Legal

Terms of Use

These Terms of Use (“Terms”) set forth the terms and conditions that apply to your access and use of the payment receiving services (“Accounts Receivable Services”) as owned and operated by Veem Inc. (“Veem” formerly, Align Commerce Corporation), its subsidiaries and/or affiliates, and bill payment services (“Accounts Payable Services”) as owned and operated by Align Commerce Payments Inc. (“Align Payments”) a wholly-owned subsidiary of Veem, and/or its affiliates.  Veem and Align Payments are collectively referred to herein as “we,” “our,” or “us”.  Accounts Receivable Services and Accounts Payable Services are collectively the “Services”.

This is a legal agreement between us and the entity or person (“you,” “your,” or “user”) who registered for a User Account or is using the Services at veem.com. These Terms describe the terms and conditions that apply to your use of the Services.

You may use the Services only to receive and make payments for goods and services. By accessing or using the Services you agree to these Terms.

We may amend these Terms at any time by posting a revised version on our website. The revised version will be effective at the time we post it. In addition, if the revised version includes a substantial change, we will provide you with 30 Days’ prior notice of any substantial change by posting notice on our website.

Veem Inc. and Align Commerce Payments Inc. are located at 50 Osgood Place, Suite 220, San Francisco, California, 94133, U.S.A.

1. Relationship For the Services

1.1       Our Role.  Veem acts as an “agent of payee” meaning we provide Accounts Receivable Services to collect and transfer funds from a sender on behalf of a receiver of funds.  Align Payments is a licensed money transmitter in applicable states in the U.S.A. that provides Accounts Payable Services on behalf of a sender to make a payment to a receiver for goods and services.

Except for our limited role in processing or receiving payments that you authorize or initiate and transmit, we are not involved in any underlying transaction between you, any other user, or any service providers and you are solely responsible for resolving any disputes concerning any underlying transaction. We are not a bank and do not offer banking services. We may use the services of one or more third parties to provide the Services and process your transactions (each a “Processor”). We do not guarantee payment on behalf of any user. We are not a selling agent in connection with any sale or purchase by you of goods or services to any person.

1.2       Your Authorization.  As a sender using the Services, you authorize us to receive, hold and disburse funds in accordance with your payment instructions. Your authorization permits us to make an electronic transfer via Automated Clearing House network (“ACH”) from your bank account in the amount and currency you specify and send money electronically to a receiver’s bank account in the designated currency. Once you have provided your authorization for the transfer, you authorize and order us to commit your payment (less any applicable Pricing, foreign exchange, or other amounts we may collect under these Terms) to a receiver. You give us the right to resubmit any ACH debit you authorized that is returned for insufficient or uncollected funds.  You agree to allow us to recover any amounts due to us if there are insufficient funds in your bank account to cover your liability, and agree to reimburse us immediately, upon demand, through other means.  You agree to reimburse us for any fees imposed on us or costs we incur as a result of the transaction. Your liability under this Section extends to any of your guarantors, successors and assigns.

You also agree to be bound by any applicable rules of the National Automated Clearing House Association.  Your authorizations will remain in full force and effect while you maintain your User Account and for any registered bank account.

As a receiver using Accounts Receivable Services you agree that we will be your agent to collect and receive payments on your behalf for goods and services sold to your customers.  You further agree the sender’s obligation to pay you is fulfilled upon delivering funds to us as your agent.

1.3       Your Privacy.  Protecting your privacy is very important to us. You agree to our Privacy Policy which explains our commitment to maintaining your privacy, as well as our collection, use and disclosure of your Information.

1.4       Intellectual Property.  You acknowledge and agree that (i) all right, title and interest in the Services and associated software, website and technology, including all intellectual property rights therein, are and will remain with us or our third party licensors; (ii) no right or interest in the software or the Services is conveyed herein; and (iii) the software, website and the Services are protected by the copyright and other intellectual property laws. All rights not expressly granted in these Terms are reserved.

