VENELITE LLC CUSTOMER PRIVACY STATEMENT

VENELITE LLC (“VENELITE”) values your privacy. To learn more about what personal and user data VENELITE collects, uses, retains and shares; how we protect your personal data; and what choices and means of control you have over your personal data, please read this statement in its entirety.

This privacy statement was last updated on 26 June, 2022

If we make important changes to this privacy statement, we will post a notice on our website and/or contact our customers as appropriate or as required by applicable law.
  1. What does this privacy statement cover?

    This statement describes VENELITE’s customer privacy practices for our VENELITE -branded global websites and app, VENELITE services, VENELITE customer sales and marketing activities, and VENELITE customer services and support functions, among others. This statement does not apply to VENELITE employee data practices. Please also note that certain VENELITE websites, or app and software experiences may have links to third-party websites or services. In most cases, those third-party resources are subject to the privacy practices and policies of those third parties and not VENELITE.

  2. What personal, user and product data does VENELITE collect and how does VENELITE use and share the personal data it collects?

    VENELITE may collect certain categories of data about you when you use our websites; use our services; receive our marketing communications; interact with our customer service and support teams; and in other contexts. The data we collect can be broadly categorized as follows:

    • Personal Data: This is individually identifiable data that you may choose to provide us. This may include basic information such as your email address and phone number, or more sensitive information such as your full date of birth, home address, social security number, or your payment information.
    • Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information. If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity.
    • User Data: This is data that we collect from users of our services. User data could include personal data such as your unique VENELITE user ID or account username and password, but sometimes this user data is anonymous or “pseudonymous”, i.e., certain user data that could be made identifiable if associated with personal data.
    • Location Data: This is data we collect that help us determine a location based on your IP address in order to customize our Service and for other uses consistent with this Privacy Statement.

    VENELITE has various uses for your personal and user data you provide to us. Here are the principal contexts in which we may use, retain and share your personal and user data:

    • Websites and Account Management: Most often, you may browse our websites without providing any personal data to us. However, if you choose to establish a user account with VENELITE, engage in e-commerce, sign up for marketing communications, or interact with our customer service teams or participate in a forum on our website, we will likely need to collect some personal or user data from you. In addition, our web servers automatically collect certain data by default, such as IP addresses and other activity logs. This type of data is used for website security and site improvement purposes. Much of that data is not readily identifiable and is usually kept anonymous. In order to maintain and improve our websites, VENELITE uses third party hosting, content management and security partners, vendors and suppliers.
    • Sales: If you decide to purchase a service from VENELITE, we will need to collect certain personal data from you, including payment-related information. Typically, we use third party partners, vendors and suppliers, such as payment processing companies during our sales.
    • Marketing & Social Media: You may choose to receive VENELITE marketing communications, participate in an event/contest/promotion with us, or connect with VENELITE via social media. If you do so, we will collect certain personal data about you, such as your contact information, social media profile information and, in order to determine your eligibility for a contest or promotion, your full or partial dates of birth. VENELITE may share your personal data with our marketing agencies and partners to carry out our marketing campaigns, contests and promotions. If you wish to unsubscribe from our marketing, please follow the opt-out link in the communications you receive from us; update your contact preferences in your VENELITE account personal settings;
    • Product Registration: If you use VENELITE services, you may choose to establish a VENELITE user account. A VENELITE user account profile may include your username, password, settings, preferences, contact information, device ID information, and related data. VENELITE may share this information with other VENELITE subsidiaries and affiliates and vendors and suppliers, such as third-party hosting partners. Certain VENELITE product settings, preference information, applications history and location-based information may be used by VENELITE product development and improvement and customer service teams if you choose to enable enhanced customer support services.
    • Customer Service & Support: If you choose to interact with VENELITE customer service and support – whether it be via our website, social media, chat, email or phone – VENELITE customer service teams (some of whom work for outsourced vendors and suppliers of VENELITE) may have access to your account information, product information, contact information and payment information. You may also be required to answer certain security questions to verify your identity and your call or session with VENELITE customer support may be recorded for quality and training purposes.
    • Job Opportunities: You may choose to apply for employment opportunities at VENELITE through the VENELITE website. If you complete an application for a job at VENELITE, we may collect your contact information, data on job history and certain other information that may be required or allowed under applicable laws to screen candidates for employment. We may share this information with other VENELITE subsidiaries and affiliates and vendors and suppliers who provide us with candidate search and hiring services.
    • Board Advisory, Consulting or Non-Executive Director Opportunities: You may choose to apply or indicate your availability at VENELITE’s app to be considered for board advisory, consulting or non-executive roles or act as an expert to our portfolio companies. If you complete a professional profile, we may collect your contact information, data on job history and expertise that may be required or allowed under the applicable laws to screen candidates for those roles. We may share this information with other VENELITE subsidiaries, portfolio companies and affiliates and vendors and suppliers who provide us with candidate search and hiring services for our portfolio companies.

    The following table provides further information on some of the specific types of personal or user data we may collect from you, how we use it and with whom we may share it:

    DATA COLLECTEDPURPOSES OF USETHIRD PARTIES WITH WHOM WE MAY SHARE IT
    First and Last NameAccount Management, Sales, Marketing & Social Media, Customer Service & Support; Job Applications and Employment Screening, Board Advisory, Consulting, Non-Executive Director ScreeningVENELITE subsidiaries and affiliates; Portfolio Companies, Vendors and Suppliers; Marketing agencies who handle campaigns on behalf of VENELITE
    Identifiers (e.g. social security number, driver’s license number, passport number) Account Management, Identity Verification, Credit Check. VENELITE subsidiaries and affiliates; Portfolio Companies, Vendors and Suppliers
    Contact Information (e.g., phone, email, mailing/billing/shipping/home address)Account Management, Sales, Marketing & Social Media, Customer Service & Support; Job Applications and Employment Screening, Board Advisory, Consulting, Non-Executive Director ScreeningVENELITE subsidiaries and affiliates; Portfolio Companies,Vendors and Suppliers; Marketing agencies who handle campaigns on behalf of VENELITE
    Biometric Information (e.g. copies of photo identification). Account Management, Identity Verification, Credit Check. VENELITE subsidiaries and affiliates; Portfolio Companies, Vendors and Suppliers;
    Payment Information (e.g., credit/debit card) Sales, Customer Service & SupportVendors and Suppliers
    Username and PasswordAccount Management, Sales, Customer Service & SupportVendors and Suppliers
    Full/Partial Date of BirthSales, Marketing & Social Media, Customer Service & Support; Job Applications and Employment Screening, Board Advisory, Consulting, Non-Executive Director ScreeningVENELITE subsidiaries and affiliates; Portfolio Companies,Vendors and Suppliers; Marketing agencies who handle campaigns/contests on behalf of VENELITE
    Answers to Account Security QuestionsAccount Management, Customer Service & SupportVendors and Suppliers
    Internet Protocol (IP) AddressesWeb, Network and Product Security; Marketing & Social Media; Customer Service & SupportVENELITE subsidiaries and affiliates; Vendors and Suppliers
    Social Media Profile InformationMarketing & Social Media, Customer Service & SupportVendors and Suppliers; Marketing agencies who handle campaigns/contests on behalf of VENELITE
    Employment Background and Screening InformationJob Applications and Employment Screening, Board Advisory, Consulting, Non-Executive Director ScreeningVENELITE subsidiaries and affiliates; Vendors and Suppliers, Portfolio Companies
  3. Does VENELITE use cookies and related technologies on its websites?

    Cookies are small pieces of data that are sent to your browser from a web server and stored on your computer. Websites, including VENELITE ’s sites, use cookies to help remind us who you are when you visit our site; to help you navigate our site during your visits; and to save preferences and shopping cart contents for you so you will not have to re-enter them. VENELITE may also use cookies to store and help track information about you, including for online advertising purposes and specifically to determine which interest-based ads to display. Where required by applicable law, VENELITE will acquire consent from you prior to using certain cookies during your VENELITE website experience or will offer you the opportunity to choose which types of cookies to enable or disable. To review or change your cookie preferences on our site, please click here. To serve and manage cookies, and related technologies such as tags and website data analytics tools, VENELITE may use products and services hosted by companies such as Google, Facebook, Instagram, LinkedIn and Twitter. These services may collect information, such as your IP address, sent by your browser or via cookies. The use of such cookies is relatively standard. Most browsers are initially set up to accept them. However, if you prefer not to store cookies, you can choose to:

    • not use our sites
    • set your browser to notify you when you receive a cookie
    • set your browser to refuse to accept cookies
    • update or change your cookie preferences through our website tool here.
    • delete our cookies after visiting our site
    • browse our site using your browser’s anonymous usage setting (e.g., "Incognito" mode in Chrome)

