Privacy Policy

Last updated: 09/12/2024

 

Introduction

Venminder LLC (Venminder) is an Ncontracts company and provides a third-party risk management platform and services. Venminder also provides educational resources virtually in addition to hosting and attending global events. Online platforms include Venminder.com and thirdpartythinktank.com (individually, “Website” and collectively the “Websites”). This privacy Policy aims to inform you about how we collect, use, disclose and store information about you when you:

• Use any of our products, services, or applications (including those only used as a trial) (collectively the “Services”) in any manner;
• Use and/or interact with our Websites. This includes downloading materials from our resources library, interacting with our community, or requesting a demo; and
• Register for and/or attend any of our events, webinars, or the conferences we attend (collectively “Events”).
  
  

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Policy

What Information Does Venminder Collect?
Venminder collects various types of information from several sources. This may include information that identifies or may identify you as an individual (“Personal Information”). This is explained in more detail below. Please do not provide us with any other person’s Personal Information, unless we expressly prompt you to do so.

Information You Provide to Us:
Venminder collects, and collected in the previous twelve months, Personal Information that you directly or indirectly give through our website, during events, or via our online community. Specifically:

• Venminder may collect Personal Information that you choose to send to us or provide to us via our websites or events. Examples include information that you provide if you complete a “Request a Demo” (or similar) online form or if you register for a Venminder webinar. If you contact us through the Websites, we will keep a record of our correspondence.

Venminder may collect Personal Information that you otherwise provide directly to us. For example, when setting up new users within the Venminder application, we collect Personal Information, such as name and contact information, to provide the requested Services. The types of information we collect directly from our clients and their internal users include: names, email addresses, postal addresses, phone numbers, job titles, employer, transactional information (including Services purchased, community postings), as well as any other contact or other information provided to us or uploaded to our systems in connection with the Services. Also, when users register in our online community, Third-Party ThinkTank, we collect Personal Information, such as name and e-mail address.

Information We Automatically Collect:
Venminder automatically collects, and automatically collected in the previous twelve months, Personal Information from our websites, via cookies, or otherwise. Specifically:

• From our Websites – We use our analytics tracking system to collect certain information related to your device, such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our site.
• Usage information – We use our analytics tracking system to track user activity as it relates to the types of Services our customers and their users use, the configuration of their browsers, and performance metrics related to their use of the Services.
• Logging of information – We log information about our customers and their users including Internet Protocol (“IP”) address, referring website, what pages your device visited, and the time that your device visited our site.
• Cookies and other similar technologies – We use various technologies, including cookies, localStorage, and sessionStorage to collect information which may include saving data to users’ computers. For additional information, see the section below entitled “Cookies and other Tracking Technologies” and our Cookies Policy.
• Customer Feedback – While using our Services, you may be asked to provide feedback (e.g., in the software directly or after receiving help from our support team). Providing this feedback is entirely optional.

Information We Purchase from Third Parties:
Venminder also purchases information, which may include Personal Information, from third parties who are authorized to sell us that information, including sales intelligence organizations. The Personal Information that we purchase from such third parties includes names, email addresses, postal addresses, phone numbers, job titles, and employer,.

How We Use the Information
We use, and have used in the previous twelve months, the information we collect via our Website and events, based on your consent or for our legitimate interests, such as monitoring and improving our Websites and Services. Specifically:

• To administer our Website/events and for internal operations, including:
  • Troubleshooting
  • Data analysis
  • Testing
  • Statistical and survey purposes;
• For improvements to our Websites and to ensure that content is presented in the most effective manner for you and for your computer;
• For trend monitoring, marketing, and advertising;
•  For other business purposes we will make clear to you at the time you submit your information, including to:
  • Fulfill your request for a demo;
  • Provide you with access to one of our webinars or whitepapers or to provide you with information you have requested about our Services; and
  • As part of our efforts to keep our Websites secure.

Our use of your Personal Information may be based on our legitimate interest to ensure network and information security, our direct marketing purposes, or your consent (e.g., when you request a demo).

