Privacy Policy

Introduction

Verlo is a B2B software platform that uses AI to help financial advisors capture meeting notes, answer questions about clients, and draft follow-up communications.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes Verlo's policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights.

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

Data Protection Officer

Verlo is headquartered in St. John's, NL, in Canada. Verlo has appointed an internal data protection officer for you to contact if you have any questions or concerns about Verlo's personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Verlo's data protection officer.

Verlo's data protection officer's name and contact information are as follows:

How we collect and use (process) your personal information

Verlo collects personal information about its website visitors and customers. With a few exceptions, this information is generally limited to:

• name
• job title
• employer name
• work address
• work email
• work phone number

We use this information to provide prospects and customers with services. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.

From time to time, Verlo receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third party website (e.g. LinkedIn).

Google user data

This section applies to the data that Verlo receives from your Google Account when you connect Gmail, Google Calendar, or Google Drive to Verlo. We call this data “Google user data”. This section adds to the rest of this Privacy Notice. If any other part of this notice disagrees with this section, this section applies.

What we access, and why

You choose whether to connect a Google Account. If you connect one, Verlo asks only for these permissions:

• See your email messages and settings — to show your email history with a client on that client’s record, and to let the Verlo assistant answer your questions about a client from those emails.
• Send email on your behalf — to send a follow-up email that you wrote or approved in Verlo.
• View events on your calendars — to show your upcoming meetings, and to send the Verlo notetaker to the meetings that you select.
• See and download your Google Drive files — to import the client documents in the folders that you select, so that you can search them and ask questions about them in Verlo.

You can disconnect a Google Account at any time in Verlo, in Settings › Integrations. You can also remove Verlo’s access from your Google Account permissions page at myaccount.google.com/permissions.

How we use it: Limited Use

Verlo’s use of information received from Google APIs follows the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• We use Google user data only to provide and improve the Verlo features described above. We use it for no other purpose.
• We do not sell Google user data. We do not transfer it to any third party, except: to the service providers that operate the features described above, acting on our instructions; for security purposes, such as investigating abuse; to comply with applicable law; or as part of a merger, acquisition, or sale of assets, after we get your explicit prior consent.
• We do not use Google user data for advertising of any kind. This includes ads, retargeting, and personalized or interest-based advertising.
• We do not let people read your Google user data, except: when you give us explicit consent, for example when you ask our support team to examine a specific message or file; when it is necessary for security; or when the law requires it.
• We do not use Google user data to create, train, or improve any generalized artificial intelligence or machine learning model. Verlo sends your data to AI models to answer your requests in the application. Our AI providers are contractually prohibited from training their models on your data.

How long we keep it

We keep Google user data only while the Google Account stays connected and your organization uses Verlo. When you disconnect the account, we stop collecting new data and we delete the stored copy within 30 days. You can ask us to delete it sooner at any time.

Use of the Verlo Website

As is true of most other websites, Verlo's website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of Verlo's website, including a history of the pages you view.

We use this information to help us design our site to better suit our users' needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Verlo has a legitimate interest in understanding how members, customers and potential customers use its website. This assists Verlo with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet member and customer needs.

Cookies and tracking technologies

Verlo makes available a comprehensive Cookie Policy that describes the cookies and tracking technologies used on Verlo website and provides information on how users can accept or reject them.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these email. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Sharing information with third parties

The personal information Verlo collects from you is stored in one or more databases hosted by third parties. By default, this data is hosted in the United States. For customers located in Canada, data is hosted in Canada. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, Verlo engages third parties to send information to you, including information about our products, services, and events.

A current list of Verlo's third party sub-processors is maintained in our Trust Center.

We do not otherwise reveal your personal data to non-Verlo persons or businesses for their independent use unless:

• you request or authorize it;
• it's in connection with Verlo-hosted and Verlo co-sponsored conferences as described above;
• the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others;
• the information is provided to our agents, vendors or service providers who perform functions on our behalf;
• to address emergencies or acts of God; or
• to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.

We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

The Verlo website connects with third party services such as Facebook, LinkedIn, Twitter and others. If you choose to share information from the Verlo website through these services, you should review the privacy policy of that service. If you are a member of a third party service, the aforementioned connections may allow that service to connect your visit to our site to your personal data.

International transfers of personal data

Verlo has its headquarters in Canada, and the information we collect about you is processed and stored in the United States by default. For customers located in Canada, data is stored in Canada. By using Verlo's services, you acknowledge that your personal information will be processed in the United States or in Canada, and that it may be accessed by Verlo personnel in Canada in the course of operating and supporting our services.

The United States has not received a general finding of "adequacy" from the European Commission under Article 45 of the GDPR. Canada has received a partial finding of adequacy covering commercial organizations subject to PIPEDA. Pursuant to Article 46 of the GDPR, Verlo is providing for appropriate safeguards for transfers out of the EEA and the UK by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.

Depending on the circumstance, Verlo also collects and transfers personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Verlo in a manner that does not outweigh your rights and freedoms. Verlo endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Verlo and the practices described in this Privacy Statement. Verlo also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate.

Since it was founded, Verlo has received zero government requests for information. For more information or if you have any questions, please contact us at brent@retellio.com

Data Subject rights

The European Union's General Data Protection Regulation (GDPR) and other countries' privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right of data portability
• Right to object
• Rights related to automated decision making including profiling

This Privacy Notice is intended to provide you with information about what personal data Verlo collects about you and how it is used. If you wish to confirm that Verlo is processing your personal data, or to have access to the personal data Verlo may have about you, please contact us.

You may also request information about:

• the purpose of the processing;
• the categories of personal data concerned;
• who else outside Verlo might have received the data from Verlo;
• what the source of the information was (if you didn't provide it directly to Verlo); and
• how long it will be stored.

You have a right to correct (rectify) the record of your personal data maintained by Verlo if it is inaccurate. You may request that Verlo erase that data or cease processing it, subject to certain exceptions. You may also request that Verlo cease using your data for direct marketing purposes.

In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Verlo processes your personal data. When technically feasible, Verlo will, at your request, provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Verlo will provide you with a date when the information will be provided. If for some reason access is denied, Verlo will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at brent@retellio.com. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation's data protection authority.

Data storage and retention

Your personal data is stored by Verlo on the servers of the cloud infrastructure and database services Verlo engages. These servers are located in the United States by default, and in Canada for customers located in Canada. Verlo retains service data for the duration of the customer's business relationship with Verlo and for a period of time thereafter, to analyze the data for Verlo's own operations, and for historical and archiving purposes associated with Verlo's services.

Verlo retains prospect data until such time as it no longer has business value and is purged from Verlo systems. All personal data that Verlo controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: brent@retellio.com

Children's data

We do not knowingly attempt to solicit or receive information from children.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at: