Effective date: September 1, 2020
This privacy notice is provided in accordance with the General Data Protection Regulation 2016/679 (“GDPR”), including any EU national laws implementing or supplementing the same, and any other applicable data protection laws.
PRAE-VENIRE, LLC (hereinafter, “PRAE-VENIRE” and/or “Company” and/or “we”) provides due diligence, compliance, background screening, and other risk consultancy services to clients. In this respect PRAE-VENIRE providing these services may act as data processor or as a separate data controller depending on the service being provided and the amount of control PRAE-VENIRE has over the purpose(s) and means of the data processing.
To the extent that PRAE-VENIRE is deemed to be a data controller under Data Privacy Laws, this notice fulfils its obligation to provide certain information to third parties whose personal data we process in this capacity as required by Article 14 of the GDPR and the notice requirements set out in any other Data Privacy Laws for processing personal data which has been obtained indirectly.
OUR COMMITMENT TO PRIVACY
PRAE-VENIRE reevaluates this Policy on an ongoing basis and reserves the right to change its Policy at any time in its sole discretion. All changes to the terms of this Policy shall be effective as of the date on which they are posted on the Website. It is your responsibility to check this page periodically for any such changes or updates. Your continued use of or access to the Website or our services following the posting of any changes, modifications, or updates constitutes your express acceptance thereof.
Your continued use of PRAE-VENIRE’s Website is at all times subject to the Terms and Conditions, which incorporate this Policy. Any terms not defined in this Policy shall have the same definitions given to them in the Terms and Conditions.
INFORMATION COLLECTED AND USE OF INFORMATION
PRAE-VENIRE may gather date, time, information about a user’s browser and system or device configuration and capabilities, navigation history, and IP address for all visitors to the Website to monitor and track Website use and traffic patterns in order to provide a more personalized experience on the Website. PRAE-VENIRE may use this information for its internal security audit log, for trend analysis and system administration, and to gather broad information about its audiences. However, PRAE-VENIRE does not routinely link IP addresses to anything that identifies you as an individual.
In addition to the above, we may use the following technologies to automatically collect information about your activities on our Website: cookies, flash cookies, web beacons, clear pixels, or pixel tags, web server logs, and geo-location technologies.
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Website to:
- Assist law enforcement and respond to subpoena;
- Respond to service requests;
- Email you regarding your inquiry or consultation;
- Compile anonymous statistical data and analysis for use internally or with third parties;
- Increase the efficiency and operation of the Website;
- Monitor and analyze usage and trends to improve your experience with the Website;
- Notify you of updates to the Website;
- Offer new services, and/or recommendations to you;
- Perform other business activities as needed;
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity;
- Resolve disputes and troubleshoot problems.
HOW WE COLLECT AND USE DATA
Information You Provide to PRAE-VENIRE
We receive and store any information you knowingly provide to us. We may use any information you provide to us for our business purposes.
The data you provide to us will be processed where the processing is necessary for your legitimate business interests in conducting and managing our business, in accordance with the purposes: to provide the products or perform the services requested by you and your company pursuant to a letter of engagement, statement of work, or similar; for legitimate business purposes to advise you through e-mail, phone call, or mail, in the framework of our ordinary business relationship, about products or services similar to the products or services we have provided to you and that we think will be of interest to you; for marketing purposes, and you may opt-out of receiving marketing communications and updates at any time; for security purposes to protect, to protect PRAE-VENIRE and its third parties against security breaches and to prevent fraud and violation of PRAE-VENIRE applicable agreements.
Information Collected Automatically
Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geo-location data, device identification, “cookie” information, web beacons, the type of browser and/or device you’re using to access our Website, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Website are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. A “web beacon” is an object that is embedded in a page or email and is usually invisible to the user but allows checking whether a user has viewed the page or email.
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Website as such data can provide us with how often users use a particular feature of the Website, and PRAE-VENIRE can use that knowledge to make the Website interesting to as many users as possible.
Who is collecting data?
Data will be collected by PRAE-VENIRE.
Data PRAE-VENIRE collect:
Contact data: We may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients or potential clients. For example, contact details of individuals who work for or on behalf of the clients, in order to carry out the client’s engagement with PRAE-VENIRE.
Service data: Clients may provide personal data to us as a requirement to perform the services. PRAE-VENIRE may also acquire personal data from a third party as required to perform services requested by our client(s).
Marketing information: We may collect information to respond to inquiries regarding our services or to provide you with information, reports, or updates.
