veerio UG (haftungsbeschränkt) (“we,” “our,” or “us”) is a technology company that provides manufacturing industry and commercial businesses (“factory”) innovative user interfaces to provide data analytics and insights to enhance business performance and revenue streams. It does further provide localized insights and aggregated data from industries in emerging markets to public and private companies.
Our partners (“Partners”) are manufacturing industry and commercial businesses that have access to certain customer information (“User Data”) and their own information (“Partners Data”) that they wish to use to improve their business performance. Our services include data analytics, insight and data aggregation (“Services”) by using our product: (i) VEER.IO Charts Data Dashboard. You can learn more about our Services on our website at https://getveer.io/#j-technology.
Our clients (“Clients”) are private and public companies and institutions, including NGOs, International Organisations (IO, such as e.g. UN institutions), Companies (such as e.g. insurance companies, Fast-moving-consumer-goods manufacturers, media, academics, consultancies), and Government Institutions (e.g. Energy Ministries) that wish to have access to certain insights and aggregated data for successful project management, product design and implementation of interventions. By using our Services, our Clients may have access to (i) anonymised data and/or (ii) raw data and/or (ii) de-identified aggregated data sets helpful for statistical analyses, predictions, and insights for their own projects. These analyses can be descriptive in nature (e.g. estimates of averages of certainenergy indicators) or include inference (e.g. statistical comparisons of indicators across certain sub-groups). Analytical methods used to produce such estimates will be standard statistical approaches (e.g. regression analysis) or also borrow from modern data science methods (e.g. Machine Learning approaches such as random forests). Analyses will generally target industry level or aggregate level estimands, answering questions at those aggregate levels. A typical question would be: “On average, what industry characteristics of factories are associated with higher probabilities of being resilient to negative industry trends?”. We will also sometimes conduct longitudinal studies, i.e. studies in which certain users or partners are tracked over time. The objective of such analyses will be to identify trends of indicators over time and to see whether these are influenced by any outside factors – such as e.g. the implementation of a certain programme or policy.
Users of the Products can be either the Partners themselves or factory staff in representation of Partner (together also defined as “Customers”).
We work to ensure that our Services respect users’ privacy rights. To accomplish this goal, we adhere to privacy-by-design and privacy-by-default principles throughout the process of designing, building, and delivering our Services.
By law, we are required to provide you with information regarding: (i) how and on what legal basis we use and disclose your personal data; (ii) how we take care for your privacy rights specific to your personal data; (iii) how you can reach us in case you have any concerns regarding this privacy policy (“Policy”) or the way we are handling your data.
The terms of this Policy apply to all User Data and Partner Data to the extent it contains your personal data as defined in the applicable laws and regulations.
This Policy does not apply to information collected by our websites https://getveer.io and it’s subpages. For our website privacy policy, go to the “https://getveer.io/website-privacy-policy/” section.
This Policy also does not apply to information collected by other additional third parties who may provide information to us, as their information handling practices are covered by their own privacy policies.
The Policy’s wording can be technical; in case you have any questions, do not hesitate to write to privacy@getveer.io.
USER DATA AND PARTNER DATA THAT WE RECEIVE:
We receive the following categories of User Data and/or Partner Data from our Partners: (i) geographic information (such as e.g. geolocation, city, region, province) (“Geographic data”); (ii) economic information (such as e.g. production volumes, unit costs, energy spendings) (“Economic data”); (iii) technical data (such as e.g. amount of energy used) (“Technical data”) ; (iv) names, email addresses, and phone numbers (“Identity data”); (v) knowledge, attitudes, and practice (KAP) data on certain topics (such as e.g. knowledge, attitude, and practices of energy investments in a factory) (“KAP data”). In some instances, we might receive voice recordings (e.g. as answers to specific questions) or pictures of certain objects (e.g. power installations in the factory). We will also be requesting business and revenue information from Customers such as energy spendings, production volume and unit costs.
When we obtain different User Data and/or Partner Data, we aggregate them, and we enhance such User Data and/or Partner Data to create de-identified data segments or aggregate such segments into segment lists based on our Clients’ preferences. De-identified data refers to data from which any information that could be used to identify individuals or shops is removed or amended to such an extent that identification is not possible. This includes removal of “Identity data”, which means names, birth dates, addresses, and email addresses are removed. GPS location data will either be removed or modified to such an extent that it cannot be used to identify a specific location of a shop, associating it with aggregate administrative units (e.g. cities). We then share such lists with our Clients to enable them to effectively carry out their projects and interventions, including project monitoring and evaluation.
