Privacy Notice

Venn Ltd.

Privacy Notice

Recently Updated: July 2018

Venn Ltd. and its subsidiaries (together, “Venn”, “us”, or “our”) are committed to your right to privacy. In order to fully understand your rights, we encourage you to read this Privacy Notice (“Privacy Notice”), as well as our Terms of Use. [Please link Terms of Use hereto]

This Privacy Notice governs the processing and transfer of Personal Data collected in connection with our website, available at: www.venn.city (“Site”) or with services otherwise as may be provided by Venn (collectively, “Services”), to each person (“User” or “you”) accessing or using the Site and/or the Services.

If you choose to use the Services, interact with the Site, or otherwise provide data to us, you explicitly agree to the use of such data in accordance with this Privacy Notice. You may not use the Services or the Site or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Notice shall not be construed in any manner to derogate from the Terms of Use or any other agreement or understanding between Venn and you.

Please note, that the Site may contain links to other websites, products or services offered by third parties, which are not governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by Venn.

THE HIGHLIGHTS:

  • You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.
  • Our Site and/or Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to use the Services. If you are under such age you should cease to use the Site and/or Services immediately.
  • You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Site may be restricted or disabled.
  • We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Site and/or Services to our Users, or other limited circumstances as specified herein.
  • If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: services@venn.city
  1. What is Personal Data, and what data is collected about me by Venn?
    Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.

    Non-Personal Data

    We collect non-Personal Data regarding Users concerning their use of the Site and/or Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Site, device identifiers, and other technical information regarding the device used to access the Site, such as model, operating system, etc.

    Personal Data

    1. If you choose to use the “Contact Us” feature on our Site, you will be requested to provide certain Personal Data, such as full name, phone, e-mail address, etc.
    2. When you interact with our Site, we may collect additional information, such as session duration, page impressions, advertisements viewed or clicked on, Internet protocol (IP) address, and other data regarding your use of the Site, such as the frequency and the extent of your use.
    3. We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Site or collected by us, please inform us immediately.
  2. What will Venn do with my data?
    1. Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Site and/or Services, including among others, in order to measure and understand the level of engagement to our Site, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Site and/or Services and for developing new services and features.
    2. Personal Data. Personal Data is used only for the following limited purposes:
      1. To contact you in connection with questions or comments you send us though the “Contact Us” feature on our Site, and to provide you with information regarding Venn.
      2. To prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Site or the Service and to enforce our Terms of Use.
      3. To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.
      4. To improve the Services, and to develop new features, products and services.
      5. For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, as permitted under applicable law.
      6. To provide updates with respect to material changes to this Privacy Notice or our Terms of Use.
  3. Does Venn use cookies? [Please confirm the below]Yes, we use data files such as cookies, pixel tags, “Flash cookies,” or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as a customer; customize our Site, content, and advertising; measure promotional effectiveness; help ensure that your Account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our Site and/or Services.We use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you log out of your Account or close your browser. Persistent Cookies remain on your device until you erase them or they expire.
  4. How Can I Control My Personal Data?
    1. Reviewing and amending your Personal Data. You may send us a request in connection with reviewing your Personal Data to: services@venn.city. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the Site, as applicable to you.
    2. Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
    3. Portability of Personal Data. To the extent relevant to you and to the Site and/or Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
    4. Retention of Data. We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Site and/or Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.
  5. Will Venn Share My Personal Data With Others?
    WE DO NOT SELL OR RENT ANY OF YOUR PERSONAL DATA TO NON-AFFILIATED THIRD PARTIES FOR THEIR MARKETING PURPOSES.
    1. Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.
    2. We share Personal Data only under the following limited circumstances:
      1. With trusted partners and third parties who assist us in operating the Site and conducting our business, such as fraud prevention, bill collection, marketing and technology services.
      2. As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about products, services and communications.
      3. With Venn affiliates and connected companies, such as subsidiaries, sister-companies and parent companies
      4. To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
      5. Other third parties with your consent or direction to do so.
  6. What is the lawful basis under which Venn processes Personal Data?
    1. Certain processing activities conducted by us are based on the necessity of such activities for the performance of our Site and/or Services and the contract between us and our Users.
    2. Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.
  7. Will Venn transfer my Personal Data internationally?Our databases are currently located in Ireland. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.
  8. Persons under 16
    Our Site is a general audience website, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.
  9. Applicable Laws
    The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.
    For the purpose of this Privacy Notice “GDPR” means the General Data Protection Regulation (GDPR) (EU) 2016/679 as may be amended from time to time.
  10. Questions or concerns regarding privacy
    If you have any questions or concerns regarding privacy issues, please send us a detailed message to • services@venn.city and we will make every effort to resolve your concerns without delay.
    Venn may, at any time and from time to time, modify this Privacy Notice. Modifications to this Privacy Notice will be posted on the Site, and shall be effective as of the date in which they are posted on the Site.
    You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.
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