VenU Privacy Policy

The EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF)

VenU, LLC (the “Company”) is a leading provider of online Learning Management Systems (LMS). Protecting consumer privacy is important to the Company. VenU, LLC adheres to the EU-US Data Privacy Framework Agreement and the UK Extension to the EU-US DPF concerning the transfer of personal data from the European Union (“EU”) and the United Kingdom (“UK), respectively. Accordingly, VenU, LLC follows the Data Privacy Framework Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all Personal Information received by VenU, LLC whether in electronic, paper, or verbal format.

Privacy Commitments

For Data Transfer from the EU, UK and/or Switzerland into the United States

VenU, LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. VenU, LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. VenU, LLC] has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.The Federal Trade Commission (FTC) has jurisdiction with enforcement authority over VenU, LLC’s compliance with the DPF Principles.

VenU, LLC is committed to cooperating with EU data protection authorities (DPAs), and the UK Information Commissioner’s Office (UK ICO) and will comply with the advice given by such authorities with regard to human resources data transferred from the EU, the UK, and Switzerland in the context of the employment relationship.

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

DATA PRIVACY FRAMEWORK PRINCIPLES

Notice

VenU, LLC will inform an individual of the purpose for which it collects and uses Personal Information and the types of non-agent third parties to which VenU, LLC discloses or may disclose that Information. VenU, LLC will provide individuals with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to VenU, LLC, or as soon as practicable thereafter, and in any event before VenU, LLC uses or discloses the information for a purpose other than for which it was originally collected.

Choice

VenU, LLC will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, VenU, LLC will give individuals the opportunity to affirmatively or explicitly opt out to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Accountability for Onward Transfer (Transfers to Third Parties)

Prior to disclosing Personal Information to a third party, VenU, LLC shall notify the individual of such disclosure and allow the individual the choice to opt out of such disclosure. VenU, LLC shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agrees in writing to provide an adequate level of privacy protection.

VenU, LLC is liable in the case of onward transfer of EU, UK or Swiss data to agent third parties unless we can prove we were not a party to the event giving rise to the damages.

Security

VenU, LLC will take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. VenU, LLC has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. VenU, LLC cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

VenU, LLC will only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual.

Access

Pursuant to the DPF Principles, VenU, LLC acknowledges the right of EU, UK, and Swiss individuals to access their personal data and will allow an individual access to their Personal Information and allow the individual to correct or amend inaccurate Information, except where the Company determines that the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Furthermore, EU, UK, and Swiss individuals have the right to request erasure of personal data that has been deemed to have been handled in violation of the DPF Principles.

Enforcement

VenU, LLC uses a self-assessment approach to assure compliance with this privacy policy and verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles on a quarterly basis. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using BBB National Programs as a third party resolution provider. This Agreement will be interpreted, construed and enforced in all respects in accordance with the laws of the Commonwealth of Virginia without reference to its choice of law rules.

Complaints

Data Privacy Framework Complaints

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), VenU, LLC. commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact VenU, LLC at:

VenU Privacy Officer
Phone: 1-800-596-8544
Email: privacy@ven-u.com

VenU, LLC has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

Information VenU, LLC Gathers

VenU, LLC gathers two basic types of information through the Site: “Personal Information,” information from which an individual can be identified, and “Aggregate Information,” from which an individual cannot be identified.

Aggregate Information

When you visit and interact with the Site, VenU, LLC and third parties with whom VenU, LLC has contracted to provide services to VenU, LLC, may collect anonymous information from three sources: server log files, cookies, and “pixel tags”.

Server Log Files: Your Internet Protocol (IP) address is an identifying number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use the IP addresses of all Visitors to calculate Site usage levels, to help diagnose problems with the Site’s servers, and to administer the Site. We may also use IP addresses to communicate or to block access by Visitors who fail to comply with our Terms of Service. Collecting IP addresses is standard practice on the Internet and is carried out automatically by many web sites.

