Privacy Notice - California Customers

 

Supplementary Information for California Consumers

If you are located in California, you may have rights under the California Consumer Privacy Act (the “CCPA”). The CCPA requires Venntel to provide California consumers with certain information about the processing of their “personal information” and rights available to them with respect to such personal information.

This Privacy Notice applies to personal information we collect as part of our Data Services, and through our Website. For a general description of the services provided by Venntel, the type of data we collect, how we share such data, and  secure it, please refer to our general Privacy Policy (the “Privacy Policy”). Any capitalized terms used herein and not defined shall have the meaning set forth in such Privacy Policy. This Privacy Notice for California residents supplements the information contained in such Privacy Policy and applies solely to California residents.

 

Personal Information

The CCPA defines “personal information” as “any information that directly or indirectly identifies, relates to, describes, or can be associated with or reasonably linked to a California resident or household” including, name, address, mobile device identifiers, precise location data, IP and cookie identifiers, inferences, and biometric data.

Since the CCPA requires that we disclose specific information about how we handle certain personal information collected about all California consumers, the scope of this section is different than the overall scope of our Privacy Policy, as explained above.

The following table discloses what categories of “personal information” (as defined by the CCPA) we have collected from or about California consumers within the last twelve (12) months:

 Personal Information Collected by Venntel         
CCPA "Personal Information" Category CCPA "Personal Information Examples" Website  Data Partners Your use of the Portal
Identifiers Name, address, device identifier, Internet Protocol (IP) address, email address, cookies, web beacons, account name, social security number, passport number, or other similar identifiers (i) Device identifier and IP address, and (ii) name, phone number, and email address, but only to the extent you have provided us with this information  when you submit a comment or request through our Website. Device identifier, IP address User Data, and as part of Usage Data only.
Customer Records Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Name, phone number No No
Internet or Network Activity Browsing history, search history, information on a consumer’s interaction with a website, or application Browsing history, search history, information on a consumer’s interaction with a website, or application Timestamp and lists of mobile applications from which location signals were received. As part of Usage Data only.
Geolocation Data Physical location or movements No Timestamp, latitude, longitude No
Professional or Employment Information Current or past job history or performance evaluations Yes, to the extent you provide us with this information as part of an application for employment. No Email address only.
Protected Classifications under California or Federal Law ("Demographic Data") Race, color, national origin, religion, gender, age, or disability No Age and gender No

 

Categories of Sources of Personal Information

We receive your personal information from the following categories of sources:

  • From you. Directly from you through your provision of the information to us directly on our Website or automatically from your use of our Website or as described in the Privacy Policy;
  • Our customers. Our customers may directly provide us with your information for our performance of services to them; and
  • Third Parties and Partners. Our third-party data suppliers (data resellers) who either directly or indirectly collect your personal information and provide it to us for our provision of the Data Services, as described in our Privacy Policy.

 

Use of Personal Information

Please refer to the  “How We Use Your Information” section of the Privacy Policy for information on how we use your personal information with respect to the Data Services and our Website.

 

Disclosing Personal Information for Business Purpose

Business Purpose

We may share your personal information with affiliates and service providers for a business purpose, which the CCPA generally defines as the use of personal information for operational or other notified purposes. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers;
  • Geolocation Data;
  • Internet or Network Activity;
  • User Data;
  • Usage Data; and
  • Demographic Data.

The following are categories of third parties to whom we have disclosed your personal information for a business purpose:

  • Our affiliates; and
  • Service providers.

 

Sale of Personal Information

In the preceding twelve (12) months, we have sold the following categories of personal information in order to monetize our Data Services:

  • Identifiers;
  • Geolocation Data;
  • Internet or Network Activity; and
  • Demographic Data.

We do not sell User Data or Usage Data that we collect as part of your use of the Portal. Categories of parties to whom we have sold your personal information:

  • Our affiliates;
  • Vendors;
  • Third parties, which include our customers, partners, federal law enforcement, and data management platforms.

 

Your Rights in Connection with Personal Information

The CCPA grants you a number of rights (subject to certain exceptions) with respect to your personal information that companies may hold about you. Each of your rights is outlined in more detail below:

  • Right to Know. You have the right to request that we tell you:
    • the categories of personal information we collected, sold, or disclosed for a business purpose in the previous 12 months;
    • the categories of sources from which we collected such personal information;
    • the business or commercial purposes for collecting and selling such personal information; and
    • the categories of third parties to whom we sold or disclosed for a business purpose such personal information and the specific categories of personal information sold or disclosed to each category of third party.
  • Right to Access/Portability. You have the right to receive a copy of the specific pieces of personal information that we have collected from you in the 12 months preceding your request. Upon confirming your identity, we will disclose to you a copy of the specific pieces of personal information that we have collected about you.
  • Right to Delete. You have the right to ask us to delete or remove the personal information we have collected from you and retained. Upon our confirmation of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies (for example, where your information helps us comply with a legal obligation or detect or prevent security incidents).
  • Right to Opt-Out of Sale. Where we sell your personal information, you have a right to opt out of such sale and any further resale of your personal information. You can opt-out of the sale of your personal information by clicking here or by clicking on the “Do not Sell” link available on the home page, and on all other Venntel Website landing pages. If we receive any opt-out request either directly or through a third-party partner, we will cease selling your personal information, as “sale” is defined under the CCPA.   

 

How to Exercise your Rights

In order to exercise any of the rights described above, please contact us by either:

We may need to request specific and/or additional information from you to help us confirm your identity and ensure your right to access or delete your personal information. This is a security measure designed to prevent the disclosure of your personal information to a person who has no right to receive it. We will only use this information to verify your identity or authority to make the request. An authorized agent submitting a request on behalf of a consumer must demonstrate that the consumer provided written permission, signed by the consumer authorizing the agent to act on the consumer’s behalf. For requests for information and deletion, Venntel may require that the consumer verify its own identify directly with Venntel and directly confirm that the consumer provided the authorized agent permission to submit the request.

We will deliver our written response by mail or electronically, at your option. We will not charge you a fee for access to your personal information (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, excessive, or manifestly unfounded, or we may refuse to comply with your request in these circumstances.

We will not be obligated to respond to more than 2 requests for data access/data portability in a 12-month period. Any responses will cover the 12-month period preceding your request.

If you have opted out of the sale of your personal information, you may change your mind and opt back in at any time by contacting privacy@venntel.com.  

 

Non-Discrimination

The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information. Venntel will not discriminate against you for exercising any of your CCPA rights.

 

Shine the Light

California’s Shine the Light Law (Civil Code 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please refer to any of the contact methods in the Contact Information section below.

 

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please do not hesitate to contact us at:

Venntel, Inc.

2201 Cooperative Way, Suite 600

Herndon, VA 20171

877-717-9985

privacy@venntel.com

 

Updated: August 2020

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