Privacy Policy

1. Scope and controller

This Privacy Policy explains how Velum Agency (“Velum,” “we,” “us,” or “our”) collects, uses, discloses, and retains personal information through velumagency.com, its age gate, earnings calculator, application form, contact form, and related communications (collectively, the “Site”). Velum is the controller or business responsible for the processing described here.

This Policy does not govern a creator or talent relationship after onboarding when a separate agreement or privacy notice applies, and it does not govern third-party platforms that you visit through external links. Questions and privacy requests may be sent to hello@velumagency.com.

2. Information we collect

Depending on how you use the Site, we collect the following categories:

• Application and inquiry identifiers and contact information: name, email address, optional phone number, city and country where supplied, and a unique submission reference.
• Profiles and professional information: Instagram username or URL, other profile links you voluntarily provide, public information visible through those links, and your description of your content, goals, and requested support.
• Eligibility and consent records: your 18-or-older declarations, acceptance of the Terms, acknowledgment of this Policy, permission to review and contact you, submission status, and submission time.
• Technical and security information: IP address, browser and device information, request URLs, timestamps, error information, and security or access logs that may be processed by our hosting and infrastructure providers.
• Communications: your contact-form message and information you include when you email or otherwise communicate with Velum about an inquiry, application, or privacy request.

The current Site does not request payment-card or bank information, passwords for third-party accounts, government identification documents, biometric identifiers, or explicit media. Do not place that information, health information, or other highly sensitive information in the Site’s free-text fields. If you voluntarily include unexpected sensitive information, we will process it only as reasonably necessary to review the submission, protect rights, comply with law, or respond to your request.

3. Sources of information

We collect information directly from you when you use the age gate, submit an application or contact inquiry, or contact us by another method. We may review information that you have made publicly available through profiles you link in your application. Technical and security information is generated automatically when your browser communicates with the Site and its infrastructure providers. We do not purchase application profiles from data brokers.

4. How we use information

We use personal information to:

• receive, validate, review, and administer applications and contact inquiries;
• understand your stated goals and evaluate a potential working relationship;
• respond to your question or submission and arrange follow-up conversations;
• prevent duplicate, fraudulent, abusive, or unauthorized submissions;
• operate, secure, debug, maintain, and improve the Site;
• comply with recordkeeping, regulatory, tax, legal, and law-enforcement obligations;
• establish, exercise, or defend legal claims and enforce our agreements; and
• complete a business transaction such as a financing, reorganization, merger, or sale, subject to applicable protections.

We do not use the Site application to make a solely automated decision that produces legal or similarly significant effects. A person reviews applications. The earnings calculator runs locally in your browser and does not send your slider selections or calculated scenario to Velum.

5. Lawful bases for international applicants

Where the European Economic Area, United Kingdom, or another jurisdiction requires a lawful basis, we rely as applicable on: your request to take steps toward a possible agreement; our legitimate interests in reviewing genuine applications, communicating with applicants, securing the Site, preventing abuse, and managing legal claims; compliance with legal obligations; and consent where the law specifically requires it. You may withdraw consent for future processing at any time, but withdrawal does not affect processing that was already lawful or information we must retain by law.

6. Age gate, cookies, and browser storage

The entrance gate uses a first-party session cookie named velum_age to remember an affirmative 18+ declaration during the browser session. The cookie contains a confirmation value, not your birth date or identity document. Browsers may preserve session cookies when restoring a session; you can remove it through your browser settings. Declining the age declaration removes that cookie.

We use our own aggregate website analytics to count page views, entry-page loads, broad referral categories (such as Instagram or a search engine), calculator interactions, and clicks toward our forms. Our analytics counters store only the calendar day, a predefined page or action, a broad source category, and a count. They do not store IP addresses, visitor identifiers, full referring URLs, query strings, form answers, or calculator values. They do not use analytics cookies, browser storage, or fingerprinting. We skip this activity collection when your browser signals Global Privacy Control or Do Not Track. Separately, we count successfully saved applications and inquiries to understand form activity; the submitted details remain in their existing records. Authorized personnel can view aggregate reporting in VelumHub. Optional Meta Pixel advertising measurement is described below. The Site does not use Google Analytics or an email-marketing signup.

