1. Personal Information We Collect.

This Privacy Policy covers our use of “personal information.” When we say “personal information,” we mean information that relates to you and can – either on its own or in combination with other information – identify you as an individual. Personal information does not include data that has been de-identified or aggregated such that you can no longer be identified.

When you use our Services, we may collect the following kinds of information:

(a) Information You Provide to Us.

• Account Creation. If you create an Account, we will ask you for your name and email address.
  
  
• Online Orders. If you place an order with VENN, we will record the personal information and details associated with the transaction. For example, we will collect the items you purchase, your billing and shipping address, phone number, and payment information. Please note that we use a third-party service provider to collect and process payment card information on the Site. VENN does not directly collect or store any payment card information provided to the Site, but it may receive information associated with your payment card information (e.g., your billing details).
  
  
• Communications with Us. We may collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
  
  
• Customer Service and Support. If you call or otherwise interact with VENN’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes. 
  
  
• Interactive Features. VENN may offer interactive features such as commenting functionalities, review forums, chat services, and social media pages. VENN and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and may not be subject to the privacy protections referenced herein.
  
  
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

(b) Information We Collect Through Your Use of the Services.  We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off your IP address), Internet service provider, pages that you visit while using the Services, and other information about how you use the Services. Information we collect may be associated with your Account and the devices you use.

• Cookies, Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services.
• Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  
  
• Analytics. We may use Google Analytics and other service providers to collect information regarding user behavior and user demographics on the Services. This analytics data is not tied to any identifiable information. For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s processing of data generated by your use of the Services by visiting http://tools.google.com/dlpage/gaoptout.

(c) Information from Other Sources.  We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as a social networking service or a third-party login service, we may collect information about you from that third party that you have made available via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.

2. How We Use Your Information.

We process personal information for a variety of business purposes, including:

(a) To Provide the Services, Products, or Information Requested.

• Manage and fulfill orders;

• Respond to questions, comments, and other requests;

• Provide access to certain areas, functionalities, and features of our Services; and

• Answer requests for customer or technical support.

(b) Administrative Purposes.

• Measure interest and engagement in the Services;

• Improve our products and Services;

• Develop new products and services;

• Ensure internal quality control;

• Verify individual identity;

• Communicate with you about your Account, activities on the Services and policy changes;

• Process your payment card information and/or other payment methods for products purchased;

• Prevent potentially prohibited or illegal activities; and

• Enforce our Terms of Service.

(c) Marketing Our Products and Services.  We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

(d) De-identified and Aggregated Information Use.  We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, de-identified or aggregated information about the computer or device from which you access our Services, or other analyses we create.

(e) Sharing Content with Friends or Colleagues.  We may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Contact information that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by VENN or any other third parties for any other purpose.

(f) Technologies.  Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;
  
  
• Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  
  
• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services and keeping track of your specified preferences or past pages viewed;
  
  
• Advertising or Targeting Related. We may use first-party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our Services or on third-party sites.

(g) Other Uses.  VENN may use personal information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention. In addition, VENN may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

3. How We Disclose Your Information.

(a) We Use Service Providers.  We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment processing; (v) customer service activities; and (vi) the provision IT and related services.

(b) APIs and Software Development Kits.  We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your personal information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

(c) Information Shared with Other Users.  When you use the Services, you may share certain personal information, including User Content, with other users. This personal information may include your name and reviews you submit. Please be aware that VENN has little or no control over how individuals may use the information you share.

(d) Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide relevant personal information to business partners with whom we jointly offer products or services.

(e) Interest-Based or Personalized Advertising.  Through our Services, VENN may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

(f) Disclosures to Protect Us or Others.  We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

(g) Merger, Sale, or Other Asset Transfers.  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

4. International Data Transfers.

You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States and other countries.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

5. Your Choices.

(a) General.  You may have the right to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as described below.

(b) Email Communications.  If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).

(c) Technologies and Personalized Advertising.  If you would like to opt-out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits.  Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at https://thenai.org/opt-out/, https://www.youronlinechoices.eu/ and https://www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

(d) “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

6. Individual Rights in Personal Information.

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information held about you by VENN, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below. 

We will process such requests in accordance with applicable laws. To protect your privacy, VENN will take steps to verify your identity before fulfilling your request.

7. Data Retention.

We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8. Security of Your Information.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an e-mail to you.

9. Third Party Websites/Applications.

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

10. Children's Information.

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

11. Supplemental Notice for California Residents.

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information VENN has collected about them, and whether VENN disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Information” above, respectively.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, VENN does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

12. Supplemental Notice for Nevada Residents.  

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact” Us below.

13. Supervisory Authority.

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, and/or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

14. Changes to Our Privacy Policy.

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

15. Contact Us.

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

Venn Skincare, Inc.
750 N San Vicente Blvd
Ste 800 West
Los Angeles, CA 90069 USA

care@vennskincare.com

(888) 418-4302