Last Updated: January 2023
INTRODUCTION
Venntel, Inc. (“Venntel,” “we,” “us,” or “our”) values individuals’ (“you” or “your”) privacy. In this Privacy Policy (“Policy”), we describe how we and our corporate affiliates may collect, use, store, and disclose your information as it relates to:
Our customers (“Customers”) are entities that use our Data Services.
Our partners (“Partners”) are companies that collect information from individuals, including, their mobile device’s location information, and provide that information to us in different data sets so that we can assist our Customers.
By visiting the Website, you agree that your information will be handled as described in this Policy. Your use of this Site is subject to this Policy.
Please note that this Policy does not cover our Customers’ use of the information we provide to them. Our Customers may associate the information we provide with additional information they have from other sources and may use this combined information for a variety of purposes, such as, consumer insights, security and risk management, movement analytics, law enforcement and national security.
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, please refer to the EEA, U.K. & Switzerland Privacy notice here.
WHO WE ARE
Venntel provides real-world location intelligence. Our platform merges, categorizes and interprets disparate Location Data (as defined below). Our Customers rely on our Data Services to power their security and risk management solutions, understand movement patterns for purposes of law enforcement and national security, and to provide and improve the services they offer to their own customers.
DESCRIPTION OF SERVICES
Venntel collects and processes various types of information from mobile devices, which we receive from our third-party partners (“Partners”). The data we receive from our Partners includes location data in the form of latitude/longitude (“Location Data”), which is associated with a mobile advertising ID, such as Apple’s Identifier for Advertisers ( IDFA) or a Google Advertising ID (Advertising ID/Ad ID). Our various solutions allow our Customers to incorporate the Location Data into their own proprietary applications and analyses, create data analytics reports, and visualize Location Data through our proprietary software tool (the “Portal”). We also may receive other information from our Partners about your device, such as IP address and Device User Agent Data (as defined below) which may be included in our Data Services.
OUR DATA PRACTICES
1. Information We Collect About You
We collect the following information when you browse or submit an inquiry on our Website, contact us to request information about our products or services, or apply for a job.
Information Category | Description of Information Collected |
Identifiers | IP address, and the following information if you choose to provide it to us: name, email address, phone number; job and company information, and state |
Device Information | Your browser type and operating system, time zone setting and location, browser plug-in types and versions. |
Internet or Network Activity | Web pages you view, links you click, the length of time you visit our Site, and the webpage that led you to our Site. |
Communications Preferences | Your preferences in receiving marketing from us and your communication preferences. |
Professional or Employment Information | If you apply for a job, current or past job history or performance evaluations. |
We collect the following information about you from our Partners and use it to provide our Data Services:
Information Category | Description of Information Collected |
Location Data |
Precise geolocation data, including latitude-longitude coordinates obtained from mobile Apps via requests to the mobile device operating system which utilizes various mechanisms to derive Location Data, including GPS tools, cell tower triangulation, WiFi data, or other techniques. We do not collect your precise geolocation in real-time. Neither Venntel, nor its third-party data partners determine whether Location Data is received from GPS signals, cell tower triangulation, WiFi data, or by other techniques. The device operating system determines which signal is most readily available to the device and returns the Location Data to the corresponding mobile application provider. |
Identifiers | IP address; mobile advertiser ID (“MAID”); hashed e-mail |
Internet or Network Activity | Timestamp, list of mobile applications from which location signals were received. |
Device User Agent Data | Device type; browser family; browser version; operating system; version of operating system; device model number, carrier data. |
Demographic Data | Age, gender, generational suffix, marital status, parental status, number of children, educational level, yearly income. |
Bidstream Data | Venntel DOES NOT collect mobile advertising bidstream data to support our Data Services. We likewise ask our third-party partners to refrain from supplying data sourced from the mobile advertising bidstream. |
We collect the following information from you (or on your behalf) when you use our Data Services:
Information Category | Description of Information Collected |
User Data | Name and email address provided by you or your Company so that Venntel may enable you to create an account to access the Portal. |
Usage Data | This is information that Venntel collects about you when you’re accessing and/or using the Portal and includes: session information (login time, usage time, logout time, number of searches, nature of search) |
2. How We Use Your Information
Venntel uses information we collect through our Website for the following purposes:
Venntel uses the information we receive from our Partners to provide Data Services to our Customers. We do not use information collected through our Website to provide our Data Services.