Cookies: Cookies are data that a web server transfers to an individual’s computer for recordkeeping purposes. Cookies are an industry standard used by most web sites, and help facilitate users’ ongoing access to and use of a particular web site. Cookies do not cause damage to your computer systems or files, and only the web site that transferred a particular cookie to you can read, modify or delete such cookie. If you do not want information collected through the use of cookies, there are simple procedures in most browsers that allow you to delete existing cookies, to automatically decline cookies, or to be given the choice of declining or accepting the transfer of particular cookies to your computer. You should note, however, that declining cookies may make it difficult or impossible for you to use portions of the Site.

Pixel Tags: The Site may use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) to compile aggregate statistics about Site usage and response rates. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

Personal Information

You are not ordinarily required to register or provide Personal Information in order to access our Site, though certain functionalities (such as a membership program, through which purchasers of products may receive discounts on online purchases) may require registration. We only require that certain data is collected during registration, and the other fields are optional. We collect Personal Information from you only when you voluntarily provide it to us – for example, in contacting us through the Site. Personal Information may include your contact information (such as your name, postal address, telephone numbers and/or email address).

Children’s Privacy

VenU, LLC does not knowingly collect any personally identifiable information or other user information from children under the age of 18.

Data Processing

VenU, LLC will not process your user information without a lawful basis to do so, which is defined in Article 6 of the GDPR. In general, VenU, LLC will process your user information on the legal bases of consent, contract (if you have entered into an agreement with us and such processing is a necessary part thereof), or legal obligation (as noted above).

Rights of Data Subjects

You may at any time request an export of your personal information.

You may at any time correct information associated with your account.

You may at any time withdraw consent by requesting that your account be deleted.

You may object at any time to the use of your personal data by contacting privacy@ven-u.com.

You may at any time lodge a complaint regarding the processing of your personal data by VenU, LLC with the Supervisory Authority of your EU member state.

Data Encryption

VenU, LLC uses encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so VenU, LLC can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.

Use and Disclosure of Information VenU, LLC Gathers

Personal Information

We may use your Personal Information in any of the following ways.

Communications: We encourage Visitors to contact us with questions and comments. Personal Information may be used in order to respond to your questions and comments.

Third Party Service Providers: We work with third parties who provide services, including web site hosting, credit card processing, data analysis, newsletter services, promotional activities, and other administrative services. We may share your Personal Information (onward transfer) with such third parties for the purpose of enabling such third parties to provide such services.

Miscellaneous: Finally, we may disclose your Personal Information if we believe that we are required to do so: (i) by law; (ii) to comply with legal process or governmental requests; (iii) to enforce our Terms of Service; (iv) to protect our operations; (v) to protect the rights, privacy, safety or property of VenU, LLC, you or others; and (vi) to permit us to pursue available remedies or limit the damages that we may sustain.

We may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security and law enforcement requirements.

Aggregate Information

We analyze Aggregate Information in order to enhance web site security; to track the popularity of certain pages of the Site, the success of our email notifications, traffic levels on the Site; and to collect other usage data, all of which helps us provide content tailored to your interests, improve the Site and related services, and otherwise enhance your experience on the Site. We may share Aggregate Information with affiliated entities and other third parties.

Updating Your Information and Contacting Us

VenU, LLC has procedures in place to keep your Personal Information accurate, complete and up to date for the purposes for which it is collected and used. You have a right to access personal data we hold about you. You may review the Information we have collected and, where appropriate, you may request that it be corrected. We also provide you with you several options for reviewing, correcting, updating or otherwise modifying information you have previously provided:

You may contact us at: https://ven-u.com/contact-us/
You may call us at 1-877-256-0830

Please clearly indicate the Information that you wish to review or have changed. We will endeavor to comply with your request as soon as reasonably possible.

Some of your Personal Information can be updated or deleted through your User Profile on the site.

Note that despite any removal of or change to Personal Information requested, there may also be residual Information that will remain within our databases and other records, which Information will not be removed or changed.