Privacy

Last Updated: September 2019

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Venn 2014 Ltd. and its subsidiaries (together, “Venn” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“Member”, “you”) such as in the following use cases:

  1. When you browse or visit our website, https://vennglobal.wpengine.com/ (and together with its sub-domains, the “Website”), including:
  2. When you request a tour of our community(ies), and the surrounding neighborhood(s);
  3. when you sign up for our mailing list/newsletter;
  4. when you submit a job application through Website; and
  5. When you contact us (e.g., customer support or inquiries).
  6. When you sign up for our living experience services (or “Services”), whether offline or by making use of, or interact with, our mobile software application, and any other mobile software application, that we license to our Members (each individually, and collectively, the “App”), including:
  7. When you download our App and create an Account; or
  8. When you upload your personal data to our App;
  9. When we use the Personal Data of our customers (e.g., when you use certain Services we provide, or purchase a product or service through our App).
  10. In other instances other than the Website and App, such as:
  11. When you attend a marketing event (including when exchanging business cards);
  12. When we acquire your personal data from third-party sources (e.g., from lead generation companies);
  13. we use the personal data of our suppliers and service providers.
  14. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide Services that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “personal data” or “personal information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. Period of storage of collected information
  3. How we protect and retain your personal data
  4. How we share your personal data
  5. Additional information regarding transfers of personal data
  6. Your privacy rights
  7. Use by children
  8. Interaction with third party products
  9. Analytic tools
  10. How to contact us

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What Information we collect, why we collect it, and how it is used.

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Data we collect
Why is the data collected and for what purposes?‍Legal basis (GDPR only)‍Consequences of not providing the data‍
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Cookies, analytic tools and log files For more information, please read our cookies policy, available at: https://legal.venn.city/general/cookies
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To customize our Website and Services for your needs. To improve our Website and Services.
Legitimate interest (e.g., when using essential or functionality cookies). Consent.
Cannot collect and store the information. Cannot use or access some parts of the Website
When you browse or visit our Website‍
‍
  • First and last name
  • Email address
  • Phone number
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To provide potential Member’s with information about our community(ies).To send marketing communications.
Our legitimate interest (following your request for a tour).Consent
Cannot process your request for a tourCannot send marketing communications
When you request a tour of our community.‍
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  • Full name
  • Email address
  • Phone number
  • Any other data you decide to provide/supply
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To add you to our mailing listTo send you newsletters or other marketing communications.
Our legitimate interests (following your request). Consent
Cannot add you to our mailing list Cannot send you marketing communications
When you sign up for our newsletters / email list‍
‍
  • First and last name
  • Email address
  • Phone number
  • Resume
  • LinkedIn Profile URL
  • Personal website (optional)
  • Any other personal data you choose to provide us.
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To internally process your job application. To assess the candidate
Necessary, at your request, prior to entering into a contract with us. Legitimate interest (e.g. to process job applications)
Cannot process your job application. Cannot assess your suitability as a candidate
When you submit a job application‍
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  • Full name
  • Email address
  • Phone number
  • Any other data you decide to provide/supply
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To process and answer questionsTo provide support (e.g., to solve problems, bugs or issues). To customize your experience
We have a legitimate interest to respond your enquiry.
Cannot assist you and respond your query, or provide you with the necessary support (as applicable)
When you contact us for customer support‍
‍
  • First and last name
  • Email address
  • Phone number
  • Nationality
  • Gender
  • Date of Birth
  • Optional – profession; and
  • Any other Personal Data you choose to share with us through the App, Site, or otherwise
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To create an account. To process your application to join or community
Processing is necessary for the performance of a contract between us, to which the Member is party or in order to take steps,  at your request prior to entering into a contract
Cannot create an account. Cannot process the product order and perform the agreement
When you create an account on our App and/or go through our onboarding process‍
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  • Full name
  • Email address
  • Phone number
  • Billing information (Credit Card etc.)
  • Location
  • IP address
  • Any other data you decide to provide/supply or that we request for a specific purpose.
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To provide our Members with requested products and servicesTo communicate with our members
Have a legitimate interest (e.g., when we send you contract-related communications)Should we require consent for a specific processing operations (e.g., signing you up to a new service), we shall do so on a case by case basis.
Cannot perform the agreementCannot communicate with you
When we use the personal data of our members‍
‍
  • Full name
  • Email address
  • Phone number
  • Company name
  • Any other data you decide to provide/supply
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To establish a business connectionTo send newsletters and marketing materials
It is in our legitimate interest (e.g. when we send you more information about Venn). Consent
Cannot establish a business connection. Cannot send you marketing communications
When you attend a marketing event (including when exchanging business cards)‍
‍
  • Full name
  • Email address,
  • Phone number,
  • Location,
  • move-in date
‍
To contact potential members and send them marketing issues
Consent
We will not be able to get in touch with you and send you marketing materials
When we acquire your Personal Data from third-party sources (such as lead-generation companies)‍
‍
  • Full name
  • Email address
  • Company name
  • Job position
  • Phone number
  • Any other Personal Data provided to us in connection with the services.
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To contact our service providers. Processing the order of the applicable service
Processing is necessary for the performance of a contract to which the service provider is a party to, or in order to take steps at the request of the service provider prior to entering into a contract with us.
Cannot communicate with you. Cannot process the order of the service
When we use the personal data of our service providers and suppliers‍
‍
  • Full name
  • Email address
  • Phone number
  • Social media profile
  • Any other data you decide to provide/supply
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To reply and/or respond to your request or questionTo establish a first business connection/discussion
We have a legitimate interest to respond your enquiry (e.g., send you more information about Venn)
Cannot reply or respond to your request
When you request a tour of our community.‍

