Last modified: August 25, 2020
This Policy describes the types of information we may collect from you or that you may provide to us, and our practices for collecting, using, maintaining, protecting, and disclosing such information. We are committed to protecting the privacy and accuracy of your personally identifiable information to the extent possible, subject to applicable provincial and federal laws. This Policy applies when you use the website venerides.com (our "Website") or when you download, register to use, access, or use the VENE mobile application (our “App”), (together, our “Services”). It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries), or any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Other than as required by laws that guarantee public access to certain types of information, or in response to subpoenas or other legal instruments that legally require disclosure, personally identifiable information is not disclosed without your consent.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with these policies and practices, your choice is not to use our Services.
BY ACCESSING AND/OR USING OUR SERVICES, YOU AGREE TO THIS POLICY.
This Policy may change from time to time, and we will post the new Policy on our website and notify you by email or by an in-App alert the first time you use the App after we make the change. Your continued use of the Services after we make changes to the Policy is deemed to be acceptance by you of those changes, so please check the Policy periodically for updates.
Children under the Age of 13
Our Services are not intended for children under 13 years of age and children under the age of 13 are not permitted to use any of our Services. No person under the age of 13 may provide any personal information to the Website or our App. We do not knowingly collect personal information from children under the age of 13. If you are under the age of 13, you may not register on the Website or through our App, make any purchases through the Website or App, or provide any information about yourself to us, including your name, address, telephone number or email address. If we learn that we have collected or received personal information from a child under the age of 13 without parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us so that we may delete such information.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Services, including:
- information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, date of birth, driver’s license, login credentials, payment information (e.g. credit card number, expiration date, authorization number or security code, billing address), your geographic location in connection with your use of the Website or the App, and other information, including but not limited to demographic information, that you provide to us through the App or Website (collectively, "Personal Information");
- information that is about you but individually does not identify you, such as usage data while you use the Services including geographic location, trip duration, start and stop times, dates of use of the Services, station use, station ID number, station location, mobility device ID number, and user type; and
- information about your internet connection and the equipment that you use to access our Services.
We collect this information:
- directly from you when you provide it to us, such as information that you provide by filling in forms on our Website and/or App. This includes information provided at the time of registering to use our Website and/or App, and while subscribing to and/or using our Services. We may also collect information from you when you respond to surveys that we might ask you to complete from time to time for research and business development purposes. We may also ask you for information if you report a problem with our Services;
- automatically as you navigate through the Website and App. Information collected automatically may include usage details, IP addresses, geographic location, and information collected through cookies, web beacons, and other tracking technologies; and
- from third parties, such as analytics providers, business partners, and payment processors.Information You Provide to Us
The information we collect on or through our Services from you may include:
- information that you provide by filling in forms on our Website and/or App.;
- records and copies of your correspondence (including contact information such as email addresses) if you contact us;
- your responses to surveys that we might ask you to complete from time to time for research and business development purposes;
- details of transactions that you carry out through our Services and of the fulfillment of your orders; and/or
- your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- details of your visits to our Website and/or App, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Website and/or App; and
- information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. This information helps us to improve our Services and to deliver better and more personalized experiences, including by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Services according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Website and/or App.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information on managing your privacy and security settings for Flash cookies, see the section below titled “Choices About How We Use and Disclose Your Information”.
- Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to compile website statistics, such as counting users who have visited those pages, recording the popularity of certain website content and verifying system and server integrity.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal information:
- to present our Website and/or App and its contents to you, and to provide our Services to you;
- to create and manage your account;
- to provide you with information, products, or services that you request from us from time to time;
- to fulfill any other purpose for which you provide it;
- to provide you with notices about your account, including expiration and renewal notices;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our Website, App and/or Services;
- to allow you to participate in interactive features on our Website and/or App;
- to promote bike sharing, mobility devices, and related programs;
- to send you promotional material;
- for testing, research, analysis, and product development;
- to comply with and enforce applicable legal requirements, industry standards and contractual obligations;
- in any other ways we may describe when you provide the information; and
- for any other purpose with your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect from you and/or that you provide to us in accordance with this Policy:
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which case Personal Information held by us about users of our Website, App and Services is among the assets transferred;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information; and/or
- to such other parties and/or for such other purposes for which you have given your consent.
