Last Updated: May 24, 2018
- A Note About Children
- Personal Information Collection and Use
- Updating or Removing User Information
- Information Collected on Behalf of our Clients
- Law Enforcement; Subpoenas
- Service Providers
- Cookies and other Tracking Technologies
- Change of Ownership
- Data Retention
- Residents of the European Economic Area (“EEA”)
- Dispute Resolution
- Contact details
For the purposes of this Policy, “Personal information” means any information or set of information that identifies or could be used to identify an individual or is otherwise associated with that information. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with personal information.
“Non-Personal Information” is information of an anonymous nature, such as the domain used to access the Website or Services, and the type and version of browser or operating system being used by visitors to access the Website or Services. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical location of our users), number of visitors, what pages users access or visit, and average time spent on the Website or Services is not considered Personal Information. Similarly, business contact information such as the name, title, business address, e-mail address, or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.
Although the use of certain Non-Personal Information collected, used or disclosed through the Internet as described herein is not restricted (and to the extent that such is the case, the obligations under this Policy do not apply to such information), we provide information in this Policy about the collection of such information for the sake of transparency with respect to the operation of the Website and Services. Such Non-Personal Information is collected or derived by us in the course of operating this Website and our Services. For example, our servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie.
This Policy applies to www.venasolutions.com (the “Website”) and our cloud application run as Software as a Service (SaaS) owned and operated by Vena Solutions (collectively, the “Services”). This Policy describes how Vena Solutions collects and uses the Personal Information through the Services. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. Unless otherwise specified in this Policy, the use of Personal Information collected through our Services shall be limited to the purpose of providing the services for which the Client has engaged Vena Solutions.
A Note About Children.
The Services are intended for use by business users. Accordingly, we do not intentionally gather Personal Information from minors including from visitors who are under the age of 16. If a child under 16 submits Personal Information to Vena and we learn that the Personal Information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at email@example.com.
Personal Information Collection and Use
- To administer your account
- To contact and correspond with you;
- To enable your use of the Services;
- To understand your needs and develop and recommend suitable products and services;
- To process transactions and payments;
- To facilitate and enhance your use of the Website;
- To understand how you interact with and use the Website and Services and improve the Website and Services; and
- To meet legal and regulatory requirements.
For example, when using the Services, including registering for the Services, you may be required to provide us with contact information or account registration information which includes but is not limited to your name, email address, phone number, and company name. The information you provide will be used by us to administer your account, send you marketing emails, respond to your questions, and fulfill your business requests while using our Services. If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us using the contact information found at the bottom of this Policy.
We will share your Personal Information with third parties only in the ways that are described in this Policy.
Updating or Removing User Information
You may, at any time, choose to correct or update the information you have submitted to Vena, by updating your account on our Website or by contacting us at firstname.lastname@example.org. You can also contact us at email@example.com with other requests related to your data. If your details are provided through a corporate account, then you may need to contact the administrator that corporate account.
We will retain Personal Information we process on behalf of our Clients for as long as needed to provide services to our Client(s) and to comply with our legal obligations, resolve disputes, and enforce our agreements. If you cancel your account, your Personal Information along with other information may be retained in our archive or backup records. Please see Data Retention below.
Information Collected on Behalf of our Clients
Vena Solutions collects information under the direction of its Clients, and has no direct relationship with the individuals whose Personal Information it processes. If you are a customer or employee of one of our Clients and would no longer like to be contacted by one of our Clients that use our Services, please contact the Client that you interact with directly.
Law Enforcement; Subpoenas
Vena may disclose Personal Information, including the information you submit to the application service, with or without notice (a) if required by a subpoena, bankruptcy proceedings, similar legal process or other judicial or administrative order, (b) where required by law, or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual or the general public or to prevent violation of our agreements or the rights of Vena Solutions or any third party.
As at the date of this Policy, we share Personal Information about you in respect of the Website and Services only with our service providers and partners which include website hosting, cloud service providers, analytics providers, email marketing providers and payment processors. Our service providers may host data worldwide and accordingly your Personal Information may be available to governments worldwide under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information. In particular, Vena Solutions uses the following third-party service providers that process Personal Information on its behalf:
- Amazon Web Services – Vena Cloud hosting provider
- WPEngine – Marketing website hosting provider
- GSuite – Corporate Email services
- Marketo -Marketing service provider
- Salesforce – CRM provider
- SalesLoft – Sales engagement provider
- Zendesk – Customer service provider
From time to time we may employ third parties to help us improve the Website and/or the Service. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the Website, and/or the Service and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf.