Below we describe the User Data and/or Partner Data categories in more detail.
(i) GEOGRAPHIC DATA
We may obtain information about the geographical location of factories and the point of installation of the VEER.IO hardware. This might include specific geolocation data collected via GPS technology (i.e. location measured in latitude and longitude). More commonly, this will include information on administrative areas a factory is located in (e.g. country, province, city, etc.) and on the addresses of a factory.
VEER.IO uses this data to aggregate information and estimates at the appropriate geographical and administrative level, such as for example estimating the average amount of electricity factories from a given industry purchase. Similarly, VEER.IO uses this information to compare estimates across geographic and administrative areas. Finally, VEER.IO uses geographical information in multivariate analyses to control for potential biases introduced by geographical factors.
(ii) ECONOMIC DATA
We may obtain information about the economic status of factories. This will include information about e.g. unit cost, energy payments, production volumes, infrastructure conditions.
VEER.IO uses this information to describe, at an aggregate level, the economic conditions of factories. It will also compare estimates of certain indicators across groups of factories that share similar conditions. Finally – as before – it will include this information in multivariate analyses.
(iII) TECHNICAL DATA
We obtain technical data from our Partners, such as the amount of energy consumed in certain periods of the day, local temperature levels, solar irradiation etc.
VEER.IO uses this information to e.g. describe industry trends, compare energy intensity across factories. Finally, VEER.IO analyses individual Partners’ data and feeds results back to them in order to help them improve their energy intensity and economic performance.
(iv) NAMES, EMAIL ADDRESSES AND PHONE NUMBERS (“Identity data”)
We may collect such information to identify Partners and Customers, and to potentially contact them via messages and emails. This data will not be used in analyses. This “Identity data” will also not be shared with our Clients.
Partners will be asked to provide: first and last name, phone number, GPS pin location, and (possibly) bank account details. Bank account details will be used to charge Partners for their Service Subscription.
(v) KNOWLEDGE, ATTITUDE, AND PRACTICES (“KAP DATA”)
We may ask Users and Partners about their knowledge of, views on, and behaviour with respect to certain issues that might be of interest to our Clients. For example, we might ask them about their interest in installing a Solar-PV system.
VEER.IO will use this data to report about the prevalence of certain KAP indicators and to compare these across different sub-groups of users. The results of such analyses will then be shared with Clients. In certain instances the KAP indicators form the basis for match-making between the Partners and Clients who might provide 3rd-party services to Partners.
(vi) SERVICE USAGE DATA
We use platforms that provides us with the following features: (i) information on how the users interact with our Service (such as, i.e. the first time an app is opened, the uninstalling of an app, updates, crashes or the frequency of use of the app are recorded); (ii) analytics reports based on such information. These data help us understand clearly how the Users behave while using our Service, so that we can make informed decisions regarding our Service features and performance optimizations.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
Our Services enable our Clients to access to certain insights and aggregated data for successful project management, product design, implementation of interventions, and Monitoring and Evaluation (M&E) activities. To achieve this goal, we need to process your personal data. We base the processing of your Personal Data on your consent.
We process your personal data if you have consented to the processing activity according to Article 6(1) lit. (a) of GDPR. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent but will not impact the lawfulness of processing based on your consent before it was withdrawn.
WITH WHOM DO WE SHARE USER DATA
We share User Data with the following categories of third parties: (i) our hosting provider; (ii) NGOs, (iv) companies, (v) International Organisations, (vi) Government Institutions.
NGOs we work with might include international NGOs such as for example OXFAM, CIFF, and the Bill and Melinda Gates Foundation.
Companies we work with might include international insurance companies or consultancies, media outlets, solar developers, industry intelligence brokers, academics and others.
International Organisations (IO) we work with might include those of the UN System (e.g. UNICEF), the World Bank, the European Union, and other IO working in International Development.
Government Institutions we work with might include ministries and other Government agencies, such as e.g. energy agencies, energy ministries, etc.
