Section 1. Information We Collect
Information Related to Your Interaction with Ventulino and the Offerings.
Registration and Contact Information. We collect information about you when you (a) register to use the Services and (b) otherwise provide contact information to us via
email, mail, or through our Offerings. This information you provide may include your
username, first and last name, email address, mailing address or phone number.
Payment Information. When you purchase the Services, we will also collect transaction information, which may include your credit card information, billing and mailing address,
and other payment-related information (“Payment Information”). We describe how Payment Information may be collected and processed in Section 4.
Technical, Usage and Location Information. We automatically collect information on
how you interact with the Offerings, such as the IP address from which you access the
Offerings, date and time, information about your browser, operating system and
computer or device, pages viewed, and items clicked. We may also collect location
information, including location information automatically provided by your computer or
Third Party Platforms. We may collect information when you interact with our
advertisements and other content on third-party sites or platforms, such as social
networking sites. This may include information such as “Likes”, profile information
gathered from social networking sites or the fact that you viewed or interacted with our
Other Information. We may collect other information from you that is not specifically
as otherwise permitted by you.
You may submit various types of information and data into the Services for hosting and
processing purposes (“Customer Data”). Customer Data may include, without limitation,
(a) personal information such as names, email addresses and phone numbers of your
end user customers, potential customers and other users of and visitors to your
websites, apps and other properties (“People”), which information may be input into the
Services by you or collected by the Services using Ventulino tags, scripts and other
code implemented on such properties, and (b) information contained in
communications between you and People using the messaging features of the
Section 2. How We Use the Information We Collect
We use your information in the following ways:
● To provide, maintain and improve the Offerings and our other products and services, including to operate certain features and functionality of the Offerings (for example, by remembering your information so that you will not have to re- enter it during this or subsequent visits);
● To process your inquiries and otherwise deliver customer service;
● To process your payments, we share and use Payment Information as described in Section 4 (Payment Information);
● To control unauthorized use or abuse of the Offerings and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
● To analyze trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole;
● To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in Section 6 (Your Controls and Choices)
● To deliver you advertising, including by serving and managing ads on the Offerings or on third party sites and to tailor ads based on your interests and browsing history. Please see Section 6 (Your Controls and Choices) for additional information on how to manage the ads you see; and
Section 3. Sharing Your Information with Third Parties
We do not sell, trade, share or transfer your personal information to third parties except in the following limited circumstances:
● We may share your personal information with our parent companies, subsidiaries and affiliates;
● We may share your personal information with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Offerings, among other things. For example, we may provide personal information to our service providers for direct emailing of our newsletters or notifications of our product/service offerings;
● We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
● We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
● We may share your personal information with our business partners who offer a service to you jointly with us, for example when running a cross-promotion;
● We may share your Payment Information to process your payments, as further described in Section 4 (Payment Information);
● We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets; and
● We may share your personal information with a third party if we have your consent to do so.
We may also share aggregated or anonymized information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information such as the types of Offerings our customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which we collected through our technology. If we are required under applicable law to treat such information as personal information, then we will only disclose it as described above. Otherwise we may disclose such information for any reason.
Section 4. Payment Information
When you make a purchase on the Offerings, any credit card information you provide as
part of your Payment Information is collected and processed directly by our payment
processor PayPal through their PayPal Checkout service. We never receive or store
your full credit card information. PayPal commits to complying with the Payment Card
Industry Data Security Standard (PCI-DSS) and using industry standard security. PayPal
Section 5. Other Access to or Disclosure of Your Information
solely to information collected by us. Even if the third party is affiliated with us through a
business partnership or otherwise, we are not responsible for the privacy practices of
such third party. We encourage you to familiarize yourself with the privacy policies of
such third parties to determine how they handle any information they separately collect from you. Please be aware that we do not warn you when you choose to click through
to another website when using the Offerings.
The Websites contain features that enable you to post reviews, comments or other
content that is publicly viewable. You should be aware that any personal information
you submit as part of those posts can be read, collected, or used by other visitors to the
Websites, and could be used to send you unsolicited messages. We are not
responsible for the personal information you choose to publicly post on the Websites.
Please see our
about posting content on the Websites.
Section 6. Your Controls and Choices
Opt-Outs. We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Offerings to you.
Communication Preferences. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Offerings. Please note, however, that you may be unable to opt-out of certain service-related communications.
How We Respond to Do Not Track Signals. Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Offerings do not respond to this type of signal.
