Privacy Notice

 

Effective Date: December 31, 2019, Last Revised December 22, 2022

Contents

1. Who Is VenPath and What Do We Do?

2. Who Are You?

  • 2.1 Device Users

  • 2.2 Website Users

  • 2.3 Customers

  • 2.4 Partners

3. What Personal Information Do We Collect?

  • 3.1 Device Users

  • 3.2 Website Users

  • 3.3 Customers and Partners

4. How Do We Collect Your Personal Information?

  • 4.1 Device Users

  • 4.2 Website Users

  • 4.3 Customers and Partners

5. How Do We Use Your Personal Information?

  • 5.1 Device Users

  • 5.2 Website Users

  • 5.3 Customers and Partners

6. How Do We Share or Sell Your Personal Information?

  • 6.1 Device Users

  • 6.2 Device Users, Website Users, Customers, and Partners

7. Cookies and Other Online Tracking Technologies as Applicable to Website Users

8. Your Privacy Rights

  • 8.1 Rights Under GDPR and Additional Information to European Residents

  • 8.1.1 Legal Basis for Processing Your Personal Information

  • 8.1.1.1 Device Users

  • 8.1.1.2 Website Users, Customers, and Partners

  • 8.1.2 Individual Rights Under GDPR

  • 8.1.3 Data Transfers and Retention Under GDPR

  • 8.2 Rights Under California Law

9. How Do We Secure Your Information?

10. Notice of Processing In the United States

11. Managing Your Information Preferences

12. Children’s Information

13. Changes to this Notice

14. How to Contact Us

1. Who Is VenPath and What Do We Do?

VenPath (“we”, “our”, “us”) is a leader in location data analytics. We provide insights and understanding to our Customers by collecting and managing consumer behavioral data, location data, and related know-how (“Services”). We work with our Partners to collect information about individuals from applications installed on their Devices, and we use that information to create and deliver analytics insights to our Customers.

We believe that openness and transparency about our data practices are critical to ensuring that we collect accurate information that aligns with the expectations of our stakeholders. This Privacy Notice (“Notice”) is intended to serve as an easy-to-understand guide to our data collection, use, and disclosure practices.

As further explained below, we purchase most of the information that we process from our third-party Partners. These Partners initially collect that information through applications that users have installed on a mobile phone, tablet, or other internet-enabled device (“Device”). However, we may also purchase information from other data aggregation companies or collect information directly from visitors’ activity on this Website.

2. Who Are You?

VenPath collects Personal Information from four categories of individuals: Device Users, Customers, Partners, and Website Users (“you”, “your”). We process your Personal Information differently depending on which category you fall under at a given time. Moreover, certain individuals will fall under more than one category simultaneously. For example, Partners may also be Website Users, whenever they use our Website. When reading this Notice, you should therefore consider each of the different ways in which this Notice might apply to you.

2.1 Device Users

Device Users are individuals who use Partner applications from which VenPath collects Personal Information in order to provide its Services. Device Users may also include individuals whose Personal Information is purchased by VenPath from third-party data aggregators or brokers.

2.2 Website Users

Website Users are individuals who visit our Website, located at https://www.venpath.net, and including any related domains, subdomains, and pages.

2.3 Customers

A Customer is any person or organization that purchases Services from VenPath. Typically, our Customers are advertisers, media, data analytics providers, government authorities or their representatives or contractors, city planning commissions, transportation authorities, academic researchers, financial services providers, and any other enterprise requiring our Services.

2.4 Partners

Partners are third-party mobile application developers from whom we purchase Personal Information in order to provide Services to our Customers.

3. What Personal Information Do We Collect?

We collect and/or process the following information about you (we refer to this information as Personal Information, or Information, throughout this Notice):

3.1 Device Users

We purchase the following Personal Information about Device Users who use Partner applications or from third-party data aggregators or brokers:

Information Category Description of Information Collected

Information Category: Personal Identifiers
Description of Information Collection:

  • Email Address.

  • The IP address that has been assigned to your Device when your information is collected.

  • A unique advertising ID or other similar unique identifier that is associated with your Device.

Information Category: Location
Description of Information Collection: This includes precise geolocation data, such as GPS coordinates of a Device (longitude and latitude) and movement of the Device over time. Location can also be derived from nearby Wi-Fi networks or cell towers or from other sensors, such as an accelerometer, which can track the movement of your Device. On many Devices, enabling or disabling “Location Services” or a similar setting controls whether the Device permits sharing location information.

