PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS SITE.
Updated: September , 2018
Our commitment at VENZA® (VENZA, Inc., VENZA Group B.V. and our affiliates) is to protect hotel guests and keep their personal data safe. We are committed to protecting your privacy. This Privacy Policy applies to our websites (www.venzagroup.com, www.Venzapeak.com, and https://venzagroup.desk.com/) (the “Websites”) and our Matterhorn™, Denali™, and Everest™ subscription services (the “Subscription Service”). This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and collection of your Personal Information (as described below). If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites or the Subscription Service or provide or otherwise make available your Personal Information to us.
We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification if we have your email address available, or if you subscribe to the Subscription Service, through your VENZA portal.
Although we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.
Use of the Subscription Service by VENZA and Our Customers
The VENZA Subscription Service
Our online Subscription Service allows any company that uses it (our customers and VENZA itself) to create accounts and access content specific to information security and compliance. The Subscription Service can also be used to help provide training and awareness. The information added to the Subscription Service, either by site visitors providing their contact information or when a Subscription Service user adds the information, is stored and managed on our service providers’ servers. This information is then used to contact visitors about their interest in the company’s goods or services and interact with the company. VENZA provides the Subscription Service to our customers for their information security and compliance needs, and we use it to meet VENZA’s related needs.
Use by VENZA
We use our own Subscription Service to access content specific to information security and compliance. Information that we collect and manage using the Subscription Service for our own purpose belongs to us and is used, disclosed and protected according to this Privacy Policy.
Use by Our Customers
Our customers use the Subscription Service to access content specific to information security and compliance to learn more about their business. VENZA processes our customers’ information as they direct and in accordance with our agreements with our customers, and we store it on our service providers’ servers. Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the Subscription Service, as permitted by this Privacy Policy, and as required by law. We have no direct relationship with individuals who provide Personal Information to our customers. VENZA acknowledges that you have the right to access your Personal Information. Our customers control and are responsible for correcting, deleting or updating information they have collected from you using the Subscription Service. If requested to remove data, we will respond within a reasonable timeframe. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage. Our agreements with our customers prohibit them from using the Subscription Service to collect, manage, or process Sensitive Information (as described below). We are not responsible for our customers’ use of information they collect on the Subscription Service.
VENZA collects information under the direction of its customers and has no direct relationship with the individuals whose Personal Information it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our Subscription Service, please contact the customer that you interact with directly. We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
Sensitive Information
This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.
When You Visit Our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information (as defined below).
Personal Information
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, email address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
Personal Information also includes Navigational Information or payment information where such information can directly or indirectly identify an individual. “Navigational Information” refers to information about your computer and your visits to the Websites, such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Use of Navigational Information” section below. We collect and process payment information from you when you subscribe to the Subscription Service, including credit card numbers and billing information, using third party PCI-compliant service providers.
Log Files
When you use our services to view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by VENZA for the operation of the Subscription Service, to maintain the quality of the Subscription Service and to provide general statistics regarding the use of the VENZA Websites. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
Information We Collect from Third Parties
From time to time, we may receive Personal Information about you from third party sources, including partners with which we offer co-branded services or engage in joint marketing activities and publicly available sources such as social media websites.
Information about Children
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at privacy@venzagroup.com so that we may delete the information.
How We Use Information We Collect
Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our Subscription Service are obligated through our agreements with them to comply with this Privacy Policy.
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:
– Improve your browsing experience by personalizing the Websites and to improve the Subscription Service;
– Send information or VENZA content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
– Promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
– Provide other companies with statistical information about our users—but this information will not be used to identify any individual user;
– Send information to you regarding changes to our Customer Terms of Use, Privacy Policy (including the Cookie Policy), or other legal agreements; and
– Otherwise meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
We use the information collected through our Subscription Service by our customers for the following purposes:
– To provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
– To respond to customer support requests; and
– Otherwise to fulfill the obligations under the VENZA Customer Terms of Use.
Legal Basis for Processing Personal Information (EEA Visitors Only)
If you are a visitor/customer located in the European Economic Area (“EEA”), VENZA Group B.V. is the data controller of your Personal Information. VENZA’s Data Protection Officer can be contacted at privacy@venzagroup.com.
Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites and the Subscription Service. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about VENZA.
Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
Use of Credit Card Information
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Security of Your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Social Media Features
Our Websites include social media features, such as the Facebook Like button and widgets. These features may collect your IP address and which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
External Websites
Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Public Forums
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “To Unsubscribe from Our Communications” below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information. We securely delete the information or anonymize it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.
If you provide information to our customers as part of their use of the Subscription Service, our customers decide how long to retain the Personal Information they collect from you. If a customer terminates its use of the Subscription Service, then we will provide the customer with access to all information stored for the customer by the Subscription Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Service.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your VENZA account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How We Share Information We Collect with
Service Providers
We employ other companies and people to provide services to visitors to our Websites, our customers and users of the Subscription Service and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
VENZA Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
We partner with trusted third parties to provide you with products and services that we think may be relevant to you. When you engage with these partners, we will tell you with whom we are sharing data and provide a link to the partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These partners are required to adhere to our privacy and data protection policies.
Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by VENZA through the Websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our Website(s), of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order or legal process.
International Transfer of Information
International Transfers Within VENZA’s Entities
To facilitate our global operations, we transfer information to either the European Economic Area or the United States and allow access to that information from countries in which the VENZA affiliated entities have operations for the purposes described in this Privacy Policy.
This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected. When we share information about you within and among VENZA’s affiliated entities, we make use of standard contractual data protection clauses in accordance with the General Data Protection Regulation (GDPR).
International Transfers to Third Parties
Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area or the United States, we make use of the General Data Protection Regulation (GDPR), its data protection clauses, binding corporate rules for transfers to data processors or other appropriate legal mechanisms to safeguard the transfer.
Cookies and Similar Technologies
Cookies
VENZA and its partners use cookies or similar technologies (such as web beacons) to analyze trends, administer the Websites, track users’ movements around the Websites, and gather demographic information about our user base as a whole.
Navigational Information Collected by Our Customers
Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on the Subscription Service. VENZA does not control our customers’ use of these tools, nor do we control the information they collect or how they use it.
How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your Personal Information.
- You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
- If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Information.
Anti-Spam Policy
Our Acceptable Use Policy applies to us and to our customers and, among other things, prohibits use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service of an “opt-out” mechanism and other required information. We require all our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails, updating your communication preferences, or sending an email to us at privacy@venzagroup.com or sending postal mail to an office location below. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.
To Unsubscribe from Our Customers’ Communications
Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails or by contacting them directly.
Your Consent to This Privacy Policy
Use of the Websites signifies your consent, as well as the consent of the company for whom you use the Websites and whose information you submit (if any), to this online Privacy Policy, including the collection and use of information by VENZA, as described in this Privacy Policy, and also signifies agreement to the Terms of Use for the Websites. Continued access and use of the Websites without acceptance of the terms of this Privacy Policy relieves VENZA from responsibility to the user. We do not make any automated decisions based solely upon Personal Information you provide to us.
Contact
If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@venzagroup.com or by mail to:
Global Headquarters (USA)
VENZA, Inc.
Attention: Privacy
10886 Crabapple Road #100
Roswell, GA 30075 USA
European Office
VENZA Group, B.V.
Attention: Privacy
Prinses Margrietplantsoen 33, 2595 AM
The Hague, Netherlands