We also record each visit to the Site for 90 days to understand how the Site is used: the pages viewed, the referrer category, any campaign tag in the link, the browser and device type, screen size, language, and an approximate location by country and city derived from the network. A random visit id kept in your browser’s session storage ties the pages of one visit together and is discarded when the browser session ends. No IP addresses or typed content are stored in these visit records, browsers that signal Do Not Track or Global Privacy Control are not recorded, and a visit is linked to an application or message only when you send one.

Optional Meta advertising measurement

On the application page, Meta Pixel is off until you select Allow in Advertising choices. If you allow it, Meta receives the application page visit and a Lead event after an application is successfully saved, along with ordinary browser, device, network and page information collected by the Pixel. Meta may set advertising cookies such as _fbp and _fbc and use these events for advertising measurement, delivery and audience matching on Facebook and Instagram. We do not include your name, email, profile links, form answers, financial information, or application reference in these events, and automatic advanced matching is not enabled by our code.

Declining does not prevent you from applying. Your Allow or Decline choice is stored in this browser for up to 180 days. Use Advertising choices at any time to change it. Withdrawing consent stops future Pixel events on this browser and removes the first-party Meta cookies we can access; it does not recall events already sent to Meta. Global Privacy Control and Do Not Track signals keep this tracking off. Preview and automated sessions do not send Pixel events. Learn how Meta uses data in its Privacy Policy.

7. Service providers and disclosures

We disclose information only as reasonably necessary for the purposes described above. Current recipients may include:

• Hosting and infrastructure: OpenAI Sites and Cloudflare services used to deliver the Site, process requests, provide security, and store application records in a Cloudflare D1 database.
• Meta: the advertising events described above, only when you allow optional advertising tracking.
• Fonts and web resources: Google Fonts on the main and application pages, which requires your browser to connect to Google and disclose ordinary technical request information.
• Authorized Velum personnel and contractors: people who need access to review applications, operate the Site, provide security, or respond to requests and who are subject to appropriate obligations.
• Professional advisers: attorneys, accountants, auditors, insurers, and similar advisers where reasonably necessary.
• Authorities and legal recipients: regulators, courts, law enforcement, or other parties when required by law or reasonably necessary to protect rights, safety, and security.
• Transaction participants: prospective or completed purchasers, investors, lenders, or successor organizations in a legitimate corporate transaction, subject to confidentiality and applicable law.

Following a link to Instagram or another external service causes that service to receive information under its own privacy policy. Velum does not control a third party’s independent privacy practices.

8. Advertising data and your choices

Velum does not sell personal information collected through the Site for money. If you allow optional advertising tracking, we share the limited advertising events described above with Meta for measurement and relevant advertising. Application form answers are not part of those events. Choose Decline or use Advertising choices to turn this sharing off. We honor Global Privacy Control and Do Not Track browser signals for this tracking. We do not knowingly share advertising events about anyone under 18.

9. Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy. Retention criteria include whether an application is active, whether future recruitment consideration is reasonably expected, the duration of communications or a resulting relationship, security and fraud-prevention needs, applicable limitation periods, legal holds, and statutory or regulatory recordkeeping.

Florida law requires covered talent-agency application, registration, and contract records to be preserved for at least one year after the last entry. Some records may be retained longer when necessary to comply with another legal obligation, resolve a dispute, enforce an agreement, or establish, exercise, or defend a claim. When retention is no longer required, we will delete, de-identify, or securely dispose of the information in accordance with our processes and provider capabilities. Backup and security copies may persist for a limited period before deletion cycles complete.

10. Security

We use administrative, technical, and organizational measures designed for the nature of the information we process. The Site uses HTTPS, restricts public access to application records, validates and limits application submissions, and limits access to people and providers with an operational need. No storage or transmission method is completely secure, and we cannot guarantee absolute security.

