Last Updated: September 2019
- When you browse or visit our website, https://vennglobal.wpengine.com/ (and together with its sub-domains, the “Website”), including:
- When you request a tour of our community(ies), and the surrounding neighborhood(s);
- when you sign up for our mailing list/newsletter;
- when you submit a job application through Website; and
- When you contact us (e.g., customer support or inquiries).
- When you sign up for our living experience services (or “Services”), whether offline or by making use of, or interact with, our mobile software application, and any other mobile software application, that we license to our Members (each individually, and collectively, the “App”), including:
- When you download our App and create an Account; or
- When you upload your personal data to our App;
- When we use the Personal Data of our customers (e.g., when you use certain Services we provide, or purchase a product or service through our App).
- In other instances other than the Website and App, such as:
- When you attend a marketing event (including when exchanging business cards);
- When we acquire your personal data from third-party sources (e.g., from lead generation companies);
- we use the personal data of our suppliers and service providers.
- When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
Table of contents:
- What information we collect, why we collect it, and how it is used
- Period of storage of collected information
- How we protect and retain your personal data
- How we share your personal data
- Additional information regarding transfers of personal data
- Your privacy rights
- Use by children
- Interaction with third party products
- Analytic tools
- How to contact us
What Information we collect, why we collect it, and how it is used.
Finally, please note that some of the abovementioned personal data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
PERIOD OF STORAGE OF COLLECTED INF
- Your personal data (as described above) will be stored until we (i) no longer need the information and proactively delete it; or (ii) you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your personal data perpetually.
HOW WE PROTECT AND RETAIN YOUR INFORMATION
- Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- Retention of your personal data. In addition to the retention periods mentioned in Section 2 above, In some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
HOW WE SHARE YOUR PERSONAL DATA
- We will share your data with several categories of recipients, for the following activities:
- With multinational payment processing service providers, for billing purposes;
- With Canadian screening service providers, for background check purposes; and
- US based security service provider in order to help us keep our members residence secure.
- In addition to the recipients described above, we may share your personal data as follows:
- To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
- In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
- Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
- Internal transfers: Transfers within the Venngroup will be covered by an internal processing agreement entered into by members of the Venngroup (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
- External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data, or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
- Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
- You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
- You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
- You have the right to object, to or to request restriction, of the processing;
- You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
- You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
You can exercise your rights by contacting us at email@example.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
- Deleting your account: Should you ever decide to delete your account, you may do so by emailing firstname.lastname@example.org. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
USE BY CHILDREN
- We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at email@example.com.
- INTERACTION WITH THIRD PARTY PRODUCTS
- We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
- Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Members, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.
- UXcam. We use UXcam (relevant terms available at: https://help.uxcam.com/hc/en-us/articles/360004158171) to collect and analyze data from our services.
- Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about Members who have turned on Ads Personalization, base across device types and on aggregated data from Members who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above.
- Facebook Custom Audience
- Lookalike Audience
- If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org.