Last Modified: [March 11, 2019]
Legal Basis for Processing
We process personal data for, or based on, one or more of the following legal bases:
- Performance of a Contract. We use personal data to enter into and to perform under, an agreement between us.
- Legitimate Interests. We use personal data for our legitimate interests, including contact information, Service interaction, and Website usage data.
- Compliance with Legal Obligations and Protection of Individuals. We may use personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.
- Your Consent. We process certain personal data because you have given us your consent to process it in that manner.
Collection of Information
Information We Collect About You. We collect several types of information from and about users of the Website and Services, some of which is personally identifiable and some of which is non-identifying or aggregated, including:
- information by which you and/or your Designee may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you and/or your Designee may be contacted online or offline, and credit card and ACH payment information and related billing information, including but not limited to bank name and account and routing number, business/entity type, and billing address (collectively, “personal information”), including payment information collected and processed by Stripe (see “Collection of Information by Third Party Providers” below);
- information that is about you and/or your Designee but individually does not identify you and/or your Designee; and/or
- information about your and/or your Designee’s Internet connection, the equipment you and/or your Designee use to access the Website and usage details.
We collect this information (i) directly from you and/or your Designee when you provide it to us, (ii) automatically as you and/or your Designee use the Website (which information may include usage details, Internet Protocol (IP) addresses and information collected through cookies, web beacons and other tracking technologies), and (iii) from third parties (such as our business partners).
Information You Provide to Us. The information we collect on or through the Website or otherwise through your and/or your Designee’s use of the Services may include (i) information that you and/or your Designee provide about yourself or others by using our Website and/or Services, including information provided at the time of registering to use our Services, such as username, password, e-mail address, employer information, credit card, PayPal, or ACH payment information; (ii) records and copies of your and/or your Designee’s correspondence, including e-mail addresses, if you and/or your Designee contact us; (iii) your and/or your Designee’s responses to surveys that we might ask you and/or your Designee to complete for research purposes; and (iv) details of any transactions that you and/or your Designee carry out through the Services.
Information Collected Through Data Tracking Technologies
As you and/or your Designee use the Website and/or Services, we may use automatic data collection technologies to collect certain information about your and/or your Designee’s devices, browsing actions and patterns, including details of your and/or your Designee’s use of the Website and/or Services (such as traffic data, location data, logs and other communication data) and information about your and/or your Designee’s devices and internet connection (including your and/or your Designee’s IP address, operating system and browser type).
The technologies we use for this automatic data collection may include:
Log Information. We may automatically collect and store certain information in our server logs when you and/or your Designee use the Website, including details about how you and/or your Designee used the Website and Services, IP address, and information specific to your and/or your Designee’s device (such as system activity, hardware settings, browser type, and browser language).
Device Identifiers. We may collect information about your device, such as your operating system, hardware version, device settings, file and software names and types, mobile network information and device identifiers. This helps us measure how the Website is performing and to improve the Website for you and/or your Designee on your particular device.
Location-Based Data. We may collect and process information about your and/or your Designee’s geographic location (for example, through GPS signals) when you and/or your Designee use the Website. We will not store or track your and/or your Designee’s device location on an ongoing basis or without your and/or your Designee’s permission. We do not share precise geolocation data with third parties, other than our service providers as necessary to provide the Website and/or Services.
Analytics Data. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Website and/or Services. These third-party analytics do not collect direct personal information about any user.
Information Collected at Events
Data Trends. The discussions at the Venwise events may yield useful information regarding business trends. You acknowledge and agree that Venwise may aggregate and anonymize such information (collectively, “Aggregated Data”) for sharing and publication among Venwise members and the public and that Venwise may monetize such Aggregated Data, in its discretion. No member will be entitled to participate in any revenues realized by Venwise from monetization of the Aggregated Data.
Why We Collect Information
The information we collect helps us to improve the Website and Services and to deliver a better and more personalized experience, including by (i) enabling us to estimate our user size and usage patterns; (ii) store information about your and/or your Designee’s preferences, allowing us to customize our Website and Services according to your and/or your Designee’s individual interests; (iii) connect you and/or your Designee with other users who are willing to chat about issues in which you and/or your Designee have expressed an interest; (iv) recognize you and/or your Designee when you use the Website and/or Services; and (v) contact you and/or your Designee regarding the Services.
All payment transactions made through the Services are processed by Stripe, a service offered by Stripe, Inc., which is used for payment and payout processing for users.
Third Party Collection of Information
Some content or applications, including advertisements, on the Website may be served by third parties, including advertisers, ad networks and servers, content and application providers, and your mobile device manufacturer and mobile device service provider. These third parties may use tracking technologies to collect information about you and/or your Designee when you and/or your Designee use the Website and/or Services. The information they collect may be associated with your and/or your Designee’s personal information or they may collect information, including personal information, about your and/or your Designee’s online activities over time and across different websites and other online services. They may use this information to provide you and/or your Designee with interest-based (behavioral) advertising or other targeted content.
Venwise does not control these third parties’ tracking technologies or how they may be used. If you and/or your Designee have any questions about an advertisement or other targeted content, you and/or your Designee should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you and/or your Designee or that you provide to us, including any personal information, to:
- Provide you and/or your Designee with the Services, and any other information, products or services that you request from us.
- Present our Website and its contents to you and/or your Designee.