1.5       Password Security and Keeping Your Email and Address Current. You are responsible for maintaining adequate security and control of any and all IDs, passwords, or any other codes that you use to access your User Account and the Services. You are responsible for keeping your mailing address and email address up to date in your User Account.

1.6       Notices to You. You agree that we may provide you communications about your User Account and the Services electronically to the email address or by mail to the mailing address registered on your User Account.  Any electronic communications will be considered to be received by you within 24 hours after the time we post it to our website or email it to you. Any communications sent to you by postal mail will be considered received by you 3 Business Days after we send it.

1.7       Notices to Us. Notices to Veem or Align Payments must be sent by postal mail to:

Veem Inc.
Attention: Legal Department

50 Osgood Place, Suite 220

San Francisco, California, USA, 94133

1.8       Prohibited Businesses and Activities.  You may not use the Services for any activities we have identified as an unacceptable industry or business types and we do not allow users to send or receive payments for activities that:

• violate any law, statute, ordinance or regulation.

• relate to transactions that involve or support:

Internet pharmacies; internet pharmacy referral sites; nutraceuticals; pharmaceutical, inhalants; synthetic drugs; drugs or drug paraphernalia; prescription drugs; bestiality; rape/violence; bride catalogs; escort services; any payment for sexual services; trading of items or support of organizations that promote hate, violence, or racial intolerance; multi-level/affiliate marketing businesses; money making schemes; pawn shops; paper mills; payday loans; counterfeit goods; resale of social media activity; communications jammers; load balancing; malware; spyware; phone unlocking services; illegal downloads or any other goods and services infringing intellectual property rights (trademark, patent, copyright) of a third party; tobacco products; gambling; poker chips; firearms, ammunition, weapons, or knives; illegal or stolen goods or services.

(iii) are other business types we may choose not to service at its sole discretion.

You may not use the Services in or for the benefit of a country, organization, entity, or person embargoed or blocked by any government, including those on sanctions lists identified by the Office of Foreign Assets Control of the United States Department of the Treasury (“OFAC”).

2. User Account

2.1       Eligibility.  To be eligible to use the Services, you must be at least 18 years old and a resident of the United States or one of the countries on our Countries Service List. You may use the Services only to receive and make payments for goods and services. To send or receive payments using the Services, you must register for a User Account or send a payment as a Guest User pursuant to these Terms.  We may terminate your use of the Services at any time for any reason.

2.2       Registration.  To register for a User Account, you or the person or persons registering for a User Account (your “Representative”) must provide us with your business or trade name, address, email, phone number, tax identification number, URL, the nature of your business or activities, valid bank account information, and certain other information about you that we require. We may also collect personal information (including name, birthdate, and government-issued identification number) about you, your beneficial owners, principals, and your Representative. You agree to provide us with accurate and verifiable information about you and your business.  Federal law requires that we verify some of your information.  Until you have submitted, and we have reviewed and approved all required information, your User Account will be available to you on a preliminary basis only, and we may close, suspend, or limit access to your User Account and/or the Services in the event we are unable to obtain or verify your information or for any reason.  You must provide accurate and complete information in response to our questions, and keep that information current.

If you are a business, you confirm you are authorized to conduct business by the jurisdiction in which you operate and that you and your Representative are an authorized signatory for the business you represent.

2.3       Guest User.  We may allow for a guest use of the Services to make limited payments.  The amount of funds you can send as a guest user will be restricted based on a risk assessment.  Guest use requires you to provide information we will require to fulfill a transaction and comply with applicable laws.  You will be required to register for a User Account as your use increases.

2.4       Identity Authentication.  You authorize us, directly or through third parties, to make any inquiries we consider necessary to validate your and your company’s identity and information. This may include asking you for further information that will allow us to reasonably identify you, requiring you to take steps to confirm ownership of your email address or valid bank account, ordering a credit report, or verifying your information against third party databases or through other sources.

2.5       Continuing Validation.  At any time during your use of the Services, we may require additional information from you to verify beneficial ownership or control of the business, validate information you provided, verify you or your Representative’s identity, and assess the risk associated with your business. This additional information may include business invoices, copies of government-issued identification, business licenses, copies of bank statements, or other information related to your business, your beneficial owners or principals. Your failure to provide this information may result in suspension or termination of your User Account or placing a hold on your transaction.

