Privacy Policy

Last Modified: April 11th, 2015

This privacy policy describes the treatment of information provided or collected on the site where this privacy policy is posted. It also explains the treatment of information provided or collected on applications we make available on third-party sites or platforms if disclosed to you in connection with use of the application. We follow this privacy policy in accordance with local law in the places where we operate.

Types of Information We Collect

We collect two types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of information, aggregate information. We collect the following categories of information:

  • Registration information you provide when you create an account, including your first name and surname, country of residence, gender, date of birth, email address, username and password
  • Transaction information you provide when you request information or purchase a product or service from us, whether on our sites or through our applications, including your postal address, telephone number and payment information
  • Information you provide to us when you use our site, access our accounts on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your registration account

How We Collect Your Information

  • We collect information you provide to us when you request products, services or information from us, register with us, participate in activities on our site, respond to customer surveys, or otherwise interact with us. Please keep in mind that when you provide information to us on a third-party site or platform (for example, via social media), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.

Use of Your Information by Veena

Data collected will be used for the following purposes:

  • Provide you with the products and services you request
  • Communicate with you about your account or transactions with us and send you information about features on our site or changes to our policies
  • Consistent with local law and choices and controls that may be available to you:
    • Send you offers and promotions for our products and services
    • Personalize content and experiences on our site
  • Optimize or improve our products, services and operations
  • Detect, investigate and prevent activities that may violate our policies or be illegal

Sharing Your Information with Other Companies

We will not share your personal information information outside of Veena, except in limited circumstances, including:

  • When you allow us to share your personal information with another company, such as:
    • Directing us to share your personal information with third-party sites or platforms, such as social networking sites

Please note that once we share your personal information with another company, the information received by the other company becomes subject to the other company’s privacy practices.

  • When companies perform services on our behalf, like package delivery and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law

Your Controls and Choices

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with local law, your controls and choices  may include:

  • You may correct, update and delete your registration account
  • You may change your choices for subscriptions, newsletters and alerts
  • You may choose whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you
  • You may request access to the personal information we hold about you and that we amend or delete it and we request third parties with whom we have shared the information do the same

You may exercise your controls and choices, or request access to your personal information, by visiting contact us and emailing your requests. Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you. If you have questions regarding the specific personal information about you that we process or retain, please contact us by email.

Children’s Privacy

We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our site. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

  • Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information
  • In accordance with applicable law, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children
  • Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity
  • Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted

For additional information about our practices regarding children’s personal information, please read our Children’s Privacy Policy.

Children’s Privacy Policy

The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents

Veena offers to its users a range of activities, which are primarily targeted at children. Our site offers a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from  a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

Registration

Children can register with our site to view content, participate in contests and engage in special features. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first and last name and gender and the child’s email address. We also may ask for birth dates from children to validate their ages. We strongly advise children never to provide any personal information in their usernames. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.

About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us via email. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.

Content Generated by a Child

Certain activities on our site and applications allow children to create or manipulate content and save it with Veena. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, Veena plans to post the content publicly we will obtain a higher level of parental consent.

About Verifiable Parental Consent:

Email Consent. In the event Veena wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.

High-Level Consent. In the event Veena collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax.

Contests

For contests, we typically require only the information necessary for a child to participate. We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest.

Of course, some contests ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission. Please see Content Generated by a Child above for more information on our collection, notice and consent policies.

Email Contact with a Child

In order to verify accounts created and to respond to a question or request from a child, Veena will need to ask for the child’s online contact information, such as an email address. Veena will not contact the child directly for the purpose of advertising products. In addition this online contact information will only be retained while the child’s account remains open and only for the purpose of contests available on the Veena site. Children’s online contact information will not be shared with any third-party groups.

In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about site contests. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication and a parent may be required to “opt-out” of each communication individually.

Please contact us through our contact form with questions about the operators’ privacy policies and collection and use practices:

When Information Collected From Children Is Available To Others

In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:

We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

Parental Choices and Controls

At any time, parents can refuse to permit us to collect further personal information from the child we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. Where a child has registered for an account, the method to allow parents to access, change, or delete the personally identifiable information that we have collected from their children is: Parents can request access to and delete their child’s personal information by logging on to the child’s account through the Veena site. Parents will need their child’s username and password.

Data Security, Integrity and Retention

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

Changes to this Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are made and, where required by applicable law, we will obtain your consent.

Comments and Questions

If you have a comment or question about this privacy policy, please contact us via email. Our site may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications to read the privacy policies of other sites that may collect your personal information.

California Residents: If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Veena to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content.

Definitions

Aggregate Information. Aggregate information means information about groups or categories of guests, which does not identify and cannot reasonably be used to identify an individual guest.

Anonymous Information. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify an individual guest.

Application. Application means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile or other platforms and environments, including those operated by third parties, which permits us to interact directly with our guests.

Children. Children means individuals who we have identified are not of legal age to consent to the collection and processing of their personal information. In the United States and Latin America, the term “children” refers to individuals under 13 years of age.

Notice. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

Parents. Parents means a parent or legal guardian.

Personal information. Personal information means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address and telephone number. When anonymous information is directly or indirectly associated with personal information, this anonymous information also is treated as personal information.