Information Category: Commercial Information
Description of Information Collection: Information about purchases you either make in an application or that are tracked by an application. This also includes other transactional data or purchase history about products or services that you purchase or have purchased, credit card or loyalty card data, or other sources of compiled transactions.

Information Category: Demographic Information
Description of Information Collection: We may purchase or derive demographic information about you, which may include age, gender, household income, level of education obtained, presence of children in a household, marital status, or information about your interests and hobbies.

Information Category: Device Information
Description of Information Collection: Various information about your Device, including Device type and model. For example, we may see that your is an iPhone 12. This also includes information about the browser type and operating system, time zone setting, and browser plug-ins. If your Device has a cellular connection, we may also collect information on the type of connection, your cellular carrier, country location, and your signal strength.

Information Category: Application Usage
Description of Information Collection: Information on your usage of our Partners’ applications. When you use our Partners’ applications, we gather certain information about your usage of these applications. This can include the version of the application, application permissions, the date the application was installed or deleted, when the application was last used, and how long the application was used.

 Information Category: Inferences
Description of Information Collection: We use the information we collect about you to create inferences that reflect your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. This includes using location information that we collect from a Device to create inferences about you based on the Device’s movements and locations, such as assumptions as to where you work or where you live. We may also create inferences about you using any of the other information that we collect about you.

3.2 Website Users

We collect the following Personal Information from individuals that use our Website:

Information Category: Personal Identifiers
Description of Information Collected:

  •  The IP address that has been assigned to your Device when your information is collected.

  • In order to communicate with you, we may collect contact information, which includes name, address, phone number, and email address, but only when you agree to provide it to us.

Information Category: Device Information
Description of Information Collected: Various information about your Device, including Device type and model. For example, we may know that you are using a phone and that it is an iPhone 12. This also includes the browser type and operating system, time zone setting, browser plug-in types and versions.

Information Category: On-Site Internet or Network Activity
Description of Information Collected: Web pages you view on our site, links you click, the length of time you visit our Site, the webpage that led you to our site, and the webpages you go to.

3.3 Customers and Partners

We collect the following Personal Information from our application Partners and from the Customers to whom we sell our Services:

Information Category: Personal Identifiers
Description of Information Collected:

  •  In order to communicate and provide our Services to our Partners and Customers, we collect our Partners’ and Customers’ contact information, which includes name, address, phone number, and email address.

  • Login information necessary to access your online account.

Information Category: Payment Information
Description of Information Collected: In order to process or issue payments from or to our Partners and Customers we collect bank account or credit card information from Partners and Customers.

4. How Do We Collect Your Personal Information?

4.1 Device Users

The majority of the Device User Information we collect is purchased from our Partners, who collect Information directly from Device Users through those Partner’s applications installed on Devices (as defined in Section 1 above). The categories of Partner applications through which we collect Personal Information include the following:

  • Weather applications

  • Shopping applications

  • Utilities applications

  • Sports applications

  • Gaming applications

  • Lifestyle applications

  • Education applications

  • Health & Fitness applications

  • Maps & Navigation applications

  • Music & Audio applications

  • Social applications

We also may purchase Device User information from data aggregation companies.

4.2 Website Users

We collect Information directly from Website Users to the extent you directly interact with us, or in the provision of our Services. We also use tracking tools like browser cookies and web beacons to passively collect Information from Website Users. We collect Information about Website Users over time when you use this Website. We may have third parties collect Personal Information in this way. We do this to understand the visitors to our site and better communicate with them – no information collected passively from our Website is incorporated into our Services.

4.3 Customers and Partners

We collect information directly from Partners and Customers to the extent you directly interact with us or in the provision of our Services.

5. How Do We Use Your Personal Information?

5.1 Device Users

We Combine Information. As part of the Services we provide to our Customers, we combine all Information we receive about you into one data set, which we may further customize based on the needs of our Customers. For example, we may combine Personal Information that we have collected about you from our Partners (described in Section 2.4 above) with Information we have purchased from data aggregators. We may also combine Information we have collected from you with Personal Information we purchase.

We Draw Inferences from Your Data. As part of the Services we provide to our Customers, we use all available Information we collect to draw inferences about Device User location and movement patterns and to create custom reports for our Customers. Examples of inferences could include where we think a Device User lives or works, places they visit, activities they engage in, preferences, interests, or just how they move through the world. In so doing, we may identify other locations of interest, where the Device may go, or predicted future behaviors. We will also create inferences from the other Personal Information that we collect about you. We build these inferences into the Services that we sell to our Customers.

