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Venley Capital Privacy Policy

This privacy policy applies to www.Venley Capital.app (including its subdomains) (the “Site”), Venley Capital Mobile Application (the “App”), associated social media, Venley Capital Inc., and all of its controlled subsidiaries (“Venley Capital”, “we” and “our”). The App, the Site and social media are collectively referred to as the “Platform”.

This Privacy Policy describes how we collect, use, share and secure the personal information we receive from our users and our visitors (“you” or “your”), from our Platform. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Your right to privacy is a priority to us. Our goal in gathering information is to consistently improve our relationship with you. We do not sell your information to outside organizations.

1. What Personal Information does Venley Capital collect?

“Personal Information,” as used in this Privacy Policy, means any information or set of information that identifies or could be used to identify an individual, a legal entity or trust, or household.

  • Identifiers such as your first and last name, the names of your affiliates and related parties, email address, postal address, phone number, user account name and password, social media handle, date of birth, proof of employment eligibility (if you are applying for a job), tax identification numbers, credit reporting documentation, tax returns, bank statements, bank account information, identity verification documentation, such as driver licenses or passports, or other similar identifiers;
  • Protected characteristics such as your gender, age, race, or other protected classifications under applicable law;
  • Financial information such as bank or credit card numbers, investment history and experience, or other financial information;
  • Audio, electronic, visual, or similar information such as photographs of you, biometric identifiers, IP address or voice recordings from you;
  • Professional information such as information about your employer, job history, job interests, income, net worth, or job title;
  • Education information such as your education history, degrees or certifications obtained; or
  • Communications When you participate in polls or surveys, register for an event or contact us, we may maintain a record of that communication including any Personal Information you provide in the communication;
  • Third Party analytics such as data received through services like Google Analytics, Firebase, etc.

We may ask you to provide Personal Information when you:

  • Use our website(s) or application(s)
  • Activate a software license or register software;
  • Request quotes, services, support, downloads, trials, whitepapers, training or information;
  • Place orders for products or services;
  • Make or modify an investment or seek information about an investment;
  • Create and manage a user account;
  • Register for events or webinars;
  • Participate in surveys, sweepstakes or other promotional activities online or in any other venue;
  • Provide a testimonial;
  • Subscribe to newsletters, marketing and promotional emails or other materials;
  • Interact with us on third party social networks (subject to that third party’s terms of use and privacy policies);
  • Apply for a job; or
  • Contact us.

You may choose not to provide Personal Information or withdraw any consent you may have provided to our processing your information at any time, although it may affect our ability to provide you with relevant information or services. For some areas of our site(s) and/or application(s) and through other interactions with us, we ask you to provide additional Personal Information that helps us enhance your site visit, usage of application(s), assists you with technical support issues, permits post-visit follow-up and to communicate with you about your requests processing, product announcements, contract entitlements, and other matters essential to our services.

This information might include your name, email address, company information, job title, mailing address, application information, product preferences, or contact preferences. Learn more details about your Venley Capital.app and Venley Capital Application profile and their benefits at Venley Capital.app and in Venley Capital Application.

2. Information collected from third parties

In order to offer you a more consistent and personalized experience in your interactions with us, information collected through one source may be combined with information we obtain from other sources. This may include information that allows us to identify you across multiple devices through which you access our websites or application(s). We may also supplement the information we collect with information obtained from other parties, including our trusted business partners and other third parties. Examples of how we may use this information include using your data to help us to improve your experience using our website, to present you with options tailored to your preferences and for targeted advertising purposes as explained below, and to help prevent and detect fraud.

Personal Information we receive from third parties may include the following categories:

  • Identifiers such as your first and last name, email address, postal address, phone number, user name and password, social media handle, or other similar identifiers.
  • Protected characteristics such as your gender, age, race, or other protected classifications under applicable law.
  • Financial information that may include bank or credit card numbers or other financial information.
  • Audio, electronic, visual, or similar information such as photographs of you or your IP address.
  • Professional information such as information about your employer, salary, job history, job interests, or job title.
  • Education information such as your education history, degrees or certifications obtained.
  • Information we automatically collect As is true of most websites, we may use cookies or similar technologies to gather certain information automatically that helps us analyze trends in the aggregate and administer our website(s). This information may include the following categories of information:
  • Identifiers such as Internet protocol (IP) addresses, browser type and language, Internet service provider (ISP), device identifier, and geolocation; and
  • Internet or other electronic network activity information such as the Uniform Resource Locator (URL) of the website that referred you to our website and the URL to which you browse away from our website if you click on a link on our website, the pages you have viewed on our website and access times.