2.6       Business Representative. You and your Representative individually affirm to us that you and your Representative are authorized to provide the information described in these Terms on your behalf and to bind you to these Terms. We may require you or your Representative to provide additional information or documentation demonstrating your Representative’s authority. Neither you nor your Representative may register or attempt to register for a User Account on behalf of a user previously terminated from use of the Services without our express written consent.

If you are a sole proprietor, you and your Representative also affirm that you and your Representative are personally responsible and liable for your use of the Services and your obligations under these Terms.

2.7       Changes to Your Information, Keeping your User Account Current: You agree to keep the information in your User Account current. You must promptly update your User Account with any changes affecting you, the nature of your payment activities, your Representative, beneficial owners, principals, or any other pertinent information. We may suspend or terminate your User Account or place a hold on your transaction if you fail to keep this information current.

2.8       User Account Activity. You may view your User Account activity at any time by logging into your User Account.  You are fully responsible for all activity that occurs under your User Account, including any actions taken by your Representative or other persons to whom you have granted access to your User Account.

2.9       User Account Suspension, Limitation or Termination.  You may close your User Account at any time. You will still be obligated to us for any fees incurred before the closure. We will remit any payments that you have committed to prior to account closer, but have not been processed and paid out after closure.  We may terminate your use of the Services at any time for any reason. Any termination of these Terms does not relieve you of obligations to pay Pricing or costs accrued prior to the termination and any other amounts owed to us as provided in these Terms.  We will not be liable to you for any losses that you incur in connection with our closure or suspension of your account.

3.1       Payment Purpose.  You warrant and represent that your use of the Services is solely to receive and make payments for goods and services as permitted under these Terms.

3.2       Payment Limits.  The amount of funds you can send or receive may be restricted based on a risk assessment and the amount of verification on your User Account. Your User profile will tell you what is required to increase your limits.  For questions, please contact Support at (877) 279-2629 or email [email protected].

3.3       Payment Review.  We review and monitor payment transactions for risk, fraud, money laundering and terrorist financing activity.  For certain potentially high-risk transactions, we will place a hold on the payment, conduct a review, may contact you for additional information, and either clear or cancel the payment.  In order to prevent financial loss to you or to us, we may place a delay on a payment for a period of time, refuse to process a payment, or deactivate your User Account. If we have reason to suspect that you are using the Services to violate local, state or federal laws, we may share information about you with law enforcement agencies.

3.4       Refused and Refunded Transactions. When you send money, the receiver is not required to accept it. You agree that you will not hold us liable for any damages resulting from a receiver’s decision not to accept a payment made through the Services. Any unclaimed, refunded or denied payment will be returned to your bank account. We will return any unclaimed payment to you within 30 Days of the date you initiated payment. To be eligible for a refund, a transaction must not have been fulfilled by any statutory refund timelines. You must submit a request for a refund in writing to [email protected].

3.5       Pricing.  We will provide the Services to you at the rates and for the fees described in the Pricing Schedule (“Pricing”), which is incorporated into these Terms by reference.  We charge a percentage ­on the value of the funds being transmitted.  The initiator of the transaction generally determines who pays the Pricing.  The Pricing is paid by either the sender or receiver.

3.6       Insufficient Funds and Reversals.  When you send or receive a payment, you are liable to us for the full amount of the payment plus any Pricing if the payment is later invalidated for any reason (e.g. insufficient funds from sender). This means that, in addition to any other liability, you will be responsible to us for the amount of the payment, plus the applicable Pricing if there is a reversal of the payment. You agree to allow us to recover any amounts due to us by debiting your bank account. If there are insufficient funds in your bank account to cover your liability, you agree to reimburse us immediately, upon demand, through other means.  You agree to reimburse us for any fees imposed on us or costs we incur as a result of the transaction. Your failure to fully pay amounts that you owe us on demand will be a breach of these Terms. You are liable for any of our costs associated with collection in addition to any amounts owed, including attorneys’ fees and expenses, collection agency fees, and any applicable interest. Your liability under this Section extends to any of your guarantors, successors and assigns.