We Use Your Data for Marketing and Research. We use Device User Personal Information for the following purposes related to marketing and research, as part of the Services we provide to our Customers:

  • Segmentation and Ad Targeting. We use location information, personal identifiers, inferences, commercial, demographic, and device information for marketing, advertising and research purposes. This information is used to better predict and draw insights about consumer, market or scientific trends related to human movement patterns. These movements may include retail visitation, commute patterns, exposure to out-of-home advertisements, or visitation that could infer shopping behavior, which may be used to create profiles on individuals. These measures may be used to target advertising or inform marketing programs, measure them, or optimize media exposure based on real-world activities or trends.

  • Trend Analysis. We utilize aggregated location information, commercial information, and inferences to create trend-level analysis on consumer behavior, commercial activity, commodity generation and distribution, and general economic insights. All of these analyses are used individually and in conjunction with each other to provide trend activity and economic measurements of markets, consumer behavior, and how that may affect a business or stock price.

Smart Cities Aggregated Traffic Patterns and Research. We use aggregated Device User location information to draw insights about consumer, market or scientific trends related to human movement patterns. We may use or license this information to real estate professionals, city planners, transit authorities, or smart city companies, augmented with inferences, demographic, and commercial information to create more specific segments. For example, we may infer whether an aggregate group of Device Users drive vs walk to determine whether to put a bus stop in an area or to understand the flow of traffic over time to help a Customer determine whether or not to purchase real estate.

Security. We use Device User Personal Information for the following purposes related to security as part of the Services we provide to our Customers:

  • Asset Management. We use location information over time to track Device movement to maintain the location and utilization of equipment for our enterprise Customers. This enables us to track and detail where equipment and assets are, the estimated utilization and maintenance schedule, use life of each piece of equipment, and future cost analysis for upgrades or replacements.

  • Facility Security. We use aggregated location information to create location perimeters and determine risk based on activity and incursion into those spaces. We also look at overall security and threat potential across multiple facilities and industries. We may measure the regular inhabitants of a location and determine any anomalous behaviors or Devices.

  • External Threat Analysis. We may use location information, personal identifiers, Device information, commercial information, and inferences to do complex analysis on threats, both physical and cyber, for enterprises and their facilities, national, state, or local public authorities, individuals and their security teams, and other organizations.

Media and Marketing Attribution. By using Device User Personal Information (specifically location information) over time we create movement data to measure foot traffic of Device User movement to retail locations. We use this dataset in combination with inferences and commercial information about Device Users for targeting media messaging to those individuals whose activity indicates they would be receptive to associated messaging. We also measure the effectiveness of that messaging by looking at post-media exposure activity to measure and calculate the effectiveness of the media exposure.

Publisher Insights and App Analytics. We use Device User Personal Information (specifically application usage information) to provide our Partners with an analytics and measurement product based on Device activity within their apps. We also use Application Usage information to determine app usage in a specific geographic region.

5.2 Website Users

Maintain or Improve Our Website and Services. We use Device information and internet or network activity Information from Website Users to improve our Website and Services.

5.3 Customers and Partners

Provide Services. We may use your contact information in order to provide our Services, contact you and respond to your requests. We also use your payment information to send and receive funds to and from you.

Marketing Purposes. We use personal identifiers to send Partners and Customers information about our products or Services. We also use personal identifiers to tell Partners and Customers about new features or updates.

Security and Fraud Prevention. We use personal identifiers, device information, payment information, and internet and network activity information to protect our website or Services, our company, and others and to prevent fraud, theft, and misconduct.

Transactional Purposes. We use your personal identifiers to contact you about this Notice or our terms.

We use your Information as otherwise permitted by law.

6. How Do We Share or Sell Your Personal Information?

6.1 Device Users

VenPath sells Device Users’ Personal Information to the following categories of recipients:

  • Customers. We share or sell Device User information, including personal identifiers, location information, commercial information, demographic information, device information, and inferences, through the provision of our Services to Customers. This includes the sale of our Services, which we produce using combined Personal Information, and includes inferences, marketing and research, government/smart cities, security, attribution, or publisher insights, as described in detail above. Customers may use your data for the same purposes for which VenPath uses your data, in addition to other purposes determined by the Customers. Our Customers may include advertisers, media, data analytics providers, governmental authorities or their representatives or contractors, city planning commissions, transportation authorities, academic researchers, financial services providers, and any other enterprise requiring our Services.

