1. Data Controller
The Data Controller is:
Gabriele Tognoni
Operating under the name Velora Network
Privacy contact:
gtognoni05@gmail.com
Requests concerning personal data or the exercise of privacy rights may be sent to the email address above.
2. Scope of this Privacy Policy
This Privacy Policy applies to personal data processed in connection with:
- the Velora Network website;
- project requests;
- quotations and pre-contractual communications;
- active projects;
- customer support;
- Discord-related services;
- hosting and maintenance services;
- payment administration;
- communications between Velora Network and prospective or existing clients.
It does not replace the privacy policies of independent third-party services that users may interact with, such as Discord, Stripe, PayPal, Revolut, Vercel, Neon, Oracle, or banking institutions.
3. Data Collected During Website Navigation
Velora Network does not require users to create an account or log in in order to browse its website.
Velora Network does not intentionally use the website to profile visitors or collect personal information for advertising purposes.
However, normal technical information may be processed automatically when a website is accessed. This may include, where technically necessary:
- IP address;
- date and time of a request;
- browser type;
- operating system or device information;
- requested pages or resources;
- HTTP request information;
- diagnostic information;
- technical and security logs.
Such information may also be processed automatically by the infrastructure providers used to operate the website.
This data is used only where necessary for providing the website, maintaining infrastructure, diagnosing technical problems, preventing abuse, and protecting the security of Velora Network systems.
4. Project Requests
When a user submits a project request, Velora Network may collect the following information:
- name of the requester;
- organization name, where applicable and voluntarily provided;
- email address;
- project or request status;
- project description and details;
- Discord server link, where applicable;
- Discord username;
- files, images, documents, code, branding material, or other assets voluntarily provided by the requester;
- any other information voluntarily included in the project request.
This information is used to:
- review and understand the request;
- determine whether Velora Network can provide the requested service;
- prepare a quotation or project proposal;
- communicate with the requester;
- define project requirements;
- establish a contractual relationship where the proposal is accepted;
- deliver the requested project or service.
The primary legal basis for this processing is the performance of measures requested by the user before entering into a contract and, after acceptance of a project, the performance of the resulting contractual relationship.
5. Required and Optional Information
Some information may be necessary in order for Velora Network to evaluate or perform a project.
If information necessary to understand, quote, or deliver a project is not provided, Velora Network may be unable to process the request or provide the requested service.
Fields explicitly identified as optional, such as an organization name when no organization exists, do not have to be provided.
Users should only submit information that is reasonably necessary for the requested project.
6. Client Communications
Communications relating to a project may take place through methods agreed with the client.
These may include:
- Discord;
- email;
- telephone number;
- other messaging or communication services requested or agreed with the client.
Where a telephone number or another private contact method is used, such information is provided and agreed privately between the parties.
Information contained in project-related communications may be processed where necessary to manage the request, provide support, perform the project, document decisions, or resolve issues.
7. Discord Data
Where a project involves Discord, Velora Network may process information necessary to configure, develop, maintain, or support the requested service.
Depending on the project, this may include non-sensitive or publicly available information such as:
- Discord usernames;
- Discord user IDs;
- server IDs;
- channel IDs;
- role IDs;
- public server configuration;
- permissions;
- publicly accessible server information;
- information necessary to configure Discord bots or servers.
Velora Network does not require access to Discord user account tokens.
Prohibited Credentials
Clients and users must never provide Velora Network with Discord user tokens or bot tokens, unless a specific secure technical procedure explicitly requires the client to configure their own credential without disclosing it to Velora Network.
Users must also avoid sending:
- passwords;
- authentication codes;
- private API keys;
- access tokens;
- session credentials;
- other confidential authentication secrets.
Where possible, credentials and secrets must be entered directly by the client into the relevant platform, hosting environment, or configuration system.
8. Project Assets and Files
Clients may voluntarily provide assets necessary for a project, including for example:
- logos;
- images;
- graphics;
- text;
- documents;
- configuration files;
- source material;
- code;
- other project resources.
Velora Network processes such material only to the extent reasonably necessary to evaluate, develop, deliver, maintain, or support the relevant project.
Clients are responsible for ensuring that they have the right to provide such material to Velora Network.