We may also disclose your Personal Information:
- to comply with any court order, law, or legal process, including responding to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website, located at www.networkadvertising.org.
Accessing and Correcting Your Information
You can review and change your Personal Information by logging into the Website and/or App and visiting your account profile. You may also send us an email at firstname.lastname@example.org to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Accordingly, any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Services.
If you wish to use methods other than online enrollment, you may submit requests by email to email@example.com or mail addressed to: 1111 Lincoln Road, Ste 500, Miami Beach, FL 31339.
Links to Other Sites
You may encounter links to the web sites of organizations not directly affiliated with the Services or with us. Please be aware that we are not responsible for the information practices of external organizations. We recommend you review the privacy statements of each external Web site that collects personal information.
It is our policy to post any changes we make to this Policy on this webpage. If we make material changes to how we treat our users' Personal Information, we will post the new Policy on our website and notify you by email or by an in-App alert the first time you use the App after we make the change. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and/or App and this Policy to check for any changes.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our CCPA Privacy Notice.
To ask questions or comment about this Policy and our privacy practices, contact us at: 786.789.5489
VENE’S Privacy Notice for California Residents
Effective Date: August 22, 2019
Information We Collect
Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, VENE's Services has collected the following categories of personal information from its consumers within the last twelve (12) months:
Examples of Information
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, physical characteristics or description, address, telephone number, driver's license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older) and gender.
D. Commercial information.
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Behavioral characteristics or activity patterns used to extract a template or identifying information such as physical patterns and health or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include: (i) publicly available information from government records; (ii) deidentified or aggregated consumer information; and (iii) information excluded from the CCPA's scope, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and (b) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
VENE obtains the categories of personal information listed above from the following categories of sources:
- Directly from you when you provide it to us by, for example, filling in forms on our Website and/or App at the time of registering to use our Website and/or App, while subscribing to and/or using our Services, through your responses to surveys that we might ask you to complete from time to time for research and business development purposes, through details of transactions that you carry out through our Services and of the fulfillment of your orders, through records and copies of your correspondence (including contact information such as email addresses) if you contact us, and through your search queries on the Website.
- Directly and indirectly as you navigate our Website and App. For example, information collected may include usage details, IP addresses, geographic location, and information collected through cookies, web beacons, and other tracking technologies.
- Indirectly from you by, for example, through information we collect from you in the course of providing you Services.
- From third-parties that interact with us in connection with the services we perform, such as analytics providers, business partners, and payment processors.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. If you provide your personal information to purchase our Services, we will use that information to process your payment and facilitate delivery and we may also save your information to facilitate new purchase our Services or to process refunds.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To provide, support, personalize, and develop our Services and to create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
- To personalize your Website and/or App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and/or App, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website and App, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of VENE’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by VENE about our Website and App users is among the assets transferred.
VENE will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
VENE may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties:
- Service providers and contractors, including third-party payment processors, who need access to such information to carry out work on our behalf.
- Our subsidiaries and affiliates.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Our affiliates.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which case personal information held by us about users of our Website, App and Services is among the assets transferred.
- To governmental or regulatory authorities to the extent necessary to comply with any court order, law, or legal process, including responding a government or regulatory request.
- To such other parties and/or for such other purposes for which you have given your consent
In the preceding twelve (12) months, we have not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that VENE disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling 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 (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that VENE delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at [786.789.5489].
- Visiting [www.venerides.com].
- Sending an email to: firstname.lastname@example.org
Only you, or a person registered with the California Secretary of State that you authorize 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. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share Your personal information with third parties for their own direct marketing purposes.
Changes to Our Privacy Notice
VENE reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the new Policy on our website and notify you by email or by an in-App alert the first time you use the App after we make the change, and update the effective date. Your continued use of our Website and/or App following the posting of changes constitutes your acceptance of such changes.