3. How does Venley Capital use Personal Information?

We use different methods to collect Personal Data from and about you including through:

  • Deliver the products, services and support or carry out the transactions you have requested;
  • Send communications to you, including information about product safety, your transaction status including notifications about products in your cart and order confirmations, specific Venley Capital programs in which you have chosen to participate, Venley Capital products and services, events, promotional offers and market surveys;
  • Facilitate your use of our website and online community forums, including customizing webpage language and content;

Facilitate communications from our authorized distributors and business partners;

  • Customize, analyze and improve our products and services (including the content and advertisements on our website to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you;
  • Better understand our users, including identifying your interests based on your interactions with our site;
  • Personalize content and implement your preferences;
  • Enforce our conditions of sale, website terms and separate contracts (if applicable) with you;
  • Prevent fraud and other prohibited or illegal activities;
  • Protect the security or integrity of our websites, our businesses, and our products or services;
  • Perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.

4. Legal bases of processing

Our legal basis for collecting and using your Personal Information depends on the Personal Information concerned, the specific context in which we collect it and how it is to be used. In general, we collect and process your Personal Information on one or more of the following bases:

  • Your consent for example where we have obtained your consent to process your personal data for certain activities (such as the use of cookies for online tracking and analysis). You are free to withdraw your consent at any time by contacting us. If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew it. Where applicable, we may ask for your consent to processing at the point where you provide your Personal Information.
  • To comply with a contractual obligation (for example, using your address details to sending you documents or using your email address where you have asked us to do something, such as providing you with additional information about our services). We will advise you upon collection whether the provision of your Personal Information is mandatory and of the possible consequences if you do not provide us with your information.
  • For compliance with our legal obligations where other laws require the processing of your Personal Information (for example, health and safety, taxation, Know Your Customer requirements and anti-money laundering laws) or where we need your Personal Information to protect your vital interests or those of another person.
  • Our (and our business partners’) legitimate interests which include the provision of Venley Capital.app and/or Venley Capital Application and/or relevant products and services, and/or the carrying out of marketing and personalizing activities,

provided always that our legitimate interests are not outweighed by any prejudice or harm your rights and freedoms.

If you have any questions or need more information concerning the legal basis on which we collect your Personal Information, please contact us.

5. Retention of your Personal Information

We will retain your information for as long as your account is active or as needed to provide you support or services, and in accordance with our retention practices and legal requirements. This retention will continue, for example, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6. International transfers

We may transfer your Personal Information among our affiliates and/or business partners, if required for the purposes described in this Privacy Policy. This may involve the transfer of your Personal Information to countries outside your home country or region, including outside the European Economic Area if that is your region, which may have a different level of data protection from your home country.

Such countries may include, without limitation, the United States and other countries in which we or our affiliates or business partners maintain facilities. We take all reasonable technical and organizational measures to safeguard Personal Information we transfer.

7. How we may share Personal Information

We may disclose your Personal Information for any purpose with your consent. Except as described below, we will not disclose your Personal Information to third parties for their own marketing purposes without your consent.

We also may share your Personal Information with these categories of third parties for the following purposes:

Service providers and business partners

We engage service providers, online advisors and business partners to assist us with operating and providing your access to our website(s), application(s) and other Venley Capital services. These service providers or business partners may perform advertising services, process secure payments, fulfill orders, optimize services, provide integration services for our users, provide technical and user identity verification services, serve online behavioral advertising, send newsletters and surveys, support email and online community services, administer polls and surveys, and analyze information to help us improve our business. Some of our service providers or business partners may engage their own service providers or business partners to further assist us. In these instances, the receiving party is not permitted to retain, use or disclose Personal Information for any purpose other than for performing the specific business purpose on our behalf.

Venley Capital Partner Network

Venley Capital Partners are specialized experts that we may ask to contact you regarding a service or product you request. In such a case, we will share only relevant contact information and information about the relevant service or product you have requested with the Venley Capital Partners. The Venley Capital Partners then contact you regarding your request.