These third parties may only see the list of segments created based on User Data and/or Partner Data. Data are not shared in a way that individuals can be identified – which means that any ‘Identity Data’ and other data that allows to identify individuals (e.g. birth dates, names, etc.) will be removed from any lists shared. Where possible, only aggregated data will be shared with Clients. We will also disclose your User Data and/or Partner Data in response to valid legal processes, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements. We also may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. We are required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In addition, we may transfer your information to an entity or individual that acquires, buys, or merges with us, or our affiliates. In these cases, we will require the acquiring company to carry on the material terms of this Policy, including the requests for deletion.
WHEN WE TRANSFER USER DATA INTERNATIONALLY
When we share User Data and/or Partner Data with the recipients described above, such sharing may constitute a transfer outside of your factory location. By law, we are required to ensure that the level of protection guaranteed for your personal data by the European laws is not undermined by such transfer. We enter EU Standard Contractual Clauses with respective User Data and/or Partner Data recipients.
HOW WE PROTECT PERSONAL DATA
We take appropriate technical and organizational safeguards to protect any personal data we receive from theft, loss, and unauthorized access. We follow generally accepted standards to protect personal User Data and/or Partner Data throughout the entire use cycle starting from the initial transfer until deletion. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
Your personal data belongs to you. You have the following rights with respect to your personal data: (i) right to request confirmation as to whether or not we process any of your data, and, where that is the case, right of access to your data; (ii) right to request rectification of inaccurate personal data; (iii) right to request erasure of your personal data; (iv) right to restrict processing of your personal data if certain conditions are met, e.g., if you believe the personal data we hold about you is not accurate; (v) right to object to us processing your personal data; (vi) right to data portability, which only applies, however, if you provided us your personal data directly.
The options to exercise these rights are described below.
OPT-OUT OPTIONS
To make us erase your personal data associated with a User and/or a Partner from our system, Users and/or Partners can submit your request to our Privacy Team at privacy@getveer.io. We will delete all User Data and/or Partner Data associated with such request. Alternatively, at any time Users and/or Partner can access the Data Terminal and delete all the information previously provided and made available in their account.
In particular, Partners can submit a deletion request to our Privacy Team at privacy@getveer.io and/or delete their account and uninstall the VEER.IO Charts Data Dashboard.
The deletion request will be forwarded to all Clients that might have received access to the relevant Users Data.
Some data will remain stored in anonymised form in order to allow future analyses to be carried out. This means that we will remove all information that allows to personally identify individuals or households. This relates to the “Identity data” but also to any geographic, demographic and economic data that could reasonably be used for identification purposes. Names, birth dates, addresses, GPS locations, biometric information, will be removed.
Apart from all the above rights, you can also lodge a complaint with a supervisory authority if you believe we or our Partners infringed upon your rights.
INFORMATION RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.We retain data until the occurrence of the following events: (i) request from a Partner to delete certain User Data; or (ii) the User submits a deletion request of associated data; or (iii) expiration of VEER.IO defined retention period of:
- For each Partner: 24 months from the last usage of the VEER.IO Charts Data Dashboard.
- For each User: 24 months from the last data collection point. We might conduct longitudinal studies in which the same users will be asked to provide information about certain issues repeatedly over time. Generally, the pauses between such points in time will not be longer than 24 months. This means that we will get in touch with users within that time frame to ask them to provide information again. Hence, this data will generally not be stored beyond this time period after the last data collection point.
Some data might be stored for the purpose of future research without retaining any identifiable information. This means that we will remove any data that we consider to be data that can be used to identify individuals or households (e.g. names, birth dates, addresses, GPS locations, biometric information). The purpose of this is to ensure that future analyses can be conducted by referring back to longitudinal data as well – e.g. from a certain area. Where possible, we will store such information in aggregate form that will still allow to carry out key analyses.
CHILDREN’S PRIVACY
We do not knowingly collect data directly from children, the features of the Data Terminal are intended to prevent any use by children (i.e. the height of the Terminal shall be unreachable by users under the age of sixteen (16)).
We might collect data of children from their parents and, in such cases, we take additional steps to protect children privacy, including: (i) re-notifying parents about the types of information we may collect on their children and related usage; (ii) obtaining their explicit parental consent.
CONTACT
If you have any questions or suggestions about this Policy and our privacy practices, please contact us at: privacy@getveer.io
CHANGES TO THIS PRIVACY POLICY
VEER.IO may from time to time change this Policy or change, modify, or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, VEER.IO will post a notice advising of such change at the beginning of this Policy and on this site’s home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.