Do not send passwords, financial credentials, identity documents, or explicit media through the application. If you believe information submitted to Velum has been accessed or used without authorization, contact hello@velumagency.com.

11. International processing and transfers

Velum operates from Florida, United States, and the Site’s providers may process information in the United States or other locations where they operate. If you apply from outside the United States, your information will be transferred to and processed in the United States, where privacy laws may differ from those in your country.

Where applicable law requires a transfer mechanism or additional safeguard, we will use a recognized legal mechanism or take other required steps. You may contact us for information about safeguards relevant to your information. Submission of an application does not waive any transfer protection that cannot lawfully be waived.

12. Your privacy choices and rights

Depending on where you live and whether a particular law applies to Velum, you may have the right to request access to personal information; correction of inaccurate information; deletion; portability; restriction of or objection to processing; withdrawal of consent; and information about categories, purposes, sources, recipients, sales, or targeted-advertising sharing. You may also have the right not to receive discriminatory treatment for exercising a privacy right.

To make a request, email hello@velumagency.com with the subject “Privacy Request” and describe the request. We may ask for information reasonably necessary to verify your identity and authority. You may use an authorized agent where permitted by law, but we may verify the authorization and your identity. We will respond within the period required by applicable law. Rights are subject to lawful exceptions, including required talent-agency records, security, fraud prevention, free-expression rights, and legal claims.

13. Appeals and complaints

If we deny a privacy request and applicable law provides an appeal right, you may appeal by emailing hello@velumagency.com with the subject “Privacy Appeal” and explaining why you believe the decision should be reconsidered. You may also have the right to contact the Florida Department of Legal Affairs, the California Privacy Protection Agency or California Attorney General, your local data-protection authority, or another regulator with jurisdiction.

14. California disclosures

If the California Consumer Privacy Act applies to Velum and your information, the categories collected during the preceding twelve months correspond to the categories described in Section 2: identifiers, internet or electronic activity, professional or application information, and inferences drawn directly from the information you provide for application review. The business and commercial purposes and recipient categories are described in Sections 4 and 7.

Velum does not sell Site personal information for money or offer a financial incentive for that information. Optional advertising events are shared with Meta only when you allow the tracking described above. Use Advertising choices to decline or withdraw that choice. California residents may request to know, correct, or delete covered information and may exercise other applicable rights using the process in Section 12.

15. EEA and United Kingdom disclosures

Applicants in the EEA or United Kingdom may have rights to access, rectify, erase, restrict, port, or object to processing and to withdraw consent. You may lodge a complaint with the data-protection authority where you live or work. You are not required by law to submit an application, but Velum cannot review an application without the required fields. Velum does not use the application for solely automated decision-making with legal or similarly significant effects.

16. Information about minors

The Site is restricted to adults aged 18 or older and is not directed to children. We do not knowingly solicit application information from anyone under 18. If you believe an underage person submitted information, contact us so we can investigate and take appropriate action, subject to legal recordkeeping and preservation requirements.

17. Data incidents

If a security incident affects personal information, Velum will investigate, contain, and document the incident and provide notices to affected individuals, regulators, or others when required by applicable law. Nothing in this Policy limits any breach-notification right that cannot lawfully be waived.

18. Third-party sites

The Site contains links to services we do not operate. Their collection and use of information is governed by their own terms and privacy notices. Review those notices before providing information to the third party. Velum is not responsible for a third party’s independent conduct.

19. Changes to this Policy

We may update this Policy as our practices, providers, or legal obligations change. The “Last updated” date identifies the current version. Material changes will be presented or communicated when required by law, and we will obtain consent before applying a new use where consent is legally required.

20. Contact

Privacy questions, rights requests, appeals, security concerns, and underage-submission reports may be sent to hello@velumagency.com.

Disputes concerning the Site are also subject to the dispute-resolution provisions in the Terms of Service, but those provisions do not eliminate non-waivable privacy rights or prevent you from contacting a regulator.