3.7       Refund and Reversal Currencies. All refunds and reversals will be made in the same currency as the original transaction. If your transaction must be refunded or reversed and you do not have the correct currency available in your bank account, a currency conversion will be performed.

3.8       Payment Processing Delays.  We will use commercially reasonable efforts to process and facilitate your payment in accordance with these Terms and applicable law.  When you send a payment to a receiver, the payment is treated as authorization to process your payment and complete the transaction. Some receivers may delay claiming your payment, in which case the payment may be held as pending until the receiver claims your payment.  We will cancel the transaction within 30 Days of the date you initiated payment in accordance with Section 3.4.

3.9       Errors Regarding Payments.  It is your responsibility to review all payment transactions initiated through the Services. Your payment transaction information is maintained in your User Account and included in the receipts we provide you. All questions about transactions made through the Services must be directed to us either in writing to [email protected] or by calling us at (877) 279-2629.  We will rectify any of our processing errors that we discover. If the error results in a receiver’s receipt of less than the correct amount to which a receiver is entitled, we will credit their account for the difference. If the error results in their receipt of more than the correct amount to which a receiver is entitled, we will debit the extra funds from their account.

3.10     Unauthorized Transactions.  You are responsible for the security of your User Account and credentials which are used to make payments.  You should regularly log into your User Account and review the activity to ensure that there has not been an Unauthorized Transaction or other error. We will also send an email to the primary email address you provide to notify you of each transaction. You should also review these transaction confirmations to ensure that each transaction was authorized and is accurate.  When an Unauthorized Transaction occurs, we will work with you to address the issue as described below:

An “Unauthorized Transaction” is a type of error that occurs when payment is sent that the sender did not authorize and that did not benefit the sender.  Unauthorized Transactions that result from our processing error will be addressed as set forth in Section 3.9.  Other types of Unauthorized Transactions, or remedies will be addressed as follows:

Business Users:  We will work with you to provide information necessary for you to seek remedies that may be available to you through your financial institutions.

Consumer Users:  In some cases, users of our services are individuals that may be entitled to remedies under applicable laws.  To be eligible for such remedies, you must provide us with an Unauthorized Transaction Notice.

Unauthorized Transaction Notice Process:  No later than 60 days from the transaction date you made a “remittance payment” within the meaning of Regulation E, you must report an Unauthorized Transaction. We will seek to complete its review and take action on the Unauthorized Transaction Notice within 10 business days. Some claims will require documentation and associated time for response. We will resolve such issues within 45 days from the reporting date.

The Unauthorized Transaction Notice should be submitted to us through your User Account.  You may also contact [email protected].  We may seek additional information from you to address the issue in a timely and complete manner.

4. Changes to the Service

We will occasionally provide automatic upgrades to the Services and its functionality to improve your experience, although these upgrades may not be consistent across all platforms and devices. You agree to take no action to interfere with such automatic upgrades and changes to the Services.  We have the right at any time to change, modify, add to, discontinue or retire any aspect or feature of the Services including, but not limited to, the hours of availability, equipment needed for access or use, the maximum or minimum settlement amounts or the availability of the Services on any particular device or platform.  We have no obligation but will make a reasonable effort to provide you with notice of any such changes.

5. General Provisions

5.1       Indemnity.  Notwithstanding the foregoing or anything to the contrary in these Terms, you agree to defend, indemnify, and hold us harmless, and our respective employees, directors, agents, affiliates and our Processors (collectively, “Veem Parties”) from and against any claim, suit, demand, loss, liability, damage, action, or proceeding arising out of or relating to (a) your breach of any provision of these Terms; (b) your use of the Services; (c) your obligation to pay for Pricing or other amounts owing to us, or third parties; and (d) negligence or willful misconduct by you, your employees, contractors, agents or Representatives.

