VENN PRIVACY POLICY

*Last Updated:* June 26, 2024

Venn NY, Inc., and its affiliated companies (together, "Venn" "we", "our" or "us") understand the importance of protecting the privacy of our users' Personal Information (as defined below). This privacy policy ("Privacy Policy") governs information you ("you") provide to Venn or we learn from your use of our application as well as all services provided by Venn (collectively, "Services") in order to provide you with a satisfying experience. In order to preserve your trust, we want you to understand what Personal Information we collect from you, how we use such Personal Information, and the choices you have regarding our use of this.

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal information. "Personal Information" means any information that can be used, alone or together with other data, to uniquely identify any living human being. We have a contractual relationship with our customers, the managers of the buildings (the "Customers"). In the context of the provision of our Services, the Customer can upload, add, input and/or allow the end users, the residents of the building making use of the App (the "End Users") to upload or share information, including Personal Information.

1. PERSONAL INFORMATION THAT WE COLLECT

We collect certain information when you use our Services. This includes information you provide to us, information we collect automatically, and information we receive from other sources.

Information you provide to us:

  • Account information. When you use our Services, you may provide Personal Information about yourself including your name and contact details (e.g. your address, email address and telephone number). You may also provide us with various other categories of Personal Information (e.g. profession, interest, your picture, family details), as well as any other information that you decide to provide us with.
  • Content you create. This includes any content that you upload to the Services. For example, you may write messages or posts, or upload and share photos through the Services.
  • Payment information. If you make payment through the App, you may need to submit a valid payment method and associated billing information, including your full name and billing address. Our third party payment processors, like Stripe and PayPal, receive and process your payment information. Depending on the processor, we may also receive and store certain billing information, which may include the last four digits of the credit card number associated with the transaction.
  • Information from actions you take. We collect information about your use of our Services and your activities on the Services. This includes without limitation, service requests you submitted, amenity reservation, events RSVP, and marketplace offering upload.

Information we collect automatically:

We also collect automatically via log files and other tracking technologies information from you when you use our Services. This includes:

  • Information about your device. We collect information about the device you are using to access the services. For example, this includes information like your IP address, operating system information, browser information and other such information.
  • Information about your use of the App. Information related to how and when you use our Services (such as the pages, the activities you engage in, number of interactions, and other such information), including log and events. We may capture your App browsing experience to expedite support and improve the Services.

We may receive information from cookies (small data files placed on your device that allow us to record certain pieces of information whenever you use or interact with the Services) and similar technologies. The cookies allow you to use the services and to help us analyze and improve your experience and the services. If you would like to opt out of the cookies and similar technologies we employ on the Services, you may do so by blocking, deleting, or disabling them as your device permits or by changing your settings and preferences on your device.

In certain circumstances, and only if you granted us permission, we may collect the location of your device in order to enable features of our Services (for example: smart locks and access control). This information is not stored on our servers and databases.

Information we receive from other sources:

We have a contractual relationship with our customers, the managers of the buildings (the "Customers"). In the context of the provision of our Services, we receive from the Customer certain Personal Information of you for the purpose of providing the Services (the "Common Data"). For example: your lease information, service orders, and similar information.

2. WHAT WE DO WITH YOUR PERSONAL INFORMATION

We will only use your Personal Information in order to:

  • provide you our Services,
  • provide you with Customer Support,
  • allow you to use specific features of our Service, for example: Group chat, Service request and Amenity Reservation
  • analyze your behavior during the use of Services
  • analyze technical errors and bugs fix
  • customize the Services for your needs
  • administer and improve the Services
  • we may also use your Personal Information to send you push notifications and/or emails and notifications regarding your account or certain features of the App.
  • In certain cases, we may or will anonymize or de-identify your Personal Information and further use it for internal and external purposes, including, without limitation, to analyze and improve the Services and for research purposes. We will use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).

3. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

We have implemented appropriate technical, organizational and security measures designed to protect your Personal Information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers.

We retain Personal Information until we determine it is no longer needed for the processing purposes for which we collected or retain it or for legal compliance.

4. HOW WE SHARE YOUR PERSONAL INFORMATION

We share some of your Personal Information with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your Personal Information as is reasonably necessary to provide the Service under reasonable confidentiality terms. We ask all our Service Providers to treat your Personal Information securely and in accordance with this Privacy Policy, and we will take reasonable steps to enforce this.

We may share some of the Personal Information with the Customers (who are the administrators of your building and have access to your requests, comments, bookings, actions, amongst others).

In addition to the recipients described above, we may share your Personal Information as follows:

  • To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer, some or all of our business, shares or assets to a third party, your Personal Information may be among the items sold or transferred. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.
  • 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 Information in connection with the foregoing events; and/or
  • Where you have provided your consent to us sharing or transferring your Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

If after having given us permission to pass your Personal Information to third parties you change your mind you can opt out by contacting us as described below.

5. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

Rights: You have the right to access the Personal Information held about you and to ask us to:

  • let you know which categories of Personal Information we hold about you;
  • make any changes or update to ensure that any Personal Information we hold about you is accurate and up to date; or
  • erase or stop processing any Personal Information we hold about you.

Exercise your rights: You can exercise your rights by contacting us at info@venn.city(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 fulfill 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.

Deleting your account: Should you ever decide to delete your account, you may do so by contacting your property manager. If you terminate your account, any association between your account and Personal Information 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.

Deletion of content from California residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to info@venn.city(info@venn.city). Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

6. USE BY CHILDREN

We do not offer our Services for use by children and, therefore, we do not knowingly collect Personal Information 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 Information to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Information 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.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We may 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 information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. ANALYTIC TOOLS

We collect Personal Information such as your email address and your activity through the use of our Services, using 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/(http://www.cooladata.com/privacy/). You can opt-out of Mixpanel's services by clicking on the following link: https://mixpanel.com/optout/(https://mixpanel.com/optout/).

We collect Personal Information such as your activity through the use of our Services, using Smartlook. Smartlook's ability to use and share information is governed by the Smartlook Terms of Use, available at https://help.smartlook.com/docs/terms-of-service (https://help.smartlook.com/docs/terms-of-service%C2%A0)and the Smartlook Privacy Policy, available at https://help.smartlook.com/docs/privacy-policy(https://help.smartlook.com/docs/privacy-policy). You can opt-out of Smartlook's services by clicking on the following link:_ https://www.smartlook.com/opt-out/(https://www.smartlook.com/opt-out/).

We reserve the right to remove or add new analytic tools.

9. Changes to this Privacy Policy

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Services or by other means.

10. CONTACT US

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(info@venn.city).

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