We use the information we collect from our customers and their users in connection with the Services we provide for a range of reasons, including:

• Providing and maintaining our Services;
• Setting up user accounts;
• Processing and completing transactions;
• Sending related information, including transaction confirmations and invoices;
• Managing customer use of the Services, responding to inquiries and comments, and providing customer service and support;
• Sending customer technical alerts, updates, security notifications, and administrative communications;
• Communicating with you in relation to our offerings and services via different channels (e.g., by phone, email, chat) and responding to your requests;
•  Investigating and preventing fraudulent activities, unauthorized access to the Services, and other illegal activities;
•  Recommending services and offerings that might be of interest to you, identifying your preferences, and personalizing your experience with Venminder;
• Using Personal Information for a specific purpose that we communicate to you; and
• For any other purposes about which we notify you.

We use your Personal Information in this context based on an agreement that we have in place with you or our legitimate interest for security purposes (e.g., the prevention and investigation of fraudulent activities). The Personal Information used for these purposes will be deleted based on the terms of any agreement between us or pursuant to our policy (see “How Long Do We Keep Your Personal Information?”).

Finally, we use the information that we purchase from third party sources that have a right to sell us such information, for our direct marketing activities, based on our legitimate marketing purposes.

How We Share and Disclose Information to Third Parties
Venminder does not rent or sell your Personal Information to anyone other than authorized service providers that support our business, as described below. We share and disclose information (including Personal Information), and have disclosed such information in the preceding twelve months about our customers as reasonably necessary for the following legitimate business purposes and in the following limited circumstances:

• Third Parties - We may share your Personal Information with third party vendors, consultants, contractors, and other “service providers” who we employ or with whom we have a contract to perform duties and/or tasks on our behalf, only sofar as reasonably necessary for the business purposes. These companies include our payment processing providers, website analytics companies (e.g., Google Analytics), website advertisers (e.g., LinkedIn), product feedback or help desk software providers, CRM service providers (e.g., Salesforce), email service providers, e-sign providers (e.g. Docusign), and intelligence providers (e.g. 6sense), and others. Categories of Personal Information that we may share with these third-party service providers may include your name, email address, postal address, phone number, job title, and employer.

If Venminder receives your Personal Information and subsequently transfers that information to a third-party agent or service provider for processing, Venminder remains responsible for ensuring that such third-party agent or service provider processes your Personal Information to the standard required by our privacy commitments, and is contractually prohibited from selling or otherwise using your Personal Information for any reason other than providing the contracted services to Venminder.

• Event Sponsors - If you attend an event or webinar organized by us, or download or access an asset on our website, we may share your Personal Information, such as name, email address, postal address, phone number, job title, and employer, with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy policy. If you do not wish for your Personal Information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned.
  
  
• Business Transfers - We may choose to buy or sell assets and may share and/or transfer your Personal Information in connection with such transactions, including to any subsidiaries, insofar as reasonably necessary for the business purposes.
  
  
• Disclosures for National Security or Law Enforcement - Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
  
  
• Protection of Venminder and Others - We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of Venminder, our employees, our users, or others.

How We Provide Data Security
We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. An information security policy is maintained to govern our overall information security posture. The policy addresses the confidentiality, integrity, and availability of our products and services and is owned and reviewed by our Chief Information Security Officer annually to ensure it remains up-to-date and relevant. Data in transit to or from, or stored within, our platform is encrypted using industry best practices. Employees are required to take security and privacy training upon hire and annually thereafter. Employees also undergo background checks upon hire. Our internal control environment is SOC 2 Type II audited to ensure controls are designed appropriately and operate effectively. Penetration testing is performed by a third party annually to assess our network and platform, with significant findings remediated or mitigated timely. Physical security is managed by our service provider, Amazon Web Services (AWS), who provides infrastructure-as-a-service to us. We review AWS’s SOC 2 Type II report annually to ensure the aspects of data security they manage are designed appropriately and operate effectively.

While we follow generally accepted standards to protect Personal Information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our Websites, please contact us by using the information in the “Contacting Us" section, below.
 
How Long Do We Keep Your Personal Information?
We may retain your Personal Information for a period consistent with the original purpose of collection (see “What Information Does Venminder Collect”, above) or as long as required to fulfill our legal obligations or legitimate legal or business purposes. We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of the Personal Information being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, or upon your verified request (see “Individual Rights”, below) your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such information. We may retain your Personal Information if necessary for compliance with a legal obligation or to protect your vital interests or the vital interests of another person.
 
Cookies and Other Tracking Technologies
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device to remember information about you, such as your language preference or login information. The cookies from our website are set by us and called first party cookies. Depending on which of our Websites you are visiting, we may also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts, as well as to understand your browsing of our Websites (for example, which page you visit or how long you stay on each page). Venminder uses cookies and other tracking technologies for the following purposes:

• Assisting users with navigation
• Assisting with the registration to our events, login, and your ability to provide feedback
• Analyzing your use of our products, services and/or applications
• Assisting with our promotional and marketing efforts (this includes tracking preferences and behavioral advertising)

Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.
For information about cookies, including what cookies we use and how to manage cookies and cookie preferences, please see our Cookies Policy. 

Google Analytics
On some of our Websites, we also may utilize Google Analytics, a web analysis service provided by Google, to better understand your use of the Website and Services. Google Analytics collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers an opt-out mechanism for the web available here.

“Do Not Track” Disclosures
Venminder adheres to the standards set out in this Privacy Policy and does not monitor or respond to “Do Not Track” browser requests.

Your Privacy Rights
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

Marketing Communications
You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the unsubscribe link in the emails communications we send or by using the information in the “Contacting Us” section, below.

If you have an account for our Services, we will still send you non-promotional communications, such as service-related emails.

Children
Our Websites and Services are not directed at children. We do not knowingly collect Personal Information from children under the age of 13. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the “Contacting Us” section below and we will take steps to delete their Personal Information from our systems.

Individual Rights
You may have certain rights relating to your Personal Information, subject to local data protection laws. To the extent provided by applicable laws, these rights may include the right to:

• Access your Personal Information held by us;

• Know more about how we processed your Personal Information;

• Correct inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete;

• Erase or delete your Personal Information (also referred to as the right to be forgotten);

• Restrict our processing of your Personal Information;

• Obtain a transferable copy of Personal Information that you have provided to us, to the extent possible (right to data portability);

• Object to any processing of your Personal Information carried out based on our legitimate interests. Where we process your Personal Information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;

• Opt out of certain disclosures of your Personal Information to third parties;

• If you’re under the age of 16, opt in to certain disclosures of your Personal Information to third parties;

• Not be discriminated against, and receive equal service and price, for exercising your rights described above;

• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our Websites or in our Services; and

• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

If you are located in the European Economic Area (the “EEA”), you also have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

How to Exercise Your Rights
To exercise your rights listed above, please contact us by using the information in the “Contacting Us” section, below. We try to respond to all legitimate and verified requests within one month, but in any event within the applicable legal time frames, and will contact you if we need additional information from you in order to verify and honor your request. Occasionally it may take us longer than a month, considering the complexity and number of requests we receive. If you are an employee of a Venminder customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.
Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.

To update your billing information, discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contacting Us” section, below.

Venminder Client/Vendor Submitted Information
We may unintentionally receive and store Personal Information uploaded by Venminder clients or vendors. If not stated otherwise in this Privacy Policy or in a separate disclosure, our obligations with respect to that Personal Information is as a processor, and we will take immediate appropriate action once we are made aware of receiving such unintentional Personal Information. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Policy. If your data has been submitted to us by or on behalf of a Venminder client or vendor and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. If you wish to make your request directly to us, please provide us the name of the Venminder client or vendor who submitted your information to us. We will refer your request to that client or vendor and will support them as needed in responding to your request within a reasonable timeframe.
 
Linked Websites
Our website makes use of hyperlinks that link to other websites not owned or operated by Venminder. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of any of these linked sites or of any companies that we do not own or control. These other sites may collect information in addition to that which we collect on the Websites. Venminder does not endorse any of these other sites, the services, or products described or offered on such other sites, or any of the content contained on them.
 
Transferring Your Personal Information
If you are located in the EEA, note that you are transferring your Personal Information to a location outside the EEA, specifically to our servers located in the United States. When you provide personal information to us, we request your consent to transfer that personal information to the United States. The United States does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the United States provide adequate protection for personal information. Although the laws of the United States do not provide legal protection that is equivalent to EU data protection laws, we safeguard your personal information by treating it in accordance with this Privacy Policy. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your personal information in storage. We use secure transmission methods to collect personal data through our website. We also enter into contracts with our data processors that require them to treat personal information in a manner that is consistent with this Privacy Policy.
 
Changes to the Privacy Policy
Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. You can see the date on which the latest version of this Privacy Policy was posted. Unless stated otherwise, our current Privacy Policy applies to all Personal Information we have about you and your account. We will alert you to material changes by, for example, placing a notice on our Websites and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. You are responsible for periodically reviewing this Privacy Policy.