PERSONAL INFORMATION RECEIVED
PRAE-VENIRE does not rent or sell your Personal Information in personally identifiable form to anyone, provided certain Personal Information may be shared with third parties as described in this section:
Protection of PRAE-VENIRE and Others: We may use or disclose personally identifying information if we have a good-faith belief that the disclosure is reasonably necessary (a) to satisfy applicable law, regulation, legal process, or enforceable governmental request, (b) to enforce agreements we have with you, (c) to address fraud or security issues, or (d) to protect against harm to the rights, property, or safety of the users, or our employees.
Processing of Personal Information
This Policy covers our treatment of personally identifiable information (“Personal Information”) that PRAE-VENIRE gathers when you are accessing or using our Website and when we collect personal data to offer and administer our services. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Website, including to enhance and personalize your experience with PRAE-VENIRE, to contact you, to fulfill your requests for certain services, and to analyze how you use the Website. PRAE-VENIRE may also share some Personal Information with third parties, but only as described below.
“Personal Information” shall refer to information which you provide to us which personally identifies you, and includes, but is not limited to, your name, email address, mailing and/or physical address, telephone number, and other information or data that identifies you, which is provided by you through your use and access of the Website or if you otherwise directly provide such information to us.
Whenever we process your “Personal Information” for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your written consent or are otherwise required or permitted to by law. You have the right to object to this processing if you wish.
PRAE-VENIRE’s Website is directed to individuals over the age of eighteen (18). It is not intended for children under thirteen (13) years of age. PRAE-VENIRE does not knowingly solicit data online from, or market online to, children under the age of thirteen (13) years. In addition, children under the age of thirteen (13) years are not permitted to submit any personal information to PRAE-VENIRE or the Website. If you believe that a child under 13 may have provided us personal information, please contact us at firstname.lastname@example.org.
Personal data and services provided to our clients
Our clients engage us on a wide range of matters to help them mitigate risk, for example to conduct due diligence on a potential partner, supplier, employee, investment or acquisition target. PRAE-VENIRE has a legitimate interest in processing data to support its clients in these objectives provided that the privacy rights of any individual are negatively affected.
The personal data we process while providing our services for and on behalf of our clients includes but is not limited to any information relating to living individual, identified or identifiable, as name, contact and financial information, education and work history, directorship, and when necessary, data concerning criminal convictions and offences and some special categories of information as sensitive personal data, as defined by laws of other jurisdictions.
In connection with our services we collect various types of personal data from a variety of different sources, such as our clients, public sources (public records, social media websites, and internet), other third party sources (corporations and industry in general).
We only share personal data with your consent or in accordance with this notice for the purposes set out in it.
PRAE-VENIRE may share your information with external third parties (vendors, consultants, legal advisors, auditors and other service providers who are performing, advising or assisting with certain services on behalf of PRAE-VENIRE. Such third parties have access to personal data solely for the purposes of performing the specified services in the applicable contract, and not for any other purpose. PRAE-VENIRE requires these third parties to undertake security measures consistent with the protections specified in this notice.
PRAE-VENIRE may be required to disclose personal data in response to lawful requests by public authorities, including national security or law enforcement requirements.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Personal information may be transferred, accessed and stored as necessary for the uses stated above, in accordance with this notice, and in compliance with local law and regulations.
You have the right:
- To access personal information that PRAE-VENIRE holds about you;
- To ask to rectify information PRAE-VENIRE holds about you if it is inaccurate or incomplete;
- To request that PRAE-VENIRE erases your personal data (we will keep basic data that identifies you and retain it solely for preventing further unwanted processing);
- To ask PRAE-VENIRE to restrict how we process your data (we are allowed to store the data but not further processing it, and we keep sufficient data to make sure we respect your request in the future);
- To object to PRAE-VENIRE processing your data, when processing is based on legitimate interests (we will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing, and we will keep basic data to indentify you and to retain it solely for preventing unwanted processing).
Providing information to PRAE-VENIRE
If you choose not to provide certain personal information, it may be an impediment to the contract execution and we may not be able to provide you with some desired services.
PRAE-VENIRE uses reasonable administrative, technical, and physical security measures to protect your information. Because of the constitution of the Internet, however, the rules of data protection and the security measures mentioned above may not be observed by other persons or institutions beyond PRAE-VENIRE’s control. Especially unencrypted data – even if sent via e-mail – can be read by third parties. PRAE-VENIRE has no technical influence to avoid this. You have the responsibility to protect the information you provide, especially username and passwords, from misuse, whether by encryption or other means.