We do not use the information we collect about you to determine employment eligibility, credit eligibility, insurance eligibility, underwriting, or for pricing purposes.
3. How We Share Your Information
We may share your information as follows:
4. Supplementary Information for Individuals Residing In Select U.S. States
Under various U.S. State privacy laws, you may have certain additional rights that pertain to your data privacy. These additional privacy laws require Venntel to provide individuals with certain information about the processing of their “personal information” and the rights that are available to them under such laws.
Personal Information
Generally, “personal information” is defined as “any information that directly or indirectly identifies, relates to, describes, or can be associated with or reasonably linked to “an individual or household”, including, name, address, mobile device identifiers, precise location data, IP and cookie identifiers, inferences, and biometric data.
The following table discloses what categories of “personal information” (as defined by various U.S. state privacy laws) we have collected from or about individuals within the last twelve (12) months:
Personal Information Collected by Venntel
"Personal Information" Category |
"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 Classification Characteristics under U.S. State Privacy Laws 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:
Use of Personal Information
Please refer to the “How We Use Your Information” section of this Privacy Policy for information on how we use your personal information with respect to the Data Services and our Website.
Disclosing Personal Information for a Business Purpose
Business Purpose
We may share your personal information with affiliates and service providers for a business purpose, which different privacy laws generally define 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:
The following are categories of third parties to whom we have disclosed your personal information for a business purpose:
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:
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:
Your Rights in Connection with Personal Information
Many U.S. State privacy laws grant 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:
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 identity 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
Privacy laws prohibit discrimination against individuals for exercising their rights and imposes requirements on any financial incentives offered to individuals related to their personal information. Venntel will not discriminate against you for exercising any of your privacy 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.
5. Our Use of Cookies and Other Tracking Mechanisms
We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Site. We may combine this information with other information we collect from you (and our third party service providers may do so on our behalf).
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Data Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Data Services. There are two types of cookies: session and persistent cookies.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
6. Third-Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
7. Security of Your Information
We have implemented appropriate administrative, technical, and physical safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
8. Privacy Choices
Data Services Opt Out. If you would like to opt-out of our use of your device's Location Data and other related data we use in our Data Services, you can (a) disable location services on your mobile device, or (b) complete the Opt-Out & Do Not Sell Form. Please note that your opt-out will be specific to the device for which you submit the opt-out request. This means that if you use multiple devices, you will need to opt out each device that you use. In addition, if you re-set your mobile advertising ID, you will need to opt out that device again.
Email Marketing Opt Out. You may opt-out of receiving promotional communications from us by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any services you have requested or received from us.
9. Retention
We retain your personal information for so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes. We store Location Data, Internet or Network Activity, and Device User Agent Data associated with a particular mobile advertising ID and used for our Data Services, for up to four (4) years, provided, we may retain such personal information for a longer period to the extent it is required for a legal or significant operational purpose, such as for compliance, record-keeping, auditing, safety and security, and error or bug prevention.
10. Children
Our Services are not designed for children under 16. If we discover that a child under 16 has provided us with personal information, we will delete such information from our systems.
CONTACT US
If you have any questions or would like to speak with us regarding changes to your personal information, please email us at privacy@venntel.com, call us at 877-717-9985, or write to us at:
Venntel, Inc.
2201 Cooperative Way, Suite 600
Herndon, VA 20171
CHANGES TO THIS PRIVACY POLICY
This Policy is current as of the Effective Date set forth above. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.