  • Partners. We share application analytics created from Device User information with our Partners that initially provided us with your Information. This information can be specific to an individual Device User or aggregated information. Our Partners may include mobile application developers, such as: weather applications, shopping applications, utilities applications, sports applications, gaming applications, lifestyle applications, education applications, health & fitness applications, maps & navigation applications, music & audio applications, social applications and other data aggregation Partners.

6.2 Device Users, Website Users, Customers, and Partners

VenPath shares Personal Information from Device Users, Website Users, Customers, and Partners with the following categories and types of recipients:

  • Service Providers: From time to time, we may establish a business relationship with another business that provides us with certain services, when we believe that business is trustworthy and when we have confirmed that its privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as      

    o   hosting and maintenance;

    o   data storage and management;

    o   analytics and marketing;

    o   customer service; and

    o   payment processing.

    We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

  • Affiliates: We may share Personal Information with businesses controlling, controlled by, or under common control with VenPath.  Currently the only entity that may have access to Personal Information is VenPath, Inc.

  • Corporate Transactions: If VenPath is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer any Personal Information in connection with such transaction to the extent permitted by law. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Notice.

  • Compliance with Laws and Law Enforcement: We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if we are compelled by law or regulation, or where the company deems it appropriate. This may also include responding to legal requests (including court orders and subpoenas), assisting to protect the safety, property, or rights of our company or of any third party, or to comply with the law.

7. Cookies and Other Online Tracking Technologies as Applicable to Website Users

VenPath uses cookies or similar technologies to analyze trends, to administer the Website, to track Website Users’ movements around the Website, and to gather demographic information about our Website User base as a whole.

“Cookies” are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use cookies to monitor traffic, improve the Website and make it easier and/or relevant for your use.

Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your web browser to decline cookies, some features of the Website may not work or may not work as designed. For more details on our use of cookies, please review our Cookie Notice.

Some content or applications, including advertisements, on the Website are served by unaffiliated third parties, including advertisers, ad networks and servers, content providers and application providers.

Your browser or device may include “Do Not Track” functionality. Because a “Do Not Track” compliance protocol has not yet been finalized, VenPath’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Notice, whether or not a Do Not Track signal is received.

To learn more about the use of this information or to choose not to have this information used by our third party advertising partners by opting out, please visit the Network Advertising Initiative by clicking http://www.networkadvertising.org/managing/opt_out.asp. You can also opt out of interest-based advertising by clicking here or, if located in the European Union, here. Please note you will continue to receive generic ads even if you opt out of targeted advertising.

8. Your Privacy Rights

As a part of complying with applicable privacy laws in the jurisdictions in which we operate, we provide Device Users, Website Users, Customers, and Partners with the following rights regarding their Personal Information:

8.1 Rights Under GDPR and Additional Information to European Residents

If you are located in the European Economic Area or another jurisdiction covered under a law substantially similar to the GDPR (such as the United Kingdom), we will take the following additional steps when processing your Personal Information.

8.1.1 Legal Basis for Processing Your Personal Information

The GDPR requires that we notify you of each legal basis that we rely upon to process your Personal Information. We rely on the following legal bases to process your Personal Information, as described in the “How Do We Use Your Personal Information” section above.

8.1.1.1 Device Users

Consent: In some instances, we rely on Device User consent to process your Personal Information. Where a valid consent is gathered from a Device User, either through VenPath’s own consent solution or a consent solution implemented by a VenPath Partner or affiliate, we may rely on it to process location information and other Personal Information collected from a Device or a Device User as described in this Notice. In particular, we may rely on your consent to combine Personal Information that we collect and to draw inferences and to create profiles. If we are processing your Information based on your consent, you will know it, because you will have made the decision to consent to that processing before the processing took place.

Withdraw consent: If we are processing your Personal Information based upon your consent, you have the option to withdraw that consent at any time, which can be done by visiting https://www.venpath.net/legal/opt-out/. When you withdraw your consent, we will terminate any processing activities that were based upon your consent. Please note, however, that processing activities based on another lawful basis, such as our legitimate interests, may still continue.

Legitimate Interests: In many instances, we rely on our legitimate interests to process your Personal Information as described above, and as necessary to provide the Services, so long as they are not overridden by your own rights and interests. When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis. To do so, please use the contact details listed below.

8.1.1.2 Website Users, Customers, and Partners

Performance of a Contract: We process Personal Information of Customers and Partners as necessary to provide Services or as otherwise required to enter into or meet our contractual obligations. Customers and Partners have the right to refuse to provide Personal Information for this purpose. However, such refusal will compromise VenPath’s ability to provide its Services and to communicate updates regarding its Services.

