Privacy guidelines & principles

Ventiv Technology Inc. and Ventiv Technology Group International Ltd (“Ventiv”) (wholly-owned subsidiaries of Symphony Technology Group) is committed to the highest level of integrity in all of our dealings with our clients, employees and service partners. This commitment extends to any personal data about our customers that we might possess or acquire. This privacy policy describes how Ventiv collects and uses the personal information you provide on our web site: http://www.ventivtech.com. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Safe Harbor Privacy Statement

Ventiv has been awarded TRUSTe's Privacy Seal signifying that this privacy statement and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal data. The TRUSTe program covers only information that is collected through the Web site, http://www.ventivtech.com.

TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy statement or practices, please contact us at doug.wilson@ventivtech.com. If you are not satisfied with our response you can contact TRUSTe here.

Ventiv complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Ventiv has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Ventiv’s certification, please visit http://www.export.gov/safeharbor/.

For purposes of this policy, “Personal Data” means information that:

  • Is transferred from the European Union or Switzerland to the United States;
  • Is recorded in any form;
  • Is about, or pertains to, a specific individual; and
  • Can be linked to that individual.

For purposes of this policy, “Data Subject” means the individual about whom the Personal Data relates.

Personal Data Processed for Customers
Ventiv provides customized risk management information systems to help companies manage their claims and exposure information more effectively. In this capacity, Ventiv does not directly collect the Personal Data it processes; as such Personal Data is collected and controlled by Ventiv’s customers. In the case of Personal Data so transferred to Ventiv, the customer remains responsible for compliance with the relevant EU member state’s data protection law vis-à-vis the Data Subject. Pursuant to these laws, the customer is obligated to enter into a data transfer agreement that sets forth the specific steps Ventiv must take to protect and secure the Personal Data in question. As such, when Ventiv typically is acting as the processor (i.e., not directly collecting Personal Data from Data Subjects) the data transfer agreement, rather than the Principles, specifies the data protection measures Ventivis required to follow.

Personal Data Collected From Data Subjects
Where Ventiv collects Personal Data directly from Data Subjects; it has committed to apply the Principles. The following is a summary of the processes Ventiv has in place to comply with the Principles:

Notice and Choice: Individuals may visit Ventiv’s public web site, without disclosing any Personal Data. As is true of most Web sites, Ventiv gathers certain information automatically and stores it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and click stream data. This data is aggregated and is not stored in any personally identifiable form. Cookies are not linked to personal data. Additionally, the website includes an online form for visitors to request additional company and product information. In order to fulfill these requests, the visitor may be required to submit Personal Data. The only Personal Data that Ventiv will collect is name, title, company name, email address, and phone number. This Personal Data will only be used to respond to sales inquiries, to provide Ventiv publications and for marketing campaigns.

Technologies such as: cookies, beacons, tags and scripts are used by Ventiv and our marketing partners, affiliates, or analytics or service providers, Google and social network sites. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We use cookies for Google analytics for website statistics, social media buttons usage as cookie policy varies per social media networks, for functional purposes of the content management system to give each anonymous visitor a unique code, the code doesn’t store any personal data but recognizes returning visitors. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Ventiv may disclose Personal Data if required to do so by law or to protect and defend the rights or property of Ventiv. We reserve the right to disclose your personal data as required by law and when we believe that disclosure is necessary to protect our rights and/or company with a judicial proceeding, court order, or legal process served on the Web site. If Ventiv is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

If Ventiv is required to obtain individual consent before collecting, processing or disclosing Personal Data it will offer Data Subjects the opportunity to choose whether their Personal Data is: (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the Data Subject. Ventiv will provide Data Subjects with reasonable mechanisms to exercise their choices should requisite circumstances arise.

Also, please note that Ventiv is not responsible for the content or privacy practices of non-Ventiv web sites to which any Ventiv web site may link. Data Subjects should review the privacy statement of such sites before using the sites.