Section 7. Accessing and Updating Your Personal Information
When you use the Offerings, we make good faith efforts to provide you with access to your personal information upon your request and either provide you the means to correct this information if it is inaccurate or to delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
You may access, review, correct, update, change or delete your information at any time.To do so, please contact us at email@example.com with your name and the information requested to be accessed, corrected or removed. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Please note that if you cease using the Service or we terminate your access to the Service in accordance with your Master Services Agreement, you may no longer have the ability to access or update your information. We may retain your information as necessary to support the Offerings, comply with our legal obligations or resolve disputes. Note that content you post may remain on the Offerings even if you cease using the Offerings or we terminate your access to the Offerings.
Section 9. No Children Under Age 13
Section 10. Your California Privacy Rights and Disclosures
California Shine the Light Law. If you are a California resident and we disclose your
personally identifiable information to third parties for such third parties’ direct marketing
purposes, California’s Shine the Light Law (CA Civil Code Section 1798.83) allows you to
request certain information from us about such disclosures. To make a request under
the Shine the Light Law, please contact us at firstname.lastname@example.org. Please note that
under California law, businesses are not required to respond to such requests more
than once during any calendar year.
California Minors. At any time, you can delete or remove your posts using the same
deletion or removal procedures described in Section 8 (Accessing and Updating Your
Personal Information) above, or otherwise through the Offerings. If you have questions about how to remove your posts or if you would like additional assistance with deletion you can contact our support team email@example.com Although we offer deletion capability for our Offerings, you should be aware that the removal of posts may not ensure complete or comprehensive removal of that content or information posted through the Offerings.
Section 11. Security
The security of your personal information is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Further, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect personal information about you. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
Section 12. International Transfer of Data; EU- U.S. and Swiss-U.S. Privacy Shield
Section 13. Where can I get further information?
E.U. – U.S. and Swiss – U.S. Privacy Shield Policy
We, Ventulino, LLC (“Ventulino” “we” or “us”), are committed to protecting your privacy. This Policy sets out the privacy principles we follow with respect to transfers of personal data from the European Economic Area (“EEA”) and Switzerland to the United States, including personal data we receive from individuals residing in the EEA or Switzerland who visit our web and mobile sites or apps and/or who use any of our services or otherwise interact with us (“you”).
To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/ With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Ventulino is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC).
Section 1. Types of personal data we collect and use
Section 2. Data transfers to third parties
- Agents, consultants and service providers: We may share your personal data with our contractors and service providers who process personal data on our behalf to perform certain business-related functions. These companies include database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including personal data, in connection with their performance of such functions.
● Our Group Companies: We may also share your personal data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Policy.
● Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.
● Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
● Legal Requirements: We may disclose your personal data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency ,or in the good faith belief that such action is necessary (a) to comply with a legal obligation, (b) to protect or defend our rights, interests or property or that of third parties, (c) to prevent or investigate possible wrongdoing in connection with the Services, (d) to act in urgent circumstances to protect the personal safety of Users of the Services or the public; or (e) to protect against legal liability. Ventulino’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Ventulino remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Ventulino proves that it is not responsible for the event giving rise to the damage. Ventulino is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Section 3. – Security
We maintain reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
Section 4. Access Rights
In general, when processing personal data to provide our services, we do so only on behalf of our customers and in accordance with their instructions. This means that if you wish to access any personal data we process on behalf of a Ventulino customer and request that we correct, amend, delete it if it is inaccurate or processed in violation of Privacy Shield, you should contact that customer with your request. We will then help them to fulfill that request in accordance with their instructions.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should submit a written request to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Section 5. Your Choices
You may choose to change personal data or cancel an account by contacting us using the contact details below. You can also unsubscribe from our marketing communications by following the instructions or unsubscribe mechanism in the e-mail message. We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com
Section 6. Questions or complaints
In compliance with the Privacy Shield Principles, Ventulino commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact us by email at firstname.lastname@example.org. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data within 45 days of receiving your complaint.
Ventulino has further committed to refer unresolved privacy complaints to, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus (the “BBB”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.bbb.org/EU-privacy-shield/for- eu-consumers for more information or to file a complaint. This services of the BBB are provided at no cost to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Section 7. How to Contact Us
¡If you have any questions regarding this Policy or if you need to request access to or update, change or remove personal data that we control, you can do so by contacting
us at email@example.com
Changes to this Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy