Vena Solutions Privacy Policy
Last Updated: July 25, 2024
Vena Solutions Inc and its group of companies (“Vena”/”we”/”us”) respect privacy and values the confidence of users of our services (“Clients”). This Privacy Notice (the “Notice”) sets forth the privacy principles that Vena follows with respect to the processing of Personal Information (as defined below) in connection with our website at www.venasolutions.com (the “Website”), our events and the delivery of our cloud application run as Software as a Service (SaaS) and ancillary services (collectively, the “Services”). For example, this Notice describes how Vena collects and uses Personal Information through the Services. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your Personal Information. Unless otherwise specified in this Notice, the use of Personal Information collected through our Services shall be limited to the purpose of providing the Services for which the Client has engaged Vena.
Definitions
For the purposes of this Notice, “Personal Information” means any information or data that can be used to identify a natural person, either directly or indirectly. Personal Information does not include information that is anonymous, namely any information that, even when combined with additional information which is likely to be used by the Data Controller (as defined below), cannot be linked to a natural person.
Data controller
Vena is the Data Controller which processes your Personal Information, as described in this Notice. The registered office of Vena is located in 2 Fraser Avenue, Suite 200, Toronto, ON, Canada, M6K 1Y6.
A Note About Children.
The Services are intended for use by business users. Accordingly, we do not intentionally gather Personal Information from persons who are under the age of 16. If such a person submits Personal Information to Vena and we learn that the Personal Information is the information of a person under the age of 16, we will use reasonable efforts to delete the information in a timely manner. If you believe that we might have any Personal Information from a minor, please contact us at privacy@venacorp.com.
Personal Information Collection and Use
We collect Personal Information about you in three ways: directly from your input, from third-party sources, and through automated technologies.
Data You Provide to Us
The types of Personal Information that we collect directly from you depends on how you interact with us and the Services and may include:
- Contact details, such as your name and work email address, postal address and phone number;
- Account login credentials, such as usernames and passwords, password hints and similar security information;
- Other account registration and profile information, such as educational and professional background and photo;
- Comments, feedback and other information you provide to us, including surveys, questions, or information you send to customer support; and/or
- Interests and communication preferences, including preferred language.
Data From Your Organisation
We may obtain Personal Information about you from the organisation with which you are employed or affiliated in order to activate and manage your access to and use of the organisation’s subscription to the Services, including:
- Contact details, such as your name and work email address, postal address and phone number;
- Other account registration information, such as job title; and/or
- Organisational user ID.
Data From Other Sources
We also may obtain contact details and other Personal Information about you from our affiliates and from other third parties, including:
- Service providers that help us determine a location in order to customise certain products or Services to your location;
- Partners with whom we offer co-branded services or engage in joint marketing, sales or Service delivery activities;
- Service providers who we engage to analyse how you engage with the Services; and/or
- Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.
The complete list of affiliates and third parties from which we gather Personal Information about you can be provided on request by writing to privacy@venacorp.com.
Data From Service Use
The Services may automatically collect Personal Information about how you and your device interact with the Services, including:
- Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
- Usage data, such as the features you used, the settings you selected, how you engage with the Services, your URL click stream data, including date and time stamp and referring and exit pages, and pages you visited on the Services; and/or
- For location-aware Services, the region, city or town where your device is located in order to provide you with more relevant content for where you are in the world.
- We collect this data through our servers and the use of cookies and other technologies. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Website, our events and/or the Services. For more details, visit the cookie notice of the Services.
Cookies and other Tracking Technologies
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We and our partners use cookies or similar technologies to analyze trends, administer the Website, track users’ behaviour around the Website.
System Logs & Cookies: Cookies are used by us to track content usage and traffic on the Website. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. Cookies help us compile aggregate statistics about usage of this Website and the Services, such as how many users visit the Website, how long users spend viewing the Website, and what pages are viewed most often. This information is used to improve the content of the Website. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website, our events or the Services.
Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information in our databases.
Cookies that we use: We use cookies for the following purposes:
- Authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website (cookies used for this purpose are identified as “Authentication Cookies” here [link to Table of Cookies];
b. Personalisation - we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are identified as “Personalisation Cookies” here [link to Table of Cookies);
c. Security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are identified as “Security Cookies” here;
d. Advertising - we use cookies to help us to display advertisements that will be relevant to you
e. cookies used for this purpose are identified as “Advertising Cookies” here;
f. Analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are identified as “Analysis Cookies” here; and
g. Cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are identified as “Consent Cookies” here.
Cookies used by our service providers: We use various third parties who gather information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about their use of information by visiting their sites linked from the Table of Cookies. The relevant cookies are identified here as Third Party Cookies [link to Table of Cookies].
Managing cookies: Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
6.2 Blocking all cookies will have a negative impact upon the usability of many websites.
6.3 If you block cookies, you will not be able to use all the features on our website.
Purposes of Personal Information Processing and relevant Legal Bases
Applicable data protection laws (including under the General Data Protection Regulation, United Kingdom GDPR, Data Protection Act 2018, Privacy and Electronic Communications Directive 2002/58/EC (updated by Directive 2009/136/EC), and the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), and such substantially similar provincial legislation), collectively, the “Applicable Data Protection Laws”) sets out a number of different reasons for which we may collect and process your Personal Information in certain circumstances. Where Applicable Data Protection Laws apply, the legal bases we rely upon are described below:
- Registration
We process your Personal Information for managing the registration to our Website or events and/or subscribe to use the Services (including, for example, to provide our Services to you, to receive login credentials to the Services as part of your employer’s subscription, or to allow you to participate in interactive features of our Services (if applicable)). The processing of this Personal Information (e.g. the email address you provided to receive access to our Services) is necessary to perform the contract(s) in place between you and Us.
For example, when using the Services, including registering for the Services, you may be required to provide us with contact information or account registration information which includes but is not limited to your name, email address, phone number, and company name.
- Marketing
We process your Personal Information to send you marketing communications, where you have given your consent, about our products, promotions and events, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you (including individual and pseudonymous analysis and profiling). You can withdraw your consent at any time by clicking on the unsubscribe button at the bottom of each e-mail received.
However, where you have provided us with your e-mail address in the context of the sale of our services, we may send you marketing communications via e-mail without asking for your prior consent. In any case, you may always opt-out from this processing activity, by clicking on the unsubscribe button at the bottom of each e-mail received.
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter(s) to you. You may choose to stop receiving our newsletter(s) or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you contacting us using the contact information found at the bottom of this Notice.
- Compliance with legal obligations
If the law requires us to, we may need to collect and process Personal Information for legal compliance reasons. For example, we can share details of people involved in fraud or other criminal activity with law enforcement or other regulatory authorities.
- Internal Statistic and Security
We process your Personal Information to (a) ensure that content from our Website is presented in the most effective manner for you and your computer so that we can provide you with the information, products and services that you request from us, and (b) keep our Website and our Services safe and secure
- Legitimate interest
We may require Personal Information to pursue our legitimate interests or those of a third party in a way which might reasonably be expected as part of running our business, and which does not materially impact your rights, freedom or interests.
Personal Information of individuals using or accessing the Services, and certain usage data gathered through the Services, may be accessed by or shared with corporate administrators for the purposes of usage analysis, subscription management and compliance, cost attribution, and departmental budgeting.
Recipients
As at the date of this Notice, we only share Personal Information about you in respect of the Website, events, and Services with our service providers and partners (including subcontractors) who provide services such as the following: website hosting, cloud services, implementation and other services delivery, customer service, analytics, email marketing, event marketing, data loss prevention and payment processing. In particular, Vena uses the following service providers that process Personal Information on its behalf: List of Vena Sub-processors.
From time to time, we may engage third parties to help us manage and/or improve event registration, the Website and/or the Services. These third parties may have limited access to databases of user information solely for the purpose of helping us to manage and/or improve events, the Website and/or the Services and they will be subject to contractual restrictions governing their use of the Personal Information in accordance with our obligations in this Notice and under applicable law. Unless we tell or agree with you otherwise, such third parties do not have the right to use the Personal Information we share with them beyond what is necessary for them to provide the relevant services and fulfill their contractual obligations.
For Personal Information subject to Applicable Data Protection Laws, such Personal Information may be collected, transferred to, and stored by us, our affiliates, and/or third-parties described above, in Canada, the United States, or other countries outside the United Kingdom and European Union. We will take all necessary steps to ensure that the recipient of the applicable Personal Information adheres to an adequate level of protection and security, in compliance with the GDPR and other relevant data protection laws. This may include, where applicable, entering into appropriate contractual agreements, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Our service providers may host data worldwide and accordingly your Personal Information may be available to governments worldwide under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.
The complete list of affiliates and third parties to which we disclose Personal Information about you, as well as their relevant country and the legal basis of the transfer, can be requested by writing to privacy@venacorp.com.
Change of Ownership
We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used in accordance with this Privacy Notice by the entity acquiring the information.
Law Enforcement; Subpoenas
Vena may disclose Personal Information, including the information you submit to the Services, with or without notice: (a) if required by a subpoena, bankruptcy proceedings, similar legal process or other judicial or administrative order, (b) where required by law, or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual or the general public or to prevent violation of our agreements or the rights of Vena or any third party.
Data Retention
We will retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. Once the data is no longer needed for these purposes, it will be securely deleted or anonymized. Specifically, Personal Information will be deleted or anonymized within 12 months after the termination of our relationship with you, unless a longer retention period is required by law. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Notice.
If you request that your Personal Information be removed from our databases, in line with paragraph “Your rights relating to your Personal Information” below, we will do so but please note that it may not be possible to completely delete all your Personal Information due to technological and legal constraints: in this case we will inform you of such constraints. Additionally, in some circumstances, Vena may not be able to delete or erase the data subject’s Personal Data in full to comply with specific legal requirements.
Your rights relating to your Personal Information
You may have certain rights relating to your Personal Information under Applicable Data Protection Laws. These may include the right to:
- Access such Personal Information held by us, including the provision of a copy of such Personal Information;
- Know more about how we process such Personal Information;
- Rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete;
- Erase or delete such Personal Information;
- Restrict our processing of such Personal Information;
- Opt out of certain disclosures of such Personal Information to third parties;
- Opt out of the sharing of such Personal Information for delivering advertisements on non-Vena websites, applications, and services;
- Not be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects;
- 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;
- Receive the Personal Information that you have provided us or which we gathered from you based on your consent or on the performance of a contract between us, in a structured, commonly used and machine-readable format or to request its transfer to a third party;
- Not be unlawfully discriminated against for exercising your rights as described above.
Moreover, if you believe that your Personal Information is being processed in a way that violates or infringes upon Applicable Data Protection Laws, you are also entitled to lodge a complaint with the competent Data Protection Authority of the EU Member State in which you reside, work or where the alleged breach has taken place. A full list of such authorities may be found here.
We will make reasonable efforts to keep your Personal Information accurate and up-to-date.
How to exercise your rights
Access and Accuracy: You may access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect of you and to have a general account of our uses of that information. Following receipt and review of your written request, we will provide you with a copy of your Personal Information, subject to non-disclosure obligations we may have at law and/or to third parties. Where applicable, we will provide reasons for withholding such information to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
You may, at any time, choose to correct or update the Personal Information you have submitted to Vena, by updating your account in our Service or by contacting us at privacy@venacorp.com. You can also contact us at privacy@venacorp.com with other requests related to your Personal Information. If your details are provided through a corporate account, then you may need to contact the administrator of that corporate account. If you are a customer or employee of one of our Clients and would no longer like to be contacted by one of our Clients that use our Services, please contact the Client that you interact with directly.
California Privacy Rights
The California Consumer Privacy Act (as amended by the California Privacy Rights Act) (collectively, the “California Privacy Laws”)_ _requires businesses to disclose whether they sell or share certain Personal Information as defined under California Privacy Laws. We do not sell Personal Information. We may allow third parties to collect Personal Information in connection with our Website or Services if those third parties are authorized service providers who have agreed to contractual limitations as to their retention, use, and disclosure of such Personal Information in accordance with California law.
If you are a resident of California, you may have the right to:
Disclosure and Access
You can request that we disclose certain information to you about our collection and use of applicable Personal Information in the past 12 months with respect to our role as a “business” under California Privacy Laws. Once we receive your request and verify your identity, we will give you the following information, if and as required under California Privacy Laws:
- The categories of Personal Information we collected about you.
- The categories of sources of Personal Information we collected about you.
- Our business or commercial purpose for collecting or using that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information over the past 12 months, we will provide the categories of Personal Information that were shared with third party partners or service providers.
Correction and Deletion
You can request that we correct inaccuracies in your Personal Information, or that we delete applicable Personal Information that we collected from you. Once we receive your request and verify your identity, we will correct or delete, as applicable, your Personal Information from our records, if and as required under California Privacy Laws. We are not required to delete Personal Information if we need to use it for the following:
- Completing a transaction or contract with you;
- Detecting security risks, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing or intended functionality to our Services;
- Exercising, and allowing others to exercise, free speech, or exercising another right provided for by law;
- Internal uses that reasonably align with your expectations;
- Complying with a legal obligation; or
- Otherwise use Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.
Non-Discrimination
We will not retaliate or unlawfully discriminate against you for exercising any of your rights under California Privacy Laws.
Exercising Rights
To exercise the above rights, please send a letter or email with your request and current contact information to Vena at:
Vena Solutions Inc.
Attention: Privacy Officer
2 Fraser Ave, Suite 200
Toronto, ON
M6K 1Y6
Or Email: privacy@venacorp.com
Before we comply with your access or deletion request, we will ask you to verify your identity. This process may require you to provide additional information, which we will only use for verification purposes.
Dispute Resolution
Any questions or concerns regarding the use or disclosure of Personal Information as set forth in this Notice should be directed to Vena at privacy@venacorp.com. Vena will investigate and attempt to address complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Notice.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Security
The security and confidentiality of your personal information is very important to Vena. We have implemented commercially reasonable technical and organizational safeguards to appropriately protect your personal information against accidental, unauthorized, or unlawful access, use, loss, destruction or damage. Please visit our Trust Center to see the measures that we utilize.
Still, no system can be guaranteed to be 100% secure. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described in this Privacy Notice.
Changes to this Privacy Notice
This Notice was last updated on July 2, 2024. It is subject to change and may therefore be amended from time to time. In that case, appropriate notice will be given concerning material amendments or changes to this Notice. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact details
If you wish to contact us regarding our processing of your Personal Information as set forth in this Notice, you may do so using any of the following:
email: privacy@venacorp.com
phone: 1.855.434.2814
mailing address: 2 Fraser Avenue, Suite 200, Toronto, ON, Canada, M6K 1Y6