Effective Date: December 31, 2019
Information that you may submit to us offline or to websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third-party websites.
VenPath’s hosted data marketplace delivered to customers through means other than the Website (the “Marketplace”). To understand how VenPath handles its Customer’s non-PII (as defined below) with respect to VenPath’s Marketplace, please consult your [License Agreement] governing that service.
Consumer data collected through Data Supply Side Platform (DSSP). For more information about VenPath’s consumer privacy practices and models, including its collection of information via our DSSP, mobile identifiers and cookies, visit.
VenPath participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. VenPath is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
VenPath is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. VenPath complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, VenPath is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, VenPath may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
I. What Information Is Collected and Stored?
We collect two types of information from you in conjunction with your use of the Website: non-personally identifiable information (“non-personally identifiable information” or “non-PII” and personally identifiable information (“PII”). Non-personally identifiable information includes information that does not identify you personally, but it may include tracking and usage information about your location, demographics, use of the Website and the Internet. “). PII is any information that can individually identify you. We collect PII on the site which includes but is not limited to your company name, your name, and e-mail address.
A. Information Collected
We collect information under the direction of our Clients, and have no direct relationship with the individuals whose personal data we process. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
When you interact with the Website as an end user, we may collect certain information, such as device information about your computer, mobile device, or other device that you use to access the Website. This information may include IP address, location information, unique device identifiers, browser type, browser language, and other transactional information.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. We use this information to provide you a more customized experience on the Website.
Also note that when you interact with any VenPath social media platform, such as Facebook, Twitter, Google+, or LinkedIn, we may collect the PII that you make available to us on that page or account including your account ID.
B. Collection of Non-Personally Identifiable Information From Other Sources
We also may collect and store information about you that we receive from other sources (including by us from our offline interactions with you) to, among other things, enable us to verify, update and correct the information contained in our database and to better customize your experience on the Website. This information may include (emails, business name, location, demographic information, and other identifying data).
C. Cookies and Other Online Tracking Technologies
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 information on cookies and how to disable them, check out our Cookie and Tracking FAQs or visit www.allaboutcookies.org.
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.
II. How Do We Use Your Information?
We use the information we learn from you to help us personalize and continually improve your experience on the Website. We may use your PII to:
Provide you with the content you request.
Communicate with you about changes to our policies and send you information about features and enhancements on or to our Website.
Send you information about our products and services, third party products and services, or special events by e-mail, text, or another medium.
Optimize or improve our products, services and operations.
Detect, investigate, and prevent activities that may violate our policies or be illegal.
- Perform statistical, demographic, and marketing analyses of users of the Websites and their purchasing patterns.
We may also use and/or combine information that we collect off-line, or that we collect or receive from third party sources, to enhance, expand, and check the accuracy of user records.
III. Who Do We Share Your Information With?
B. Sharing of Information
We may disclose or share non-PII (or other information, other than PII) in any other manner that we deem appropriate or necessary. Among other things, we will disclose non-PII to third parties to help us determine how people use parts of the Website and who our users are so we can improve our Website. We will also disclose non-PII to our partners and other third parties about how our users collectively use the Website.
We will share your personal information with third parties only in the ways that are described in this privacy statement.
We may also use or disclose PII if required to do so by law such as to comply with a subpoena or other legal process, or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Website; (b) protect and defend our rights or property, the Website or our users, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Website or the public.
We may share your information with third parties who provide services on our behalf to help with our business activities such as analytics, sales support, customer segmentation, or other business purposes. These companies are authorized to use your personal information only as necessary to provide these services to us.
IV. How Can You Opt-Out?
You may always opt-out of receiving future e-mail marketing messages and non-transactional communications from VenPath. We provide you with the opportunity to opt-out of receiving such communications from us by clicking the “Do Not Sell My Info” link located at the bottom of any VenPath marketing email. Customers cannot opt out of receiving transactional emails related to their account with VenPath.
VenPath acknowledges that you have the right to access your personal information. We have no direct relationship with the individuals whose personal data we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the VenPath’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. You will not be permitted to examine the non-PII of any other person or entity and may be required to provide us with non-PII to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete non-PII if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect. Individuals may opt-out of having non-PII shared with business partners and third parties by sending an email to firstname.lastname@example.org with “CUSTOMER OPT-OUT” in the subject line.
We will use commercially reasonable efforts to process all opt-out and access requests in a timely manner. If you are a consumer who wants to opt-out of VenPath’s advertising databases, please email email@example.com with the subject line “Opt-Out”. Upon request Venpath will provide you as a customer with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe.
V. Other Important Information
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.
How Long Do We Keep Non-Personally Identifiable Information?
The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. VenPath will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Public and Community Areas
Please remember that any information you share in public areas, such as the comment sections of our VenPath blog (“Public Social Features”), becomes public and anyone may take and use that information. Please be careful about what you disclose and do not post any PII that you expect to keep private. Please consult the applicable guidelines, if any, for use of our Public Social Features for more information. VenPath cannot control who views information that you post in public areas of the Sites and is not responsible for how third parties may use or disclose information that you post in public areas of the Sites.
Notice to Non-US Users
Notice to California Users
Additional Rights For California Citizens
Your Rights Under the CCPA
Under the CCPA, California residents have certain rights around VenPath’s collection, use, and sharing of their personal information.
The below chart summarizes the categories of personal information we collect, where we collect it from, how we use it, and who we share it with. This chart is updated in an annual review and reflects the prior twelve (12) months from the date of last review.
|Categories Collected||Sources We Collect From||Purposes Behind Collection, Use, and Sharing||Categories of Third Parties We Disclose To|
Mobile advertising ID
|Your device |
Fraud or deceit detection
|Your device |
|Your device |
|Commercial Information |
|Our Providers||Advertising Services|
|Your device |
|Inferences (not personal information)|
Drawn to Create a Profile About a Consumer
such as preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|Your device |
Your Specific Consumer Rights From the CCPA
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.
To protect the privacy of your personal information, we are required to verify your request. Verifiable requests must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request. To 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. Along with your verified request, we will give you any categories of sources from which the personal information is collected; the purpose for collecting, selling, or sharing; and any categories of third parties with whom we share such personal information.
Right to Delete
You can make a request to delete any personal information VenPath has collected about you. Upon receiving a verified request, VenPath will notify you once your information has been deleted. We will also communicate your deletion request to our Providers and direct them to delete your personal information.
Right to Opt-Out of Sale
California broadly defines “sale” to include using services to deliver targeted advertising on other sites or applications. This means an opt-out of sale request will likely have a direct impact on the types of advertisements the requestor receives. A valid request will make VenPath 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.
Use of an Authorized Agent
Some Internet browsers allow users to send a “Do Not Track” signal to websites you visit. VenPath does not currently respond to this signal.
Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through VenPath, Inc.’s internal processes, VenPath, Inc. has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here https://www.verasafe.
Under certain conditions, an individual may invoke binding arbitration to resolve residual claims. VenPath is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
The Website is not intended for children under 13 years of age and VenPath does not knowingly collect personal information from children under 13 years of age.
Changes to this Policy
How to Contact Us
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.