Cookies and other Tracking Technologies
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, operating system, date/time stamp, and/or clickstream data.
System Logs & Cookies: Cookies are used by us to track content usage and traffic on the Website. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. Cookies help us compile aggregate statistics about usage of this Website and the Services, such as how many users visit the Website, how long users spend viewing the Website, and what pages are viewed most often. This information is used to improve the content of the Website and App. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website, App or Services.
Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information on our databases.
Change of Ownership
Residents of the European Economic Area (“EEA”)
We generally process Personal Information in order to fulfill contracts we have with our customers and to pursue our legitimate business interests listed above. Otherwise, Vena Solutions will obtain consent from an individual in respect of processing of Personal Information if required by law to do so. Further, individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) (“EU Data Protection Law”) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individuals located in to the EEA who wish to exercise these rights, should contact Vena at firstname.lastname@example.org. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.
EU Data Protection Law sets out a number of different reasons for which we may collect and process your personal data in certain circumstances. Where EU Data Protection Law applies, the legal bases we rely upon include:
- Consent: We can collect and process your data with your consent, where required by the EU Data Protection Law. We will explain how we intend to use your personal information where we ask for your consent, and will only use it for that purpose. For example, if you have given your consent to receiving marketing material from us then we will provide you that marketing material. You can withdraw your consent at any time.
- Contractual obligations: We need your personal data to comply with our contractual obligations. For example, where you have provided us with your email address to receive access to our Services, we will use this information in order to effectively deliver and communicate information to you in regard to such products and services. This type of information includes that set out in the “Personal Information Collection and Use” section above.
- Compliance with legal obligations: If the law requires us to, we may need to collect and process your data for legal compliance reasons. For example, we can pass on details of people involved in fraud or other criminal activity.
- Legitimate interest: We may require your data to pursue our legitimate interests or those of a third party in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, it is in our legitimate interests to (a) ensure that content from our Websites are presented in the most effective manner for you and your computer and that we provide you with the information, products and services that you request from us, (b) to keep our Website and our Services safe and secure;(c) for measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you (including individual and pseudonymous analysis and profiling); (d) to allow you to participate in interactive features of our Services (if applicable), and (e) to use marketing related information about you that we have lawfully collected.
If you are an EEA citizen, Personal Information hosted on our behalf is stored in Ireland, however the Personal Information that we process in relation to you may be transferred and stored by our third party service providers at destinations outside the EEA that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.
We may transfer your personal data outside the EEA:
- in order to host or store it;
- in order to enable us to provide goods or services to and fulfil our contract with you or the company your work for;
- where we are legally required to do so;
- in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
- Where your information is transferred outside the EEA, we take steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as where applicable relying on a recognised legal adequacy mechanism and contracts, to help ensure your rights and protections travel with your data and that your personal data is treated securely and in accordance with this Policy.
If you are an EEA Citizen, you have the following additional rights under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns about your information);
- to object to the further processing of your personal data, including the right to object to marketing; and
- to request that your personal data be moved to a third party.
In order to exercise these rights, you may contact us using the contact details set out below. We may ask for further information to clarify your identity and location. If you are a customer or employee of one of our Clients, please contact the Client that you interact with directly., as in that circumstance we will be acting as a data processor, not a data controller.
Any questions or concerns regarding the use or disclosure of personal information should be directed to Vena Solutions at email@example.com. Vena Solutions will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.
This Policy may be amended from time to time, and appropriate public notice will be given concerning material amendments or changes to this Policy. 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 the Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Access and Accuracy: You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
Upon request Vena will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. To request this information please contact us by telephone or email.
If you wish to contact us regarding our processing of your personal information, you may do so using any of the following:
- email: firstname.lastname@example.org
- phone: 1.855.207.1770
- address: 2 Fraser Avenue, Suite 200, Toronto, ON, Canada, M6K 1Y6