Onward Transfer (Transfers to Third Parties): It is Ventiv’s policy to ensure that Personal Data is not used or disclosed except as necessary to provide requested goods and services, to protect the confidentiality or security of Personal Data or as otherwise permitted by law. We will share your personal information with third parties only in the ways that are described in this privacy policy. Ventiv does not rent, sell or share Personal Data with other companies, including Ventiv’s parent, subsidiary and affiliate companies for marketing purposes. However, in those situations where Ventiv retains third parties to perform processing tasks, Ventiv requires that these third parties either:

  • Subscribe to the Principles, the EU Data Protection Directive, the Swiss Federal Data Protection Act or another adequacy finding; or
  • Enter into a written agreement with Ventiv requiring the third party to provide an equivalent level of protection as provided by Ventiv.

Access: A Data Subject may request that Ventiv provide access to his/her Personal Data. Upon receipt of such a request, Ventiv will confirm whether or not it possesses Personal Data relating to the Data Subject and, where appropriate and necessary, will correct, amend, delete the Personal Data or have it removed from a testimonial. This right only applies to Personal Data relating to the Data Subject making the request and is subject to other limitations as defined by law.

Individuals should direct such requests to:

Ventiv Technology Inc.
3350 Riverwood Parkway
5th Floor
Atlanta, GA 30339
doug.wilson@ventivtech.com

Ventiv’s Privacy Officer may provide additional directions on how to submit such a request. In order to confirm the identity of the Data Subject and have the necessary information to retrieve the Data Subject's information, Ventiv may request additional information and reasonable administrative fees to process the request. Filing a request in English will expedite the process. Ventiv agrees to process all reasonable requests for access within five (5) business days, but reserves the right to deny or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the Data Subject’s privacy or in the case of vexatious or fraudulent requests.

Data Retention
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security
It is the policy of Ventiv to ensure that appropriate physical, technical and administrative controls are in place to safeguard against the unauthorized disclosure of Personal Data. Ventiv limits access to Personal Data to those persons in Ventiv’s organization that have a specific business purpose for accessing such Personal Data. The security of your personal data is important to us. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Data Integrity: Ventiv takes reasonable steps to ensure the Personal Data is reliable, accurate and complete. The steps Ventiv takes to ensure data integrity are made in light of the purposes for which the Personal Data is used. It is the policy of Ventiv to ensure that all Personal Data is maintained only as long as necessary or as otherwise permitted by law.

Enforcement: Data Subjects should direct questions or concerns regarding this policy or Ventiv handling of their Personal Data to:

Ventiv Technology Inc.
Privacy Officer
3350 Riverwood Parkway
5th Floor
Atlanta, GA 30339

Ventiv’s Privacy Officer will explain the process to be followed when raising such a question or concern. Submitting the question or concern in English will expedite the process.

Changes in this Privacy Statement
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change taking effect.

Social Media Widgets
Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy statement of the company providing it.

Blog / Forum
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blog or community forum, contact us at info@ventivtech.com. In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why.

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.

Communications from the Site

Special Offers and Updates
We will occasionally send you information on products, services, promotions, etc. You can sign up for these emails from us on our registration page.

Out of respect for your privacy, we present the option not to receive these types of communications. Please see the “Choice and Opt-out.”

Newsletters
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the “Choice and Opt-out” section.

Service-related Announcements
We will send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account. You may opt-out of these communications. Please see “Choice and Opt-out.”

Customer Service
Based upon the personal data you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

Choice/Opt-out
We provide you the opportunity to ‘opt-out’ of having your personal data used for certain purposes, when we ask for this information. For example, if you sign up for our user conference but do not wish to receive any additional marketing material from us, you can indicate your preference on our form.

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at info@ventivtech.com. We offer an opportunity to opt-out of certain communications on our website, or you may contact us at info@ventivtech.com to opt-out.

You will be notified when your personal data is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.

This Privacy Statement was last updated on 22 December 2014