Privacy Policy

Last updated February 17, 2021

At Venteur, Inc., a Delaware corporation (the “Company,” “we,” “us,” and “our”), we strive for transparency and trust when it comes to protecting your personal information. This data and privacy policy (“Privacy Policy”) explains how information about you is collected, used, and disclosed by the Company when you access or use our website (the “Site”) and our online benefits and/or other services (the “Service”), which are provided through the Site. By using the Site and/or the Service, you consent to the collection, use, and disclosure of your information as outlined in this Privacy Policy.

What’s in this policy?

This Privacy Policy tells you:

  • what information we might collect about you

  • how we might use that information

  • when we might use your details to contact you

  • what information of yours we might share with others

  • your choices about the personal information you give us

Information we collect

When you visit the Site or utilize the Company’s Service, we may collect and store certain information about you, some of which can be used on its own or in combination with other information to identify you individually (“personal information”). We collect the following personal information and other information:

  • Information you provide: your name, your contact information and email address, phone number, date of birth, Social Security number or taxpayer-identification number, and benefits enrollment information.

  • Market research programs: we may collect information from you, including personal information, if you choose to participate in a market research program survey.

  • Public information: we may collect information about you from public sources, such as public social media pages, including information such as what industry you work and where you work.

  • Health and health insurance information: If you use the Service to manage benefits (“Benefits Service), we may receive personal health information about you and your dependents in order to provide the Benefits Services. The health information may include information about your insurance carrier, insurance plan and claims you submit for coverage. We receive the health information (i) directly from you when you submit enrollment or claims information, or otherwise provide health information to us; (ii) from the primary policyholder on your benefits plan, if you are a spouse or dependent of the primary policyholder; (iii) from your employer; (iv) from insurance carriers; or (v) from other third-party administrators.

  • Automatically collected information: your IP address and device identifier, operating system, browser type and the address of a referring site, including the data profile regarding your online behavior on the Site, through cookies and related technologies.

How we use your information

  • to administer the Site, manage accounts and provide the Service

  • to monitor, analyze, improve, and develop the Site and Service, and to create and test new Service features

  • to provide a more customized experience on the Site, Service and/or our partners’ or affiliates’ websites

  • to understand our users better

  • to validate user information provided to us for fraud and risk detection purposes

  • to determine eligibility for the Service and our partners’ programs

  • to prevent, identify and address fraudulent or other illegal activity and security issues

  • to (i) solicit feedback, (ii) respond to comments, requests or inquiries, (iii) provide customer service and support, or (iv) otherwise contact you in connection with the Site or Service

  • to generate anonymized, aggregated data containing only de-identified, non-personal information that we may use to publish reports

  • for our marketing purposes, such as (i) informing you of our or our partners’ or affiliates’ products, services, features or offerings that may be of interest to you, (ii) providing you with newsletters, articles, reports, updates, and announcements, as well as information about upcoming events, (iii) contacting potential customers you have referred to us via a referral program (“Referred Leads”), (iv) improving and tailoring our advertising and communications, (v) analyzing our marketing efforts, and (vi) determining your eligibility for certain programs, events and offers

  • to operate our business, which includes, without limitation, using your information (i) to process payment transactions, (ii) to manage and enforce contracts with you or with third parties, (iii) to manage our corporate governance, compliance, and auditing practices, and (iv) for recruitment purposes, if you submit an application for employment with the Company;

  • to (i) comply with laws, rules and regulations, including any disclosure or reporting obligations, (ii) resolve disputes with users or third parties, (iii) respond to claims and legal process (including but not limited to subpoenas and court orders) as we deem necessary or appropriate, (iv) protect our property rights or those of third parties, (v) protect the safety of the public or any person, and (vi) prevent or stop any activity which we may consider to be (or to pose a risk of being) illegal, unethical or legally actionable; andfor any other purpose for which you expressly authorize us to use your information.

How we work with third parties

Information from third parties

We may collect additional information about you from other companies, including a consumer reporting agency or through an authenticated bank account you agree to link to the Services.

Use of social media

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.

The Company may also publish content on social media platforms, e.g., Twitter, Facebook, LinkedIn, Instagram, through both “organic” and “paid” methods to reach current and potential users:

  • “Organic” methods describe where content and/or offers are published onto a social platform so that they may appear in your social platform’s content, without being promoted or forced to appear more prominently, e.g. Venteur’s Facebook Page.

  • “Paid” methods describe where content and/or offers are published onto a social platform so that they will appear more prominently, or be shown to users that do not currently follow Venteur’s social pages e.g. a promoted tweet on your Twitter Timeline.

We may place one or more social media platform “tags” on our Site in order to better understand how the Company may be of best value to you by providing you with the most relevant Services available according to your interactions with us on the Site. These tags only record information around events to help us understand what products or services are of interest to you so that we may use your preferences to provide more relevant content and/or offers to you, on social media platforms, e.g. removing benefits offers from your feed if you are already a current policyholder.

We do not have direct access to your personal data on your social media platforms.

Links to Third-Party Websites

​Our Site and our Services may also allow you to connect with us, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others as we do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy policies.

Retaining and storing your information

We employ administrative, physical and technical measures designed to protect your information from unauthorized access and to comply with HIPAA, HITECH and other applicable state and federal privacy and security laws. However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed to prevent any interception or other type of misuse. We also depend on you to protect your information. If you become aware of any breach of security or privacy, please notify us immediately.

Opt-out rights

If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us as indicated at the end of the Privacy Policy or by following the “unsubscribe” instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your account, the provision of Services, or related transactions with us.

Our cookie policy

Once you agree to allow our Site to use cookies, you also agree that the Company may use the data it collects regarding your online behavior (analyze web traffic, web pages you spend the most time on, and websites you visit).

The data we collect by using cookies is used to customize our Site to your needs. After we use the data for statistical analysis, the data is completely removed from our systems.

Please note that cookies don’t allow us to gain control of your computer in any way. They are strictly used to monitor which pages you find useful and which you do not so that we can provide a better experience for you. If you want to disable cookies, you can do it by accessing the settings of your internet browser.

Individuals under 18

If you are under the age of 18, do not use our Service or submit any information us on the Site. The Company’s Services are not directed to children under the age of 18 and we do not knowingly collect personal information from children under the age of 18. However, if a child under the age of 18 is a dependent on a benefits plan covered by the Benefits Service, we may collect information about the child (solely as needed to provide the Benefits Service) from the child’s parent or legal guardian, or from insurance carriers and third-party administrators.

Individuals under 18

​In addition to the rights of this Privacy Policy, if you are a California resident you have some additional rights under the California Consumer Privacy Act of 2018 (“CCPA”), including the right to be informed when any of your “Personal Information” has been “sold” and to opt-out of the future selling of your data to third parties. By “Personal Information,” we mean personal information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you. This does not include information that is aggregated or information that cannot be reasonably linked to you.

How we collect, use and share personal information

​In order to provide the products or features as part of the Company’s Services, we must process information about you, including Personal Information. Subject to the limitations described elsewhere the Privacy Policy, we may share your Personal Information for business purposes with strict restrictions on how our partners can use and disclose the data we provide, at your direction, or in ways otherwise in accordance with the CCPA. We don’t sell any of your Personal Information, and we never will.​

The best way to learn about the kinds of information we collect and how we use it is to review the “Information we collect” portion of the Privacy Policy. Here is a summary of the CCPA-related categories of Personal Information that the Company may collect, including how the information is used, and with whom we may have shared it.

Categories of Personal Information we may collect:

Examples of how Personal Information is used:

Parties with whom each category of Personal Information may be shared:

  • Identifiers (e.g., name, alias, email address, mailing address, phone number, signature);

  • Data with special protections, if you choose to provide it;

  • Commercial information, if you choose to provide it;

  • Internet or other electronic network activity information, including content you view or engage with;

  • Professional or employment information, if you choose to provide it;

  • Education information, if you choose to provide it;

  • Health information, if you choose to provide it;

  • Insurance information, if you choose to provide it;

  • Financial information, if you choose to provide it; and

  • Information derived from other Personal Information about you, which could include your preferences, interests, and other information in market research programs, if you choose to provide it

  • Providing, personalizing, and improving our Services;

  • Performing services, facilitating transactions, analytics, and other business services;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;

  • Communicating with you; and

  • Researching and innovating for technological development and demonstration;

  • Verifying and maintaining quality or safety of a service;

  • Improving, upgrading or enhancing Service controlled by the Company; and

  • Advancing the Company’s commercial or economic interests.

  • Third-party vendors or partners (including product partners, business development partners) of the Company;

  • Independent contractors of the company;

  • Apps, websites, and third-party integrations on or using our Services; and

  • Law enforcement or other third parties in connection with legal requests.

Your rights under the CCPA

Under the CCPA, you have the following rights:

  • Right to know: you have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;

  • Right to request deletion: you have the right to request that we delete your Personal Information that we have collected from you;

  • Right to non-discrimination: we will not discriminate against you for exercising any of these rights.

Please note that to protect your information and the integrity of our Services, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government-issued ID. Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf.

Contacting us for more information​

If you have any additional questions about this CCPA Notice or how to exercise your rights under the CCPA, please contact us as indicated below, and reference “CCPA” in the subject line.

Changes to this policy

We reserve the right to modify and revise our Privacy Policy from time to time. If we make any material changes to this policy, we will notify you of such changes by posting them on our Site, informing you through the Service, or sending you an email or other notification, and we will indicate when such changes will become effective. By continuing to access or use our Site or the Company’s Services after these changes become effective, you are agreeing to be bound by the revised policy.

Contact us

Please contact us at hello@venteur.co if you have any questions about our Privacy Policy and/or our privacy practices.

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