- Fulfill any other purpose for which you and/or your Designee provide it.
- Give you and/or your Designee notices about your account.
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and/or your Designee and us, including, if applicable, for billing and collection.
- Notify you and/or your Designee when updates to the Services are available, and about changes to any products or services we offer or provide though our Services.
- Contact you and/or your Designee about our own and third parties’ goods and services that may be of interest to you and/or your Designee.
- Enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your and/or your Designee’s personal information for these purposes without your and/or your Designee’s consent, if you and/or your Designee click on or otherwise interact with an advertisement, the advertiser may assume that you and/or your Designee meet its target criteria.
Additionally, we may use information that we collect about you and/or your Designee or that you and/or your Designee provide to us in any other way we may describe when you and/or your Designee provide the information or for any other purposes with your and/or your Designee’s consent.
Following termination or deactivation of an account, we may retain information and content for backup, archival, audit or other business purposes, or otherwise in accordance with applicable laws. We may maintain anonymized, de-identified or aggregated data, including usage data, for analytics purposes. If you have any questions about data retention or deletion, please e-mail firstname.lastname@example.org.
Disclosure of Your Information
We may disclose anonymized, de-identified or aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you and/or your Designee provide:
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.
- To third parties to market their products or services to you and/or your Designee if you and/or your Designee have consented to or not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To fulfill the purpose for which you and/or your Designee provide it.
- For any other purpose disclosed by us when you and/or your Designee provide the information.
- With your and/or your Designee’s consent.
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Service, found at www.venwiseportal.com/terms, and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Venwise, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may also share aggregated, non-personally identifiable information publicly, including with users, partners or the press in order to, for example, demonstrate how our Services are used, evaluate industry trends, or to create our marketing materials. Any aggregated information shared this way will not contain any personal information.
Your Rights Regarding Data
Certain laws provide individuals with enhanced rights in respect of their personal data. These rights may include, depending on the facts and circumstances surrounding, and in certain cases the legal basis for, the processing of personal data, the following:
- The right to be informed of whether we hold personal data about you.
- The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;
- The right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to (a) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (b) performance of a task in the public interest;
- The right to challenge the accuracy and completeness of your personal data and have it amended as appropriate;
- The right to be provided with information about our policies and practices with respect to the management of personal data, including: (a) the name or title, and address, of the person who is accountable for our privacy policies and practices; (b) the means of gaining access to personal data; (c) a description of the type of personal data held by us, including a general account of its use; (d) a copy of any brochures or other information that explain our policies, standards, or codes; and (e) what personal data is made available to related organizations;
- The right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and
- The right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.
Where required by applicable law, we will respond to a valid request relating to your rights within one month of receipt, or within three months where a request is complex or challenging. Note that we may need to request additional information from you to validate your request.
Under certain conditions, you may have the right to require us to:
- Provide you with further details on the use we make of your personal information
- Provide you with a copy of the personal information we hold about you
- Update any inaccuracies in the personal information we hold about you
- Delete any of your personal information that we no longer have a lawful ground to use
- Where processing is based on consent, stop that particular processing by withdrawing your consent
- Object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
- Restrict how we use your personal information whilst a complaint is being investigated
- Transfer your personal information to a third party in a standardized machine-readable format.
Your Choices About Our Use and Disclosure of Your Information
We strive to provide you and/or your Designee with choices regarding the personal information you and/or your Designee provide to us. This section describes mechanisms we provide for you and/or your Designee to control certain uses and disclosures of your information.
Location Information. You and/or your Designee can choose whether or not to allow the Website to collect and use real-time information about your device’s location through the device’s privacy settings. If you and/or your Designee block the use of location information, some parts of the Website may then be inaccessible or not function properly.
Promotional Offers. If you and/or your Designee do not want us to use your e-mail address or contact information to promote our own or third parties’ products or services as provided herein, you and/or your Designee can opt-out by sending us an e-mail stating your request to email@example.com.
Accessing and Correcting Your Information
We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Accordingly, please review all of your information carefully before submitting it to us, and notify, us as soon as possible of any updates or corrections. You and/or your Designee may review and update your account information by logging into your account and visiting your account profile page or by emailing your request to firstname.lastname@example.org.
Your California Privacy Rights
California Civil Code Section 1798.83 permits users of the Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to email@example.com.
We have implemented measures designed to secure your and/or your Designee’s personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All credit card information you provide to us is stored on our secure servers behind SSL/TLS technology. Any information you and/or your Designee provide to us through your use of the Services will be encrypted using industry standard technology.
The safety and security of your and/or your Designee’s information also depends on you and/or your Designee. Where we have given you and/or your Designee (or where you and/or your Designee have chosen) a password for access to the Website and/or payment information for the Services, you and/or your Designee are responsible for keeping this password confidential. We ask you and/or your Designee not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your and/or your Designee’s personal information and we take reasonable steps ensure that our Website is secure, we cannot guarantee the security of your and/or your Designee’s personal information transmitted through the Services. Any transmission of personal information is at your and/or your Designee’s own risk. We are not responsible for circumvention of any privacy settings or security measures that we provide.
Data Protection Officer
To further ensure Data Security, we have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO by email at firstname.lastname@example.org
If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.
The Website and Services are operated by Venwise LLC. All feedback, comments, requests for technical support and other communications relating to the Services should be directed to us at:
119 West 24th Street
New York, NY 10011