In addition, you will indemnify, defend, and hold Veem Parties harmless from and against any and all claims, costs, losses, damages, judgments, Taxes, penalties, interest, and expenses (including reasonable attorneys’ fees) arising out of any claim, action, audit, investigation, inquiry, or other proceeding instituted by a person or entity that arises out of or relates to any transaction submitted by you through the Services (including the accuracy of any content or product, service, or transaction information that you provide or any claim or dispute arising out of products or services offered or sold by you).

5.2       Limitation of Liability.  In no event will Veem Parties be liable for any lost profits, lost revenue, lost business opportunity, loss of data, or any indirect, punitive, incidental, special, consequential, or exemplary damages arising out of, in connection with, or relating to these Terms, or the Services, including without limitation the use of, inability to use, or unavailability of the Services. Under no circumstances will any of the Veem Parties be responsible for any damage, loss or injury resulting from hacking, tampering, or other unauthorized access or use of the Service or your User Account or the data contained therein, or your failure to use or implement security, controls, or processes that are appropriate for your business.

Veem Parties assume no liability or responsibility for any (a) personal injury or property damage, of any nature whatsoever, resulting from your access to or use of the Services; (b) any misuse of Services or data; (c) any interruption or cessation of transmission to or from the Services; (d) any software bugs, viruses, or other harmful code that may be transmitted to or through the Services; (e) any errors, inaccuracies, or omissions in the Services or data, or any loss or damage resulting therefrom, regardless of the manner of transmission; or (f) defamatory, offensive, or illegal conduct of any third party.

Without limiting anything to the contrary, the Veem Parties’ cumulative liability to you is limited to direct damages and in all events will not exceed in the aggregate amounts actually received by us (including any Pricing paid to us) for providing the Services to you during the three (3) month period immediately preceding the event that gives rise to the claim for liability.

This limitation of liability section applies regardless of the legal theory that the claim is based on, including without limitation contract, tort (including negligence), strict liability, or any other basis. The limitations apply even if we have been advised of the possibility of such damage.

The foregoing will apply to the fullest extent permitted by law.

5.3       No Warranty; Disclaimer.  THE SERVICES ARE PROVIDED “AS IS” AND WITHOUT ANY REPRESENTATION OF WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. VEEM, OUR PARENT AND AFFILIATES, AND THE OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS, EMPLOYEES AND SUPPLIERS OF VEEM, OUR PARENT OR OUR AFFILIATES, SPECIFICALLY DISCLAIM ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT.  We do not have any control over the products or services that are paid for with the Services and we cannot ensure that a payment sender or a receiver you are dealing with will actually complete the transaction or is authorized to do so. We do not guarantee continuous, uninterrupted or secure access to any part of the Services, and operation of our site may be interfered with by numerous factors outside of our control. We will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts are processed in a timely manner but we make no representations or warranties regarding the amount of time needed to complete processing because the Services are dependent upon many factors outside of our control, such as delays in the banking system or the U.S. or international mail service. Certain Services may not be available to you based on residency, geographic location or other eligibility criteria. Some states do not allow the disclaimer of implied warranties, so the foregoing disclaimers may not apply to you. This paragraph gives you specific legal rights and you may also have other legal rights that vary from state to state.

5.4       Entire Agreement.  These Terms and all policies and procedures that are incorporated by reference constitute the entire agreement between you and us for provision and use of the Services. Except where expressly stated otherwise in a writing executed between you and us, these Terms will prevail over any conflicting policy or agreement for the provision or use of the Services. These Terms sets forth your exclusive remedies with respect to the Services. If any provision or portion of these Terms is held to be invalid or unenforceable under law, then it will be reformed and interpreted to accomplish the objectives of such provision to the greatest extent possible, and all remaining provisions will continue in full force and effect.

5.5       Modification; Waiver.  In the event that we make material changes to these Terms, we will provide you with 30 Days’ prior notice by posting notice on our website.  You agree to the new-posted Terms by continuing your use of the Services. If you do not agree with the modified Terms, your sole remedy is to terminate your User Account and discontinue using the Service.  The waiver by either party of a breach of any provision hereof shall not be construed as a waiver of any succeeding breach of the same or any other provision, nor shall any delay or omission on the part of such party to avail itself of any right, power or privilege that it has or may have hereunder operate as a waiver of any right, power or privilege.