RETENTION PERIOD Personal Information shall be processed and stored for as long as required by the purpose they have been collected for. PRAE-VENIRE may be allowed to retain Personal Information for a longer period whenever you have given consent to such processing and for as long as such consent is not withdrawn. Furthermore, PRAE-VENIRE may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.
CONSENT TO PROCESSING AND TRANSFER OF WEBSITE INFORMATION
The Website is governed by and operated in, and in accordance with the laws of, the United States. PRAE-VENIRE makes no representation that the Website is governed by or operated in accordance with the laws of any other nation. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located in Latin America, the European Union, Canada or elsewhere outside of the United States of America, please be aware that information we collect may be transferred to and processed in the United States. By using the Website, or providing us with any information, you (a) acknowledge that the Website is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.
CALIFORNIA CONSUMER PRIVACY ACT
The CCPA provides specific privacy rights to California residents, including:
- The right to receive privacy notice;
- The right to know what personal information we have collected about you during the past 12 months;
- The right to request to access the personal information that PRAE-VENIRE holds about you, including categories of information collected, categories of sources from which the information is collected, our business purpose for collecting information, and categories of third parties with whom we share your information.
- The right to know what categories of personal information we have shared with unaffiliated third parties;
- The right to opt out of having your personal information sold; – The right (with certain exceptions) to request deletion of your personal information that is covered by the CCPA;
- The right to non-discrimination. PRAE-VENIRE will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.
You can email us with your request for information. Our contact information is provided at the end of this notice. The CCPA includes other exceptions and exemptions that may limit your ability to exercise CCPA rights for certain types of personal information and certain kinds of relationships between a consumer and PRAE-VENIRE.
Categories of Personal Information
The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual.
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (personal information).
Personal information does not include aggregate or de-identified information or publicly available information from government records.
The table below explains the categories of personal information we may collect from California residents generally:
Name, alias, postal address, unique personal identifier, online
identifier, internet protocol address (IP Address), email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
Personal Information categories described in California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Protected classification characteristics under California or federal law
Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
Physical location or movements.
Professional or employment-related information
Current or past job history
Non-public education information (per the Family Educational Rights and Privacy Act
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student financial information
Inferences drawn from other personal information.
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Sources of Personal Information
- Information directly from you, the consumer, that you choose to provide, when you interact with us, for example, when you communicate with us by phone, email or otherwise, register for an event, subscribe to marketing or other communications, or inquire about or purchase a product or service.
- Information we automatically collect when you interact with our website, content or emails such as your IP address and the pages you visited, and when you use our services, we may collect information on how you use those services. Please see our Website Use and Cookies Policy for additional information.
- Information provided by our clients in order for us to provide specific services as a service provider, or information from third parties, acquired at the direction of our clients in order to provide the services.
- Information from other sources, including service providers or publicly available sources.
We collect personal information to offer and manage our services and products. These include valuation, corporate compliance advisory, governance, risk, investigations, and related services. We use personal information for the following business purposes:
- To provide the products or perform services for clients pursuant to a written agreement, including contacting you in the course of our ordinary commercial relationship, verifying client information, processing payments, or similar activities as needed to provide services for or on behalf of our clients.
- For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding PRAE-VENIRE such as information about promotions, events, products or services. You may opt-out of receiving marketing communications and updates at any time.
- To improve PRAE-VENIRE’s communications with you. Emails sent to you by PRAE-VENIRE may include standard tracking, including open and click activities. PRAE-VENIRE may collect information about your activity as you interact with our email messages and related content in order to verify or maintain the quality of our communications, or improve, upgrade, or enhance the services we provide.
- For security purposes, including detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
- For other business purposes, which will be disclosed at the time we collect personal information.
Disclosure and Sharing of Personal Data
In the preceding 12 months, we have not sold any personal information.
We share personal information for business purposes with the following categories of third parties:
- Service providers, such as vendors, consultants and other service providers who perform certain services on behalf of PRAE-VENIRE, in which case we enter a contract that describes the purpose of processing and requires the recipient to not use it for any purpose except performing the contract.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
For your security, we will not return personal information outside the scope of the CCPA in response to an access request, except as otherwise required by law.
For questions or concerns regarding this Policy, practices of the Website, or any other transaction issue, please send e-mail to email@example.com.