Privacy Policy

Last updated June 12, 2026

This Privacy Notice for Velocity Holding Company, LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at http://www.velocitycx.com or any website of ours that links to this Privacy Notice
• Use Velocity. Velocity provides promotional fulfillment and customer experience services to businesses, including consumer and performance incentive programs, rebate processing, gift card programs, digital marketing, sweepstakes promotions, and related analytics.

‍Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@velocitycx.com.

Summary of Key Points

What personal information do we process? We collect information or materials, when you respond to a promotional offer sponsored by one of our clients, such as your name, address, e-mail address, and product proof-of-purchase data. This information is collected and used for validation and processing of your promotional submission, for fulfillment of the rebate or other promotion program, and for customer service purposes. This information is required to validate, process and fulfill your submission (the “Services”). We will not disclose the information collected to third parties, but may disclose the information collected (i) to the Sponsor who is our client; (ii) if required by law, such as compliance with a subpoena, judicial order, or similar legal process, and (iii) if required to ensure the security of the promotions and/or our network and systems.

Do we process any sensitive personal information? We do not collect or process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at privacy@velocitycx.com or calling 800.953.3098. We will consider and act upon any request in accordance with applicable data protection laws.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you access the Services,  or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• phone numbers

• email addresses

• mailing addresses

• contact preferences

• contact or authentication data

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We may derive approximate geographic location (such as city or region) from your IP address for analytics purposes. We do not collect precise location data or GPS information.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the purposes listed in the Summary of Key Points above. 

3. What Legal Bases Do We Rely On To Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with the Services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information with (i) the Sponsor of the promotional program who is our client; (ii) if required by law, such as compliance with a subpoena, judicial order, or similar legal process, and (iii) if required to ensure the security of the promotions and/or our network and systems.

We may also need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Analytics Providers. We share information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We use Google Analytics, a web analytics service, to help us understand how visitors use our Services. Google Analytics collects information such as how often users visit the Services, what pages they visit, and what other sites they used prior to arriving. We use this information to improve our Services. Google Analytics collects only the IP address assigned to you on the date you visit, rather than your name or other identifying information.

You can opt out of cookies by setting your browser to refuse cookies or to alert you when cookies are being sent. Note that some parts of the Services may not function properly if you disable cookies. Specific information about how we use cookies and how you can manage your cookie preferences is set out in our Cookie Notice.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at privacy@velocitycx.com.

9. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at privacy@velocitycx.com.

10. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "What Information Do We Collect?"

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)

• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you may email us at privacy@velocitycx.com and include: your name; the email or mailing address you used with your promotional submission (if different from the one you are writing from); the right(s) you wish to exercise; and any additional information that may help us verify your identity. You may also call us at 800.953.3098 and request to submit a privacy rights request.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@velocitycx.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

12. Data Processor and Service Provider Role

In Short: We act in two separate capacities depending on how your personal information is collected — as a data controller for our own website, and as a data processor acting on behalf of our business clients for program-related data.

Velocity Holding Company, LLC operates in two distinct capacities with respect to personal information. When you visit our website or contact us directly, we act as a data controller, meaning we determine the purposes and means of processing your personal information as described in this Privacy Notice. When we administer incentive programs, rebate programs, gift card programs, or other promotional services on behalf of our business clients, we act as a data processor or service provider. In this capacity, we process personal information of program participants solely on behalf of and under the direction of the sponsoring client, who serves as the data controller for that information. Our processing of such data is governed by our agreements with those clients and applicable law. If you are a participant in a program administered by Velocity on behalf of a third-party client, you should also review that client’s privacy policy to understand how your information is controlled.

13. Program Participant Data

In Short: When you participate in a rebate, incentive, or gift card program we administer on behalf of one of our clients, we may collect additional personal information necessary to process and fulfill your participation.

In connection with our administration of promotional fulfillment programs on behalf of business clients, we may collect personal information from program participants including, but not limited to: full name, mailing address, email address, phone number, proof of purchase, product information, retailer information, and payment or banking information where required for reward fulfillment. This information is collected solely for the purposes of validating eligibility, processing claims, fulfilling rewards, preventing fraud, and complying with applicable legal requirements. The specific data collected will vary depending on the type and requirements of the individual program. This data is retained only for as long as necessary to fulfill the program and meet our legal obligations, after which it is deleted or anonymized in accordance with our data retention practices and client agreements.

14. Sharing Program Participant Data with Sponsoring Clients

In Short: Personal information collected in connection with a client-sponsored program may be shared with the sponsoring client.

When we collect personal information in connection with a promotional, rebate, incentive, or gift card program sponsored by one of our business clients, we may share that information with the sponsoring client as necessary to administer the program, fulfill rewards, resolve disputes, and satisfy reporting obligations under our client agreements. Such sharing is governed by contractual agreements between Velocity and the sponsoring client, which require the client to handle your personal information in accordance with applicable privacy laws. We do not sell program participant data to third parties, and we do not share such data with any party other than the sponsoring client and our authorized service providers except as required by law.

15. Do We Make Updates To This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at privacy@velocitycx.com or contact us by post at:

• Velocity Holding Company, LLC
• 10220 S 51st Street
• Suite 2
• Phoenix, AZ 85044
• United States

17. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at privacy@velocitycx.com or call us at 800.953.3098.

18. Your California Privacy Rights

In Short: California residents have the right to know, access, correct, delete, and opt out of the sale or sharing of their personal information, among other rights.

As a California resident, you have the following rights under the CCPA/CPRA. These rights are subject to certain conditions and exceptions as permitted by law.

Right to Know

You have the right to request that we disclose information about our collection, use, disclosure, and sale of your personal information over the preceding twelve (12) months, including:

• The categories of personal information we have collected about you
• The categories of sources from which the personal information was collected
• Our business or commercial purpose for collecting or selling your personal information
• The categories of third parties with whom we share your personal information
• The specific pieces of personal information we have collected about you

Right to Access

You have the right to request access to the personal information we have collected about you and to receive it in a portable, readily usable format that allows you to transmit the information to another entity.

Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes for which it is processed.

Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete your personal information from our records and direct our service providers to do the same, unless an exception applies.

We may deny a deletion request if retaining the information is necessary for us or our service providers to:

• Complete a transaction for which we collected the personal information or otherwise perform a contract with you
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
• Debug products to identify and repair errors
• Comply with a legal obligation
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it

Right to Opt Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information. As noted above, we do not sell or share personal information. If this changes in the future, we will update this page and provide a mechanism for you to opt out.

Right to Limit Use of Sensitive Personal Information

You have the right to direct us to limit the use and disclosure of sensitive personal information to only that which is necessary to perform the services or provide the goods you requested. We do not collect sensitive personal information as defined under the CCPA/CPRA.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, we will not:

• Deny you goods or services
• Charge you different prices or rates for goods or services
• Provide you a different level or quality of goods or services
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services