Joint seminars

We occasionally partner with other companies in an effort to provide the most relevant and detailed information for our application(s) and services. In some cases, we and such third parties conduct joint seminars where we may conduct joint marketing activities in which both Venley Capital and the third party receive your Personal Information.

Where required by law or for other protective reasons

We may share your Personal Information with law enforcement agencies, courts, other government authorities or other third parties where we believe it necessary to comply with a legal or regulatory obligation or otherwise to protect our rights or the rights of any third party.

We also may share your Personal Information in connection with fraud protection or other legal action, or if we reasonably believe it is necessary to protect us, our users or the public.

In the context of a merger, acquisition or sale

We may share your Personal Information with potential transaction partners, service providers, advisors and other third parties in connection with negotiation or completion of a corporate transaction in which Venley Capital is acquired by or merged with another company or in which Venley Capital sells or transfers all or a portion of its assets or business.

The Personal Information we may share with third parties as described in this section may include these categories:

  • Identifiers
  • Protected characteristics
  • Commercial information
  • Geolocation data
  • Internet or other electronic network activity information; Financial information
  • Audio, electronic, visual, or similar information; Professional information
  • Education information and Communications

8. How can I access and update my information?

We want to help you keep your Personal Information accurate. To access, correct, change, update or delete your Personal Information on Venley Capital.app or Venley Capital Application, visit and log into your account or contact us. We will respond to your request to access within 30 days. We promptly record any request for changes to your communication preferences in our internal user databases; please allow 10 business days for these changes to take effect.

9. EU data protection rights

Where the processing of your Personal Information is subject to EU data protection laws, you have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law.

  • Access Request access to your personal data, as that term is defined in the GDPR;
  • Rectification Request correction of your personal data;
  • Erasure Request erasure of your personal data;
  • Objection Object to some processing of your personal data;
  • Restriction Request restriction of processing of your personal data;
  • Portability Request the transfer of your personal data to you or to a third party
  • Withdrawal of Consent transfer of your personal data to you or to a third party; ▪ Withdrawal of Consent: Withdraw your consent to processing your personal data;
  • Automated Decision-Making The right not to be subject to having a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you

In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Information infringes applicable data protection law.

If you have any questions about the type of Personal Information we hold about you or if you wish to request deletion or correction of Personal Information we hold about you, or to submit a Data Subject Access Request to exercise any other data subject right, please send a written request to us at the email provided at the bottom of this Privacy Policy. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.

10. California site visitors and users

In accordance with the requirements of the California Consumer Privacy Act, you may have certain rights in relation to your Personal Information. These rights may include the rights to:

  • Access and receive a portable copy of your Personal Information;
  • Delete your Personal Information (subject to certain limitations under applicable law);
  • Receive information about our use of your Personal Information;
  • Be free from discrimination in response to exercising these rights conferred by law;
  • Direct that your Personal Information not be sold.

To exercise any of these rights, please contact us. We do not sell Personal Information.

11. How can I manage my communication preferences?

You can change your communication preferences, including opting out of all marketing communications, at any time. You may use any of several options to express and manage your preferences, including:

  • Manage your preferences and customize the communications you receive, in the communication preferences area of your profile at Venley Capital.app or Venley Capital Application.
  • Unsubscribe by using the link at the bottom of any marketing email communications we send you.
  • Make your request by sending an email at the address listed at the bottom of this Privacy Policy.

Any marketing by us, or any third parties on behalf of us, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences (including the possibility of being removed from our advertising and marketing lists as set out above). If you opt out of receiving marketing communications, we may still communicate with you in connection with transactions you request and/or service related matters.

12. How does Venley Capital use cookies and similar technologies?

Our website(s) uses service provider "cookies" and similar technologies to enable you to sign in to our services, to help personalize your online experience, to analyze trends and to track users’ activities on the website. We use cookies to store your preferences and other information on your computer in order to save you time by eliminating the need to enter the same information repeatedly. A cookie is a piece of text that is placed on your computer's hard drive.

Depending on the settings you have selected, your browser adds the text to your device as a small file. Many browsers are set to accept cookies by default. You have the ability to accept or decline cookies as you prefer. The Help portion of your web browser, most likely found on the toolbar, typically tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to decline cookies, you may still use our website, but your ability to use some areas of our website will be limited.