Users should avoid including unnecessary personal, confidential, or sensitive information inside submitted assets.
9. Payment Information
Velora Network may accept payments through:
- Stripe;
- PayPal;
- Revolut;
- SEPA bank transfer.
Payment processing may require information such as:
- payer name;
- amount;
- transaction reference;
- payment status;
- date of payment;
- information necessary to identify or reconcile the transaction.
Payment card information, banking credentials, account passwords, or equivalent sensitive financial authentication information processed directly by payment providers are not intended to be stored by Velora Network.
Payment providers and banking institutions process payment information according to their own terms and privacy policies.
Certain transaction-related information may be retained where necessary for payment administration, legal obligations, dispute resolution, accounting, fraud prevention, or the establishment, exercise, or defence of legal claims.
10. Purposes and Legal Bases for Processing
Personal data may be processed for the following purposes:
Pre-contractual requests
To review project requests, communicate with prospective clients, understand requirements, and prepare quotations.
Legal basis: steps taken at the request of the data subject prior to entering into a contract.
Performance of a project or service
To develop, deliver, support, host, or maintain a service requested by the client.
Legal basis: performance of the contractual relationship.
Payment and administration
To manage payments, transaction records, and related administrative activities.
Legal basis: performance of the contractual relationship and, where applicable, compliance with legal obligations.
Security and abuse prevention
To secure websites, servers, databases, Discord services, infrastructure, and project systems and to detect or prevent abuse, fraud, unauthorized access, or attacks.
Legal basis: legitimate interest in protecting Velora Network, its clients, its infrastructure, and its services.
Legal claims and compliance
To comply with applicable law or establish, exercise, or defend legal claims.
Legal basis: applicable legal obligations and, where appropriate, legitimate interests.
Velora Network does not currently rely on consent as the primary legal basis for ordinary project requests or for performing client projects.
11. Infrastructure and Third-Party Providers
Velora Network uses third-party infrastructure and service providers where necessary to provide its services.
These currently include, depending on the service:
Vercel
Used for website deployment, hosting, and related web infrastructure.
Neon
Used for PostgreSQL database infrastructure.
Oracle
Oracle Cloud Infrastructure may be used for virtual machines, hosting infrastructure, and server-related services.
Payment providers
Stripe, PayPal, Revolut, and banking institutions may process information required for payments.
These providers may process limited technical or personal data when necessary for the operation of their respective services.
Each provider may act according to its own role and obligations under applicable data protection law.
Velora Network does not authorize third-party providers to use personal data for purposes unrelated to providing the relevant services to Velora Network, except where such processing is independently determined by the provider under its own legal responsibilities.
12. Disclosure of Personal Data
Velora Network does not sell, rent, or commercially trade personal data.
Personal data is not intentionally made publicly available by Velora Network unless:
- publication is explicitly requested by the client;
- publication is inherently necessary for the requested service;
- the information was provided specifically for public use;
- disclosure is required by law or a competent authority.
Data may be shared with service providers only where reasonably necessary to provide the relevant infrastructure, payment, hosting, database, or other requested service.
13. Data Retention
Velora Network follows the principle that personal data should not be retained for longer than reasonably necessary for the purposes for which it was collected.
Completed projects
The operational project request ticket and related data that are no longer required are deleted within 7 days after the definitive completion of the project.
This may include, where no longer required:
- project request information;
- ticket content;
- submitted project assets;
- operational project details;
- other temporary material associated with the request.
Requests that do not become projects
Where a request does not result in a project, personal data is retained only for the period reasonably necessary to evaluate, communicate about, and close the request, unless a longer retention period is necessary for a legitimate or legal reason.
Exceptions
Certain information may be retained for longer where necessary for:
- compliance with legal obligations;
- payment or transaction records;
- accounting or administrative requirements;
- dispute resolution;
- fraud prevention;
- demonstrating contractual agreements;
- establishing, exercising, or defending legal claims.
Data subject to such an exception will be retained only for the period required by the applicable purpose or legal obligation.
14. Hosting and Maintenance Services
Velora Network may provide hosting and maintenance services through a recurring paid subscription agreed with the client.