5.6       Applicable Law. You agree that, except to the extent inconsistent with or preempted by federal law and except as otherwise stated in these Terms, the laws of the State of California, without regard to principles of conflict of laws, will govern these Terms and any claim or dispute that has arisen or may arise between you and us.

5.7       Assignment. You may not transfer or assign any rights or obligations you have under these Terms without our prior written consent.  We reserve the right to transfer or assign these Terms or any right or obligation under these Terms at any time.  These Terms shall inure to the benefit of all permitted successors and assigns.

5.8       Force Majeure.  Neither we nor you will be liable for any delays in processing or other nonperformance caused by telecommunications, utility, failures, or equipment failures; labor strife, riots, war, or terrorist attacks; nonperformance of our vendors or suppliers, fires or acts of nature; or any other event over which we have no reasonable control. However, nothing in this section will affect or excuse your liabilities or your obligation to pay fees, reversals, or returns under this Agreement.

5.9       Taxes. You are responsible for determining any and all Taxes assessed, incurred, or required to be collected, paid, or withheld for any reason for your use of the Services (“Taxes”). You also are solely responsible for collecting, withholding, reporting, and remitting correct Taxes to the appropriate tax authority. We are not obligated to, nor will we determine whether Taxes apply, or calculate, collect, report, or remit any Taxes to any tax authority arising from any transaction. We specifically disclaim any liability for Taxes. If in a given calendar year, you process (i) more than $20,000 in gross amount of payments and (ii) more than 200 payments, we may be required by law to report information about you and your use of the Services to the Internal Revenue Service (“IRS”). For purposes of determining whether you have met the IRS reporting threshold, the gross amount does not include any adjustments for credits, cash equivalents, discount amounts, fees, refunded amounts or any other amounts. Whether you reach $20,000 in payments or more than 200 payments will be determined by looking at the taxpayer identification number (“TIN”) associated with your User Account, including the applicable social security number (“SSN”) or entity identification number (“EIN”).

5.10     Severability.  In the event that any provision contained herein shall for any reason be held invalid, illegal or unenforceable in any respect by a court of competent jurisdiction, to such extent such provision shall be deemed null and void and severed from these Terms, the remainder hereof shall remain in full force and effect and enforceable.

5.11     Independent Contractor.  We are an independent contractor for all purposes. Except as otherwise provided herein, neither we nor you have any right or authority to assume any obligations, or to make any representations or warranties, whether express or implied, on each other’s behalf, or to bind each other in any matter.

5.12     Survival. The following shall survive the termination of these Term: (i) all liabilities accrued under these Terms prior to the effective date of termination; (ii) all provisions that give rise to a party’s ongoing obligation; (iii) all provisions of Sections 1.2, 2.5, 2.8. 3.4, 3.6 and 5.1 through 5.14 of these Terms of Use; and (iv) any other terms which by their nature should survive.

5.13     Compliance with Laws.  You represent and warrant that you will comply (and will cause your employees, agents, and representatives to comply) with all laws applicable to your business and the Services.  Use of the Services is subject to all applicable laws and regulations regarding the prevention of terrorist financing and anti-money laundering. You agree and acknowledge that your use of the Services will comply with such laws and regulations, including, without limitation, the sanctions programs administered by the Office of Foreign Assets Control of the United States Department of the Treasury.

5.14     Contacting Us.  If you have questions concerning these Terms, you may contact us at [email protected] or at (877) 279-2629.

Last Updated:  March 6, 2017

Privacy Policy

This Privacy Policy describes the information Veem Inc. (formerly, Align Commerce Corporation) and our affiliates collect when a person or business (“you,” “your”) applies or signs up for an Veem account; accesses or uses any Veem application, product, service, feature, technology, content, or website (collectively, “Services”).  In this Privacy Policy we use the terms “Veem,” “us,” “we” and “our” to refer to Veem Inc. and its affiliates.