    You should also understand that some features of the VENELITE website might not function properly if you do not accept cookies. If you do not know how to control or delete cookies or would like to opt-out of receiving certain targeted ads based on your browsing history, you may wish to visit https://www.networkadvertising.org/choices/, https://www.aboutads.info/, or https://www.youronlinechoices.eu/ for detailed guidance, including opt-out instructions. If you would like to opt-out of certain third party supported Internet advertising and behavioral targeting services, please visit any of the following:

    For additional information: https://www.consumer.ftc.gov/articles/how-protect-your-privacy-online

  4. Does VENELITE collect personal data from children?

    VENELITE’s websites, products and services are intended for adults aged 18 and older. Typically, if we become aware that we have collected personal data from persons aged 17 and under, we will take appropriate steps to delete and purge that data.

  5. How long does VENELITE retain the personal data it collects?

    VENELITE intends to retain personal data only as long as necessary to complete the purposes of use described above in Section 2. When those purposes have been fulfilled, we will securely delete personal data as appropriate. However, we may retain your personal data as long as any of the following circumstances apply:

    • your VENELITE account or marketing, fund or product/service subscription is active;
    • to provide you with services or support that you have requested;
    • to comply with applicable laws, including for tax and audit purposes;
    • to enforce VENELITE ’s rights, including litigation and debt collection.
  6. Does VENELITE sell personal data?

    While VENELITE may share personal data it collects pursuant to the purposes described above in section 2, VENELITE does not sell personal data. If VENELITE did decide to sell personal data at any point, we would provide appropriate notice and consent mechanisms to individuals as required by applicable laws. In addition, please note that if VENELITE or any of its businesses or operations were to be sold to another entity at any point, that sale could involve the transfer of personal data held by VENELITE to the acquiring organization. In such a circumstance, VENELITE would provide appropriate notice and consent mechanisms to individuals as required by applicable laws.

  7. Does VENELITE transfer personal data across borders?

    VENELITE may collect, process, use, retain and transfer personal data across borders in order to fulfill our purposes of use as described above in Section 2. This may include transfers of personal data to countries that may not have equivalent privacy or data protection laws to those in your own country. However, regardless of where we transfer personal data to, VENELITE takes appropriate steps to ensure that your personal data complies with consistent standards of care. This includes signing contracts between VENELITE affiliates and with our vendors and suppliers to make sure that both parties are following consistent privacy and security principles, processes and protections. For transfers involving European personal data, VENELITE uses Standard Contractual Clauses with its partners.

  8. How does VENELITE protect personal data?

    VENELITE believes that privacy and security go hand-in-hand. We use appropriate physical, technical, and administrative controls to protect the personal data we are responsible for. That includes encryption and other enhanced security measures, where appropriate or required. We also take appropriate steps to make sure that our vendors, suppliers and certain other partners adopt consistent standards of protection for the personal data that VENELITE is responsible for. However, it is important to note that no technology is guaranteed to be invulnerable to threat or attack. Therefore, please be sure to exercise care when using any website, service or product. If technology you use is configured with privacy or security controls or features, please be sure to utilize those.

  9. How can I review, correct, amend or delete my personal data?

    If you have a VENELITE account, you may have the ability to review, correct, amend or delete your personal data through your account profile. To do so, please visit your account and click on “Profile” and then “Personal Details”. In addition, under this privacy statement and certain applicable laws, you may submit a request to VENELITE to review, correct, amend or to delete your personal data that VENELITE has about you. You may also have the right to request a machine-readable copy of your personal data. To submit such a request to VENELITE, please contact us at info@venelite.com. Please note that we will review, respond to and act upon such requests as soon as possible and in accordance with applicable laws. We are also required to verify your personal identity before granting you access to your personal data. If you have a VENELITE account, we may verify your personal identity by requiring you to sign into your account. If you do not have a VENELITE account, or an email address on file with us, then we may request additional limited information from you in order to verify your identity. Please note that if you do not have an account with VENELITE , or an email address on file, or if we are unable to verify your identity in our records, we may deny your request. You may also use an authorized agent to submit a request under this section on your behalf. If you choose to have an authorized agent submit such a request on your behalf, VENELITE will require: (i) You to provide the authorized agent written permission to do so; and (ii) your agent to verify their identity directly with VENELITE. VENELITE may deny a request from an agent that does not meet these requirements. In addition, you have the right to raise questions or complaints with your applicable national data protection authority at any time.

  10. How can I contact VENELITE?

    If you have any additional questions, complaints or concerns regarding privacy at VENELITE. Please feel free to reach us at the following: Email: info@venelite.com.

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