Finally, please note that some of the abovementioned personal data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

PERIOD OF STORAGE OF COLLECTED INF

  1. Your personal data (as described above) will be stored until we (i) no longer need the information and proactively delete it; or (ii) you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your personal data perpetually.
  2. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy (available in the link provided above).

HOW WE PROTECT AND RETAIN YOUR INFORMATION

  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  2. Retention of your personal data. In addition to the retention periods mentioned in Section 2 above, In some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

HOW WE SHARE YOUR PERSONAL DATA

  1. We will share your data with several categories of recipients, for the following activities:
  1. With multinational payment processing service providers, for billing purposes;
  2. With Canadian screening service providers, for background check purposes; and
  3. US based security service provider in order to help us keep our members residence secure.
  4. In addition to the recipients described above, we may share your personal data as follows:
  1. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  2. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
  3. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
  4. Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
  5. While we strongly encourages its service providers, partners, and other recipients of our member’s personal data to adopt responsible approaches to privacy, Venn, to the maximum extent permitted under applicable law is not and will not be responsible for the information practices of any of the third party entities referenced in this Privacy Policy, which may use the information we share with them for the same purposes as we use the information, or for their own independent purposes. The collection, use, and disclosure of information by such recipients are subject to their respective privacy policies, which may differ from this Privacy Policy.

ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

  1. Internal transfers: Transfers within the Venngroup will be covered by an internal processing agreement entered into by members of the Venngroup (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
  2. External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data, or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

  1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
  • You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at info@venn.city. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  1. Deleting your account: Should you ever decide to delete your account, you may do so by emailing info@venn.city. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

USE BY CHILDREN

  1. We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@venn.city.
  1. INTERACTION WITH THIRD PARTY PRODUCTS
  2. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

ANALYTIC TOOLS

  1. Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often Members visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  2. Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Members, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.
  3. Mixpanel. We collect personal information such as your email address and your Member activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.
  4. AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution and marketing analytics platform to understand the use of our services. AppsFlyer is exposed to the following data: (i) unique identifiers and technical data, such as IP address, Member agent, IDFA (Identifier For Advertisers) or Android ID (in Android devices); and (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. The use of this data allows us to analyze our campaigns and performance, as well as your habits and characteristics. For example, the data AppsFlyer receives includes downloads, impressions, clicks and installations of their mobile applications, mobile device use and data regarding in-app events. AppsFlyer’s terms of use (available at https://www.appsflyer.com/terms-of-use/) and privacy policy (available at https://www.appsflyer.com/privacy-policy/) also apply to the use of AppsFlyer.
  5. UXcam. We use UXcam (relevant terms available at: https://help.uxcam.com/hc/en-us/articles/360004158171) to collect and analyze data from our services.
  6. Hotjar. The Website uses Hotjar in order to better understand our Members’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our Members experience (e.g. how much time they spend on which pages, which links they choose to click, what Members do and don’t like, etc.) and this enables us to build and maintain our service with Member feedback. Hotjar uses cookies and other technologies to collect data on our Members’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized Member profile. Neither Hotjar nor we will ever use this information to identify individual Members or to match it with further data on an individual Member. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a Member profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
  7. Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  8. Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about Members who have turned on Ads Personalization, base across device types and on aggregated data from Members who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above.
  9. Facebook Custom Audience
  10. Lookalike Audience

CONTACT US

  1. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@venn.city.