Scope and Consent

You accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy (including to contact you), and for all other purposes permitted under applicable personal information privacy statutes, credit bureau reporting rules, anti-spam legislation, and consumer protection laws.

Collection of Information

We collect information about you to deliver Services.  Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information about children under the age of 13.

Information You Provide

We collect information you provide when you apply or sign up for a Veem account or use Veem Services and when you provide information as part of our identity or account verification process. We may collect information about you, including but not limited to:

• Identification information, such as your name, email address, mailing address, phone number, photograph, birthdate, passport, driver’s license, Social Security, Taxpayer Identification, or other government-issued identification number;
• Financial information, including bank account and payment card numbers;
• Tax information, including withholding allowances and tax filing status; and
• Other historical, contact, and demographic information.

We also collect information you upload to or send through our Services, including but not limited to:

• Information about products and services you purchase or sell;
• Information you provide about you or your authorized users, representatives or beneficial owners; and
• Information you provide to counterparties using our Services, for example, invoice information).

Some of the information we collect is collected to comply with laws and regulations, including anti-money laundering and anti-terrorist financing laws.

Information We Collect from Your Use of our Services

We collect information about you when you use our Services, including but not limited to:

• Device Information. We may collect specific information about the computer or mobile device (“device”) when you access our Services, including your hardware model, operating system and version, unique device identifier, mobile network information, and information about the device’s interaction with our Services. We may also identify other software running on the device for anti-fraud and malware-prevention purposes, but we will not collect any content from such software.
• Location Information. Through our applications, we may collect information about the location of your device.
  • Use Information. We collect information about how you use our Services, including your access time, browser type and language, and Internet Protocol (“IP”) address.
    • Transaction Information. When you use our Services to make, accept, request or record payments or money transfers, we may collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.
  • Information Collected by Cookies and Web Beacons. We use various technologies to collect information when you use our Services, including sending cookies to your device and using web beacons. Cookies are small data files that are stored on your hard drive or in your device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. For more information and to learn how to block or delete cookies used in the Services, please see “Your Choices” below. We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, track the number of visits to our website, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.

Information We Collect from Other Sources

We may also collect information about you from third parties, including third-party verification services, credit bureaus, mailing list providers, and publicly available sources. In some circumstances, where lawful, this information may include your government-issued identification number. By applying or signing up for an Veem account, you authorize and consent to our obtaining from, and disclosing to, third parties, from time to time, any information about you in connection with the processing of any credit investigation, identity or account verification, fraud detection, or collection procedure, or as may otherwise be required by applicable law. This includes, where lawful, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau.

We use Plaid Technologies, Inc. (“Plaid”) to gather information about you from financial institutions.  By using our Services, you grant us and Plaid the right, power and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution.  You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy located at https://plaid.com/legal.

Third-Party Advertising and Analytics

We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services. These third parties may use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Services, webpages viewed, time spent on webpages, links clicked, and conversion information (e.g., transactions entered into). This information may be used by Veem and third-party service providers on behalf of Veem to analyze and track usage of our Services, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand how you use our Services. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.

Use of Information

We may use information about you to provide, maintain, and improve our Services, such as:

• Processing or recording payment transactions;
• Displaying historical transaction information;
• Developing new products and Services; and
• Delivering the information and support you request.

We may use information about you to improve, personalize and facilitate your use of our Services. We also may use information about you to measure, customize, and enhance our Services, including the design, content, and functionality of our applications and websites, or to track and analyze trends and usage in connection with our Services.

We may use information you provide to connect you with people you already know. For example, you may upload contact information from your address book or accounting software.  We will use that information to help make transactions easier to initiate or fulfill.

We may use information about you to send you news and information, or to conduct surveys and collect feedback, about our Services and to communicate with you about products, services, contests, promotions, discounts, incentives, and rewards offered by us and select partners, based on your communication preferences and applicable law. We also may contact you to resolve disputes, collect fees, and provide assistance for problems with our Services or your Veem account.

