we will continue to do so:

• The categories of personal information that we have collected.
• The categories of sources from which we collected personal information.
• The business or commercial purpose for collecting, selling, and/or sharing personal information for targeted advertising purposes.
• The categories of personal information that we sold or shared for targeted advertising purposes, and the categories of third parties to whom this information was sold or shared, categorized by the type of personal information for each type of third party.
• The categories of personal information that we disclosed for business purposes and the types of entities to whom this information was disclosed.
• The specific third parties to which we have disclosed personal information.

Access. You can request a portable copy or representative summary of the personal information that we have collected about you.

Correction. You can ask us to correct inaccurate personal information that we have collected about you.

Deletion. You can ask us to delete the personal information that we have collected from or about you.

Revoke consent. You may have the right to revoke your consent to our processing of your personal information.

Opt-out

• Opt-out of targeted advertising. We do not process your personal information for targeted advertising purposes.
• Opt-out of sale of your Personal Information. We do not sell your personal information without your instruction.

We do not “share” or otherwise process personal information (including Sensitive Personal Information) for purposes of cross-context behavioral or targeted advertising, as defined under applicable law. We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated. We do not sell or “share”/knowingly sell or “share” personal information (including Sensitive Personal Information) of minors under 18 years of age.

Automated decision making

We do not use your personal information to engage in automated processing or profiling personal information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.

Sensitive Personal Information

We license Sensitive Personal Information to third-party AI companies for the purpose of training AI models if you instruct us to do so or if you provide your explicit consent. You may withdraw your consent at any time by contacting us as described below.

Residents outside California: Sensitive Personal Information. You can opt-out of our processing your Sensitive Personal Information by electing not to provide it to us or by notifying us of your opt-out.

Nondiscrimination

You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Appeal

You can appeal our denial of any request validly submitted.

Exercising your right to know, access, correction, deletion, and appeal and limiting processing of Sensitive Personal Information

You may submit requests at this webform, calling us toll free at 1-510-214-3469, or via email to support@velvet.video.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Exercising your right to opt-out of/revoke your consent to the “sale” of your personal information

You can submit requests to opt-out of the sale of personal information here, via email to support@velvet.video.

Verification of Identity; Authorized agents

We may need to verify your identity to process your know, access, correction, deletion, or appeal requests and reserve the right to confirm your residency. We may need to request your location, government-issued ID (such as driver’s license or passport), or other reasonable information otherwise requested through Stripe’s verification system, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to reauthenticate yourself before disclosing or deleting your personal information. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose

We have summarized the personal information we collect and may disclose, sell to or share with third parties by reference below to both the categories of personal information defined in the “Personal Information we collect,” “How we use your personal information,” and “How we share your personal information” sections of this Policy above and the categories of personal information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

See our full Privacy Policy for descriptions of each entry in this table.

Additional State-Specific Information

Consumers under 18. We do not have actual knowledge that we have collected, sold, or shared the personal information of residents who are under 18 years of age.

Additional information for Texas residents. NOTICE: We may sell your sensitive personal data, as defined by the Texas Data Privacy and Security Act.

Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale, as defined, of certain personal information for monetary consideration. If you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email support@velvet.video.

Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

Additional information for Connecticut residents. We collect, use, or sell personal data for the purpose of training large language models (“LLMs”).

Contact Us

If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.