Privacy Policy 


EFFECTIVE DATE: March 2020

 

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 data services – these are the data products and services that we provide to our Customers (the “Data Services”); and
  • This website, www.venntel.com (the “Website” or “Site”).

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, federal law enforcement and national security.

If you are a resident of California, please refer to the California Residents Privacy notice here.

 

WHO WE ARE

Venntel provides real-world location intelligence. Our platform merges, categorizes and interprets disparate location data. Our Customers rely on our Data Services to power their security and risk management solutions, understand movement patterns for purposes of federal law enforcement and national security, and to provide and improve the services they offer to their own customers.

 

DESCRIPTION OF SERVICES

Venntel collects and process 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
  1. How We Use Your Information 
  1. How We Share Your Information 
  1. Our Use of Cookies and Other Tracking Mechanisms
  1. Third-Party Links
  1. Security of Your Information
  1. Privacy Choices
  1. Retention
  1. Children
  1. Privacy Shield

 

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 through GPS tools, cell tower triangulation, WiFi data, or other techniques. We do not collect your precise geolocation in real-time.
Identifiers IP address; mobile advertiser ID (“MAID”)
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.

 

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:

  • Providing and Improving Our Services. We use your information to provide, improve, and personalize our services to you, including improving our Portal.
  • Marketing and Communications. We use your information to communicate with you about our services, respond to your inquiries, administer surveys and questionnaires, to provide customer service, and for marketing and promotional purposes. For example, we may use your information to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services.
  • Research and Analytics. To better understand how you access and use our Website, and for other research and analytical purposes.
  • Protecting Rights and Interests. To protect the safety, rights, property, or security of Venntel, our services, any third party or Partner, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that Venntel, in its sole discretion, may consider to be, or pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; to conduct audits; and to enforce this Policy.
  • Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. 

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: 

  • Affiliates: We may disclose your information to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your information will be subject to this Policy.
  • Service Providers: We may disclose the information we collect to third party vendors, service providers, and contractors or agents, who perform functions on our behalf.
  • Customers: When we provide our Data Services, we share with our Customers your information, including your device’s Location Data, mobile advertising ID, and other device information. Our Customers may use this information for purposes such as security and risk management, movement analytics, federal law enforcement and national security. In some circumstances, our Customers may also resell your information to other third parties for similar purposes.
  • Analytics Providers. We may disclose information we collected through our Website to our Website analytics providers such as Google Analytics, to evaluate usage of our Site, and to help us improve Website performance and user experiences. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • Business Transfers. If we are invested in, acquired by or merged with another company , if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or other similar business transaction, we may share your information with, or transfer the information we have collected from you to, the other company.
  • To Protect Us and Others. We may share your information where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which Venntel is involved.
  • In Response to Legal Process. We also may disclose the information we collect if we believe that such action is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • With Your Consent. We may disclose the information we collect from you with your consent.

 

4. 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.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our Site and on third-party sites.

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.

 

5. 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.

 

6.  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.

 

7.  Privacy Choices

Data Services Opt Out. If you would like to opt-out of our use of your device 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.

 

8.  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 three (3) 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.

 

9.  Children

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

 

10.  Privacy Shield

We comply with the EU-US, U.K. and Swiss-US Privacy Shield Frameworks, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the EEA, U.K., and/or Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence. To learn more about the Privacy Shield program, the Privacy Shield Principles, and to view our certification, please visit www.privacyshield.gov.

As described in the Privacy Shield Principles, We are accountable for Personal Data (as defined in the General Data Protection Regulation (EU GDPR)) that we receive and subsequently transfer 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.

In compliance with the Privacy Shield Principles, Venntel commits to resolve complaints about our collection or use of your Personal Data. EEA, U.K. and Swiss individuals with inquiries or complaints regarding this Policy should first contact us at:

 

Venntel, Inc.

2201 Cooperative Way, Suite 600

Herndon, VA 20171

privacy@venntel.com

 

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).

 

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.

©2020 Venntel, Inc. All Rights Reserved.