We may use information about you:

• To protect our rights or property, or the security or integrity of our Services;
• To enforce the terms of our Terms of Use or other applicable agreements or policies;
• To verify your identity (e.g., some of the government-issued identification numbers we collect are used for this purpose);
• To investigate, detect, and prevent fraud, security breaches, and other potentially prohibited or illegal activities;
• To comply with any applicable law, regulation, legal process, or governmental request;
• For any other purpose disclosed to you in connection with our Services.

We may use third-party service providers to, process and store your information in the United States and other countries.

Sharing of Information

We may share information about you as follows:

• With our group companies and other affiliates for the purposes outlined above;
• With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, and other entities in connection with the payment or money transfer process;
• With third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services;
• With other users of our Services with whom you interact through your own use of our Services. For example, we may share information when you make or accept a payment using our Services;
• In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business; or
• If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce or comply with the terms of our Terms of Use or other applicable agreements or policies, (iii) to protect our rights or property, or the security or integrity of our Services, or (iv) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities.

We also may share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

Your Choices

Personal Information

You may access, change, or correct information about you by logging into your Veem account at any time by contacting us.  We may need to verify your identity before granting access or otherwise changing or correcting your information.

Deactivating Your Account

You may deactivate your Veem account by logging into your Veem account or by emailing us using the contact details provided below.  We may retain archived copies of information about you and any transactions or Services you used for a period of time that we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Use or other policies, or to take any other actions consistent with applicable law.

Cookies

When you access or use the Services, to help make your experience simpler, our web server may send a cookie to your device. Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and, as such, will last longer.

We may use cookies to:

• Remember that you have visited us or used the Services before.
• Customize elements of content of our website or application for your experience.
• Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set.

You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. We currently do not respond to DNT signals. We may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

Promotional Communications

You may opt out of receiving promotional messages from Veem by following the instructions in those messages or by changing your notification settings by logging into your Veem account. If you decide to opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

California Privacy Rights

California law permits residents of California to request certain details about information we disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us at the address listed below.

Security

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you at our own premises and with the assistance of third-party service providers. We restrict access to personal information to those Veem employees, contractors, and agents who need to know that information in order to transmit, store, or process it, who are subject to contractual confidentiality obligations consistent with this Privacy Policy, and who may be disciplined or terminated if they fail to meet these obligations. Our third-party service providers store and transmit personal information in compliance with this Privacy Policy and other appropriate confidentiality and security measures.

Nevertheless, Veem cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. If information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

Amendment

We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last updated” date below. The revised version will be effective at the time we post it. We will provide you with reasonable prior notice of substantial changes in how we use your information, including by email at the email address you provide. Where these changes would cause material detriment to you, you may of course cancel your account at any time. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you and to contact us if you have any questions about these changes. Your continued use of our Services constitutes your acceptance of any amendment of this Privacy Policy.

Contact

If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our Compliance Department and we will respond to let you know who will be handling your matter. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.

Veem Inc.

50 Osgood Place, Suite 220

San Francisco, CA 94133, U.S.A.

[email protected]

Last updated: March 6, 2017

Introduction

Veem is committed to Anti-Money Laundering (AML) compliance and Anti-Terrorist Financing and has built policy, procedures and reporting to prohibit use of Veem system for such activities.

In support of our AML and Anti-TF policy and procedures Align Commerce must:

• – Identify our customers (KYC): Customer information is collected during registration and during transactions. Based on the risk, Veem will ensure that it has a reasonable belief of the true identity of our customers. In verifying customer Veem will perform enhanced due diligence for those customers presenting higher risk and may require additional information such as photo identification.

• – Monitoring transactions and activity: Veem has a risk based system and procedures to monitor on-going customer activity to detect fraud as well as money laundering activities including but not limited to placement, layering and integration of funds.

• – Reporting: Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate.

Veem is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Veem will therefore screen against European Union, US Office of Foreign Assets Control (OFAC) and other global sanctions lists in all jurisdictions in which we operate.