Legitimate Interests: We rely on our legitimate interests to process Personal Information, so long as they are not overridden by your own rights and interests. This includes processing Personal Information for purposes such as security, assisting law enforcement, or detection of fraud, or, when you are using our Website or as our Customer, for marketing purposes or transactional purposes. When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis. To do so, please use the contact details listed below.

Legal Obligation: We may process Personal Information based on a legal obligation to which we may be subject, to protect the vital interests of you or another person, or because such processing is in the public interest.

8.1.2 Individual Rights Under GDPR

Under the GDPR, Device Users, Website Users, Customers, and Partners have certain rights as they relate to Personal Information and our processing of such Personal Information. These rights, described below, are not absolute and may be subject to exceptions and verification. We will notify you if this applies. Each of these rights can be exercised by using the contact details below or by making your request at https://www.venpath.net/legal/opt-out/. Depending on the request, we may ask for additional information to verify your identity and jurisdiction.

Right of Access: You have the right to request a copy of the specific pieces of your Personal Information that VenPath processes.

As part of the right of access, you also have the right to receive information about: (1) the purposes of processing; (2) the categories of Personal Information concerned, (3) the recipients or categories of recipients to whom VenPath has or will disclose your Personal Information, in particular recipients that are not governed by the GDPR; (4) the anticipated retention period for your Personal Information or the criteria used to determine that period; (5) information about your other rights under the GDPR as a data subject, including the right to lodge a complaint with a supervisory authority; (6) information about the source of your Personal Information if VenPath did not collect it directly from you; and (7) whether VenPath uses your Personal Information to engage in automated decision-making, including profiling, and, if so, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Right to Correct: You have the right to request that we correct any of your Personal Information that is inaccurate, and, where you contest the accuracy, you have the right to restriction of processing.

Right to Erasure: You have the right to make a request to erase any Personal Information VenPath has collected about you. We will delete your Personal Information per your request and will also communicate your deletion request to our Service Providers and direct them to delete your personal information.

Right to Withdraw Consent: If you previously provided your consent to one of the Partners that we rely on to process your Personal Information, you have the right to withdraw that consent at any time.

Right to Object: You have the right to object to the processing of your Personal Information as described in this Notice. You have the right to object to the use of inferences, including for marketing purposes.

Right to Restrict Processing: You have the right to request that VenPath restrict the processing of your Personal Information as described in this Notice in certain circumstances. This means that VenPath can continue to retain your Personal Information but cannot continue to actively use it. This right applies in certain instances, such as when you believe that the Personal Information that VenPath holds about you is inaccurate or the processing activities are unlawful.

Right to Data Portability: You have the right to request the Personal Information we hold and to have it transferred to another data controller of your choice as long as this right does not adversely affect the rights and freedoms of others.

Right to Lodge Complaints: You have the right to lodge a complaint with the local Data Protection Authority in the EU Member State of your habitual residence, place of work, or where the alleged infringement of the GDPR took place.

8.1.3 Data Transfers and Retention Under GDPR

We may transfer Personal Information outside of the EEA to third parties as described in section 6, including to our servers in the United States. We ensure any such transfers of Personal Information have the appropriate safeguards in place through implementation of the European Commission approved standard contractual clauses under Article 46.2 of the GDPR. VenPath remains liable for the protection of Personal Information that we transfer or have transferred to third parties, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing. 

8.1.3.1 Website Users, Customers, and Partners

We retain Customer and Partner Personal Information for as long as needed to provide you with Services you have requested. We will also retain and process Personal Information as necessary to comply with our legal obligations, resolve disputes and enforce agreements.

8.1.3.2 Device Users

We retain GDPR-covered Device User Personal Information for thirteen months from the date of collection, in part so that we may analyze annual trends in Device User activity, at which time we either delete it or render the information fully de-identified. We use our best efforts to ensure that the data we retain is kept up to date and accurate. We may keep Personal Information for a longer period of time only where we have a legal or business need to do so, such as for auditing, corporate record-keeping, compliance, accounting, security, or bug-prevention purposes.

8.2 Rights Under California Law

Under current California law, California residents have certain rights as it relates to our collection, use, and processing of their Information. These rights are not absolute, and all requests are subject to exceptions and verification. VenPath may be required or permitted by law to decline any request. Only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to accessing or deleting your Personal Information.

