Vennio Privacy Policy

1. INTRODUCTION

IO Talent Limited, trading as “Vennio” (“Vennio”, “we”, “our”, “us”) are committed to protecting your personal data and handling it responsibly.

This policy sets out how we use and protect your personal data. It gives you information about how we collect and use your personal data when you download and use our apps and/or our website at www.vennio.com (our “Services”), including any personal data when you create an account with up, sign up to our newsletter, sign up to our Services, or any other product or service we may offer from time to time, take part in a competition or reach out to us for any reason.

Please check this policy for updates as we may update this policy from time to time.

This website is not intended for children (under 13 years old), and we do not knowingly collect data relating to children.

1. CONTROLLER

Vennio is part of a group of companies. This privacy and cookie policy is issued on behalf of the Ioconic Limited group of companies. So when we mention “Vennio”, "we", "us" or "our" in this privacy and cookie policy, we are referring to the relevant company in the Ioconic Limited group responsible for processing your data. IO Talent Limited is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy. If you have any questions about this privacy and cookie policy, including any requests, please contact the data privacy manager whose information is set out in paragraph ‎15 below [HYPERLINK TO PARAGRAPH].

1. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes the last four digits of your credit card.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, and information about your engagement on our Services, or on Instagram, Twitter and Discord, including on accounts belonging to Vennio;
• Usage Data includes information about how you use our Services, for example:
  • Activity data, such as content you create (posts, comments, audios, photos or videos), hashtags you use, the time, frequency and duration of your activities using our Services;
  • Information regarding people you follow and/or are following you, groups you’re part of, pages you follow; and
  • Information we infer based on your or others’ activities.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. It also includes information about your attendance at Vennio events.

We also collect, use and share Aggregated Data such as statistical or demographic data which is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your data to calculate the percentage of users accessing a specific feature of our Services to analyse general trends in our users interact with our Services in order to improve our Services.

We do not collect any Special Categories of Personal Data about you, this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health, and genetic and biometric data for our purposes. Nor do we collect any information about criminal convictions and offences. We recommend that you do not share any such information using our Services, but if you do, you are in control if you wish to delete any post or other content you upload on our Services containing such information.

1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:-

• Your interactions with us: we may collect personal data from your interactions with us, such as when you apply for the Services, create an account, subscribe to our Services or any newsletter, request that we send you marketing communications, enter into a competition, promotion or survey, when you give us feedback or contact us and when you engage with us online (such as on Instagram, Twitter and Discord or by using our website).
• Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this by using cookies, server logs and other similar technologies. Please see our cookie policy [HYPERLINK] for more information.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, such as analytics providers, advertising networks, payment processors, and search information providers.

1. WHY VENNIO PROCESSES YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. We rely on the following legal bases:

• Performance of a contract with you: where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: where we need to comply with a legal obligation to which we are subject.
• Consent: where we have obtained your active agreement to use your personal data for a specified purpose, for example, we will ask for your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to third party marketing at any time by contacting us.

1. PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user	(a) Identity (b) Contact	Performance of a contract with you (to provide you with access to the Services, and set up your account)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (where you have purchased goods or services from us) (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms and conditions, privacy policy and cookie policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (to inform you about updates to our terms applicable your use of our Services) (b) Necessary to comply with a legal obligation (including the UK GDPR, and consumer legislations) (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (to allow you to enter into the prize draw or competition) (b) Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business)
To administer and protect our business and our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (including the UK GDPR)
To deliver relevant content through our Services. We may also deliver relevant advertisement to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send your relevant marketing and make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or signed up to our Services, and you have not opted out of receiving that marketing. We will ask for your express opt-in consent before we share your personal data with any third party for marketing purposes.

1. OPTING OUT

You can ask us to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links at the bottom of any marketing communication, or contacting us at any time.

If you opt out of receiving marketing communications, you will still receive communications relating to the Services that are essential for administrative or customer service purposes for example relating to any order confirmations for products or service you bought, updates to our Terms and Conditions, checking that your contact details are correct.

1. COOKIES

For more information about the cookies we use and how to change your cookie preference, please see our Cookie Policy [HYPERLINK].

1. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with the Services, or part of the Services). In this case, we may have to cancel the Services, or part of the Services but we will notify you if this is the case.

14. WHO VENNIO SHARES PERSONAL DATA WITH

We will share your personal data with the following recipients:-

• Our group companies, including Ioconic Ltd for the purpose of administering our Services;
• Commercial partners (e.g. The Rocket Science Group LLC d/b/a Mailchimp), so they can advise us how best to communicate with you on their behalf.  We do not give your data to partners for them to communicate with you directly;
• third party suppliers acting as processors who provide IT and system administration services, or those involved in: data insights; website hosting; online personalisation; advertising; systems maintenance; database management; identity checking; payment processing; delivery logistics; and credit and debt management. These include:
• Mixpanel Inc. providing us with analytics on our Apps;
• Apple Inc. and Google Inc. supporting our Apps and providing information on their use;
• 650 Industries, Inc d/b/a Expo App Services to assist with log data and push notifications;
• Functional Software, Inc. d/b/a Sentry, to monitor our Apps performance and track errors; and
• Amazon Web Services to host personal data;
• Our third party payment processor Stripe Inc.;
• Professional advisers including consultants, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; and
• HM Revenue & Customs, regulators and other authorities.

If you’ve signed up for and consented to it, you may receive marketing communications from the Hosts OR from the Host you expressly agreed to share your contact information with. A “Host” is an athlete or sports club we’ve partnered with.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

1. PERSONAL DATA TRANSFERS OUTSIDE OF THE UK

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Where your personal data is transferred to a country outside of the UK, we will ensure your data is protected by appropriate safeguards. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or we may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

1. HOW LONG VENNIO RETAINS PERSONAL DATA

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period (such as after you’ve deleted your account) in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, tax purposes.

Where you have asked us not to send you direct marketing, we keep a record of this to ensure we comply with your request.

In some circumstances you can ask us to delete your data: see “Your Legal Rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

1. HOW TO CONTACT US AND EXERCISE YOUR RIGHTS

You can opt out of communications and can also correct your details through your account.

You can contact us at any time:

• by email to support@vennio.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1. KEEP US INFORMED OF CHANGES

We keep our privacy policy under regular review. 

It is important that the personal data we hold about you is accurate and current. You may update your personal data (other than the email address connected to your account) directly in your account. Please keep us informed if your personal data changes during your relationship with us.

1. THIRD-PARTY LINKS

Our Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Service, we encourage you to read the privacy and cookie policy of every website or app you visit.