We also use scripts, pixels and similar technology, that help us manage content on our site. For example, we may use scripts to personalize your experience to show you our products and services that support your industry. We may also use these technologies to identify the most popular locations on our site, to help us make more of our pages valuable to our users and to troubleshoot any issues our users raise about our site’s operation

13. Targeted Display Advertising

We may use third-party advertising companies to use cookies, and Internet browsing to help us display personalized content and appropriate advertising during your visits to Venley Capital.app and other websites. For example, if you view a product or service on our website, you may see offers for similar products or services on other websites you visit. Cookies placed by these advertising companies also assist us with measuring the performance of our advertising campaigns and with identifying the pages you view, the links and ads you click on, other actions you take on those web pages, and the site from which you came before arriving at a web page. These cookies can be effective whether you are on our website(s) or another website. If you opt out of receiving targeted display advertising, the data associated with these cookies will not be used.

If you do not wish to have this information used for the purpose of serving you targeted ads, you may opt-out of publishers’ content by visiting https://preferences-mgr.truste.com (or if located in the European Union click https://www.youronlinechoices.eu/). Please note this does not opt you out of being served all advertising. You will continue to receive generic ads.

14. “Do Not Track” signals

Please note that while you may have the opportunity to opt-out of targeted advertising through the link above and you may be able to control the use of cookies through your web browser as described in the “How Does Venley Capital Use Cookies and Similar Technologies” section above, some web browsers may also give you the ability to enable a “do not track” setting. This setting sends a special signal to the websites you encounter while web browsing. This “do not track” signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. We do not respond to web browser “do not track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Statement. For more information about “do not track,” visit www.allaboutdnt.org.

15. How does Venley Capital secure my Personal Information?

The security of your Personal Information is important to us. We follow generally accepted standards to protect your Personal Information from misuse, interference and loss, as well as from unauthorized access, modification or disclosure. The ways we do this include:

  • Using encryption when collecting or transferring sensitive information, such as credit card details;
  • Limiting physical access to our premises.
  • Limiting access to the information we collect about you.
  • Ensuring that we and our business partners have appropriate security safeguards to keep Personal Information secure.
  • Where required by law, destroying or de-identifying Personal Information.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from us asking for your personal information. We will not request your ID or password through email.

When you see either a solid key icon or a locked padlock icon at the lower portion of your browser window, your connection with our site including transfer of sensitive payment information you may enter, is secured through Secure Sockets Layer (SSL). If you do not see one of these icons, please contact us.

16. Children's Personal Information

We take children’s privacy seriously. We do not knowingly collect personal information from children through our website. If you are a child as understood by laws of your country, please do not submit any Personal Information through our website.

17. Social media features

Our websites and/or application(s) include social media features, such as the Facebook and LinkedIn buttons. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy statement of the company providing it.

18. Testimonials

We display personal testimonials of satisfied users on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us.

19. Use of Venley Capital Public Forums

Any information (including Personal Information) that you choose to disclose in public areas of our website, such as discussion forums, chat rooms, forums, message boards, or other public forums such as trade shows or conventions, becomes public information that others may collect, circulate, and use. Any text you include in a message is public. Because we cannot and do not control the acts of others, you should exercise caution when deciding to disclose information about yourself or others in public forums such as these. To request removal of a posting you have made or your Personal Information from our blog or community forum, please contact us. In some cases, we may not be able to remove your Personal Information, in which case we will let you know the reason we are unable to do so.

20. Links to third-party websites and services

Third parties control the content of all third-party websites that are linked to our website(s) or application(s). These links are provided as a benefit to you. If you submit Personal Information to any third-party website through one of those links, the Personal Information you provide is governed by the third-parties’ privacy statements. We encourage you to carefully read the privacy statement of any site you visit.

21. Notification of Privacy Statement changes

We may update this privacy statement at any time to reflect changes to our information practices. If we make any material changes, we will notify those with user accounts by email (sent to the e-mail address specified in your account) or post a notice on this site prior to the change becoming effective. All updated versions of this privacy statement will include an updated posted effective date. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about this Privacy Statement or would like to contact us regarding our privacy practices, please contact: privacy@venleycapital.com