You or your authorized agent can submit a request to VenPath at https://www.venpath.net/legal/opt-out/ or you can submit your request through the email address listed at the end of this Notice. In the subject line, include “CCPA Consumer Request,” and note in the body of the email whether you are seeking to access, delete, or opt-out of sale of your information.

To protect the privacy of your Personal Information, we are required to verify your request. Verifiable requests must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to the request. If you make a request to know or delete, in certain circumstances, we may ask you to verify your identity and proof of California residency, which may include a signed declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request.

When VenPath receives a consumer request, we make every effort to honor your request. We maintain records of all the requests received, the time it takes to respond to requests, and we track the outcomes of all requests.

Right to Access. You can make a request to access the categories or specific pieces of Personal Information VenPath collected, used, or shared about you in the past twelve (12) months.

Right to Delete. You can make a request to delete any Personal Information VenPath has collected about you. We will also communicate your deletion request to our Service Providers and direct them to delete your Personal Information.

Right to Opt-Out of Sale. Upon receiving a valid opt-out of sale request we will stop and refrain from selling any of your Personal Information. We will also communicate your opt-out of sale request to relevant third parties.

Right to Non-Discrimination. VenPath values giving consumers control over their privacy and Personal Information. If you choose to exercise any of your rights under the CCPA, we will not differentiate our Services as a result of your decision. We also do not offer any financial incentives to opt-in to sell your Personal Information.

Right to Correct Inaccurate Personal Information. You can make a request to correct your inaccurate personal information.

Right to Know What Personal Information is Sold or Shared and to Whom. You can make a request to know what personal information about you that we sell, share, or disclose for a business purpose. This includes:

  • the categories of personal information that we collect about you;

  • the categories of personal information about you that we sell or share;

  • the categories of third parties to whom we sell or share personal information about, as well as the categories of personal information sold or shared with each category of third party; and

  • the categories of personal information about you that we disclose for a business purpose and the categories of persons to whom it was disclosed to.

Right to Limit Use and Disclosure of Sensitive Personal Information. As we collect sensitive personal information about you, such as precise geolocation data, you may request that we limit the use and disclosure of your sensitive personal information to only what is reasonably necessary to perform our services. 

Use of an Authorized Agent. You can appoint a person or a business entity registered with the Secretary of State to act on your behalf. In order to do so, you must provide the authorized agent with written permission to do so. Your authorized agent should submit a copy of your written authorization. This can be done by attaching the written authorization to any request sent to the email contact listed at the end of this Notice. VenPath may request more information from the authorized agent if needed to verify the authorized agent’s identity or to avoid any breach of security or instances of fraud.

9. How Do We Secure Your Information?

We maintain commercially reasonable physical, electronic, and procedural safeguards to secure your information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, we are unable to guarantee that security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances.

10. Notice of Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location and may be deemed by your country to have inadequate data protection. If you are located in a country outside the United States and submit Personal Information to us, you thereby consent to the general use of such information as provided in this Notice and to the transfer of that information to, and/or storage of that information in, the United States of America. If you are uncertain whether this Notice conflicts with the applicable local privacy laws where you are located, please do not use this Website.

11. Managing Your Information Preferences

You can review, correct, update, or change your Personal Information or opt out of receiving certain e-mails by changing the relevant settings in your account or by e-mailing us at [email protected]. You can also opt out of receiving marketing e-mails from us by following the link provided at the bottom of all marketing e-mails you receive from us. You are able to opt out of receiving marketing e-mails from us. However, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account. If you have questions or concerns regarding this Notice, please e-mail us at that same address.

12. Children’s Information

We do not knowingly collect Personal Information of minors under the age of 16 or collect data from Partners who target minors under the age of 16. If a Device User identifies themselves as a minor under the age of 16, our system de-identifies all data associated with the unique identifier. If you are either a minor under the age of 16; or a parent or legal guardian of a child under the age of 16 you may submit a request to know, opt out, or delete at https://www.venpath.net/legal/opt-out/ or by sending an email with the subject line “Minor Information Request” to the email address listed at the bottom of this Notice. Note that all requests are subject to appropriate verification.

13. Changes to this Notice

We may change the terms of this Notice from time to time without notice. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

14. How to Contact Us

If you have questions about this Notice, please contact VenPath via e-mail at [email protected] with “PRIVACY NOTICE” in the subject line or by mailing us at the following address:

VenPath
228 Park Ave S #37362
New York, New York 10003-1502

We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question.