If you are located in the European Economic Area, U.K., or Switzerland, you may have rights under the General Data Protection Regulation or similar laws in the U.K. and Switzerland (the “GDPR”). Under the GDPR, Venntel is required to provide individuals with certain information about the processing of their “Personal Data” and rights available to them with respect to such Personal Data.
The GDPR defines “Personal Data” as any information relating to an identified or identifiable individual. This may include a name, address, mobile device identifier, precise location data*, IP address, cookie identifiers, biometric data and related information, among others.
* For clarity, “precise location data” does not mean “real-time” data. Instead, it is information that describes the precise geographic location of a device derived through any technology that is capable of determining with reasonable specificity the actual physical location of a device at a previous point in time.
Your Rights in Connection with Personal Data
The GDPR grants you a number of rights with respect to your Personal Data that controllers, such as Venntel, may hold about you. Each of your rights is summarized in more detail below; additional conditions may apply:
Right to Object. You have a right to object to the processing of your Personal Data. This right exists where we are collecting your Personal Data because we have a legitimate interest in that data (like preventing fraud) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have a right to object where we are processing your Personal Data for direct marketing purposes.
How to Exercise Your Rights
In order to exercise any of the rights described above, please contact us at email@example.com.
We may need to request specific information from you to help us confirm your identity and assist us in responding to your request. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We will only use the information you provide to us when exercising your rights above to verify your identity or authority to make 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 excessive or manifestly unfounded, or we may refuse to comply with your request in these circumstances.
Should you have a complaint, please contact us as soon as possible. If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority.
Legal Basis for Processing Personal Data
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a legally justified reason, or “legal basis” for that use. Most commonly, our legal basis for processing your Personal Data will be:
Transfers of Personal Data
Venntel, Inc. may share your Personal Data with third parties who are located in jurisdictions outside the EEA, U.K., or Switzerland. These jurisdictions have privacy laws that the European Commission considers are less protective of Personal Data than the privacy laws in your own country.
As described in the Privacy Shield Principles, Venntel is accountable for Personal Data that it receives and subsequently transfers to third parties to the extent such third parties who process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. We are not, however, liable for the data handling practices of our third-party partners and customers unless they are acting on our behalf.
In compliance with the Privacy Shield Principles, Venntel commits to resolve complaints about our collection or use of your Personal Data. EEA, U.K., or Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact us at:
2201 Cooperative Way, Suite 600
Herndon, VA 20171
Venntel has further committed to refer unresolved Privacy Shield complaints to American Arbitration Association (AAA) 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 resolved your complaint, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of AAA are provided at no cost to you.
As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Venntel is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Please contact us with any questions or comments about this EEA Privacy Notice or our practices at:
2201 Cooperative Way, Suite 600
Herndon, VA 20171
Updated: August 2020