The cost of such services is borne by the client according to the applicable agreement and Terms of Service.
When hosting or maintaining a client's project, Velora Network may technically have access to systems containing personal data controlled by the client.
Where Velora Network processes personal data exclusively on behalf of a client:
- the client remains responsible for determining the purposes and means of the relevant processing;
- Velora Network processes such data only where necessary to provide the agreed service and according to the client's documented instructions;
- access to such data must be limited to what is technically necessary;
- an appropriate data processing agreement may be entered into where required by applicable law.
Personal data belonging to a client's users does not become property of Velora Network merely because Velora Network provides hosting or maintenance services.
15. Cookies and Tracking
Velora Network does not currently require a user account or login to browse its website.
The website is not intended to use:
- advertising cookies;
- profiling cookies;
- marketing cookies;
- behavioral tracking systems.
Velora Network does not intentionally track visitors for advertising or profiling purposes.
Normal server requests, infrastructure logs, network information, and security information generated during access to the website are not treated as advertising or profiling cookies.
If Velora Network introduces non-essential cookies, analytics, profiling systems, or other tracking technologies in the future, this Privacy Policy and any required consent mechanisms will be updated accordingly before such technologies are used where prior consent is legally required.
16. Data Security
Velora Network takes reasonable and appropriate technical and organizational measures designed to protect personal data against:
- unauthorized access;
- unauthorized disclosure;
- unlawful processing;
- accidental loss;
- destruction;
- alteration;
- misuse.
Access to personal data is intended to be limited to what is reasonably necessary for the relevant project or service.
No internet-based system can provide an absolute guarantee against every possible security incident. Velora Network therefore commits to applying appropriate security measures rather than representing that any system is completely immune from security risks.
17. International Data Transfers
Some infrastructure or service providers used by Velora Network may operate or process data in countries outside the European Economic Area.
Where personal data is transferred outside the European Economic Area and applicable law requires additional safeguards, Velora Network will rely on an appropriate transfer mechanism or on safeguards made available under applicable data protection law.
The exact locations and mechanisms may depend on the infrastructure provider and service configuration in use at the relevant time.
18. Automated Decision-Making and Profiling
Velora Network does not use personal data to perform automated decision-making producing legal or similarly significant effects on users.
Velora Network does not perform behavioral profiling for advertising purposes.
19. Data Subject Rights
Subject to the requirements and limitations established by applicable law, individuals may have the right to:
- request confirmation as to whether their personal data is being processed;
- obtain access to their personal data;
- request correction of inaccurate or incomplete data;
- request deletion of personal data;
- request restriction of processing;
- object to certain processing;
- request data portability where applicable;
- withdraw consent at any time where a specific processing activity is based on consent.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
A request to delete data may not require Velora Network to erase information that must lawfully be retained for legal obligations, payment records, dispute resolution, or the establishment, exercise, or defence of legal claims.
Requests may be sent to:
Individuals also have the right to lodge a complaint with the competent data protection supervisory authority.
For users in Italy, the competent authority is the Garante per la protezione dei dati personali.
20. Data Concerning Minors
Velora Network's commercial project services are intended for persons who meet the eligibility requirements established in the Velora Network Terms of Service.
Velora Network does not intentionally request personal data from minors for the purpose of entering into a client project.
Where Velora Network becomes aware that personal data has been submitted contrary to the applicable eligibility requirements and there is no lawful reason to retain it, the information may be deleted.
21. Third-Party Services and Links
The Velora Network website or project communications may contain links to third-party websites or services.
Velora Network does not control the independent privacy practices of third-party platforms.
Users should review the privacy policies of any external service they choose to use.
22. Changes to this Privacy Policy
Velora Network may update this Privacy Policy where necessary to reflect:
- changes to its services;
- changes to infrastructure;
- new processing activities;
- changes in applicable law;
- security or operational requirements.
The date shown at the beginning of this Privacy Policy indicates the latest revision.
Where a change materially affects the way personal data is processed, reasonable steps will be taken to provide appropriate information where required.
23. Contact
For questions, requests, or concerns relating to privacy or the processing of personal data, contact:
Gabriele Tognoni
Operating under the name Velora Network
Email: gtognoni05@gmail.com