Inveniam - Privacy Policy

‍Introduction

Inveniam and its subsidiaries ("Inveniam", "we", "us", "our") know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This webpage describes our privacy policy ("Privacy Policy"). By visiting our website, services, and applications (collectively, the "Services"), you are accepting the practices and terms and conditions described in this Privacy Policy.

This Privacy Policy addresses:

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1. What Information We Collect

The information we learn from customers and users of our Services helps us personalize and continually improve our Services and your experience. The types of information we gather include:

Information You Give Us: We receive and store any information you enter when using our Services or give us in any other way. This includes, but is not limited to:
- Contact and Profile Information: your name, email address, physical address, and phone number.
- Transaction Information: detail related to your subscriptions or purchases.
- Communications: information you submit to our support team or in response to surveys and other requests.

You can choose not to provide certain information, but then you might not be able to take advantage of some of our features.

Automatic Information: We receive and store certain types of information whenever you interact with us. For example, like many websites, our Services use “cookies,” and we obtain certain types of information when your web browser accesses our Services or advertisements and other content served by or on behalf of Inveniam on other websites. This includes:
- Log and Usage Data: such as your IP address, browser type, operating system and version, referral URLs, and web pages visited.
- Device Information: such as the device type, screen size, and device identifiers.
Mobile: When you use our Services via a mobile device, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to turn off location services.
Email Communications: To help us make emails more relevant, useful, and interesting, we often receive a confirmation when you open an email from us if your computer supports such capabilities. We also compare our customer list to lists received from other companies in an effort to avoid sending unnecessary messages to our customers.
Information From Other Sources: We might receive information about you from other sources, such as third-party data providers or public sources, and add it to our account information.

2. How We Use Your Information (Lawful Purpose)

We use the information we collect for various purposes:

To Provide, Improve and Add Services: We use your information to operate our Services, process transactions, respond to your requests, and continually improve our Services. (Contract & Legitimate Interests)

For Marketing and Communications: We use your information to communicate with you about product updates, offers, and events. You may withdraw your consent at any time. (Consent, Contract & Legitimate Interest)
For Safety and Security: We use information to protect against fraud, abuse, and to ensure the security of our Services. (Legal Obligation & Legitimate Interest)
To Comply with Legal Obligations: We may use your information as required to comply with applicable laws and regulations, including compelled disclosures to courts and regulators. (Legal Obligation, Consent & Legitimate Interest)

3. Cookies and Tracking Technologies

Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device during and between visits. The “help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies and saved site data, by changing the add-on’s settings or visiting the website of the software developer. Because cookies are required to take advantage of some of our Services' important features, we recommend that you leave them turned on.

Some web browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. There is no consensus in how Websites should interpret and respond to DNT signals. Most websites and web services do not change their behaviors or data collection based on DNT signals. Our Services do not currently respond to ‘Do Not Track’ (DNT) signals.

4. How We Share Your Information

Information about our customers is an important part of our business, and we are not in the business of selling your information to others. We share customer information only as described in this Privacy Policy and with our subsidiaries and affiliates that Inveniam controls that either are subject to this Privacy Policy or we believe follow practices at least as protective as those described in this Privacy Policy.

Within Our Own Organization: Access to customer information is strictly controlled and restricted to authorized personnel on a “need-to-know” basis.

Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples of these functions could include sending communications and email, delivering packages, sending mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, and providing customer service. These other companies and individuals could have access to personal information needed to perform their functions but they are not authorized to use it for other purposes.

Business Transfers: As we continue to develop our business, we might sell or buy stores, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy policy (unless the customer consents otherwise). Also, in the unlikely event that Inveniam or substantially all of its assets are acquired, customer information will be one of the transferred assets.

Protection of Inveniam and Others: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our policies and other agreements; or protect the rights, property, or safety of Inveniam, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With Your Consent: Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to elect not to share the information.

5. Data Retention and Security

We retain personal information for as long as it is reasonably necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, and for other legitimate business purposes. The precise periods for which we keep your personal information will vary depending on the nature of the information, the purpose for which it was collected, and our legal or business needs.

The criteria used to determine our retention periods include:

The length of time you have a relationship with us. We generally retain your information for the duration of our relationship with you (for example, as long as you maintain an account with us) and for a period thereafter as required for transitional purposes.
Compliance with our legal obligations. We are often required to retain certain information for specific periods to comply with applicable laws and regulations, such as tax, commercial, and financial reporting requirements. We would also retain information related to legal processes, such as litigation holds or to respond to lawful requests from public authorities.
Resolution of disputes and enforcement of our agreements. We will keep your information for the applicable statute of limitations period to resolve disputes, enforce our agreements, and defend our legal rights.
Legitimate business needs. We retain information as necessary for our legitimate business operations, such as for security purposes, fraud prevention, and to maintain the integrity of our services and business records.

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When we no longer have a legitimate business need to process your personal information, or when the retention period expires, we will either delete or anonymize it. If immediate deletion is not possible (for example, because your information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is feasible. We use secure methods to permanently and irrecoverably delete or irreversibly anonymize your data.

We employ administrative, technical, and physical security measures designed to protect your information from unauthorized access, use, or disclosure. We employ encryption to protect data in transit, using protocols like https with security certificates, and at rest. The encryption we use ensures that data is not exposed as plain text. However, any communications you send to us through unencrypted channels, such as email, may be transmitted in plain text and could be more vulnerable to interception.

Despite our efforts, we, like other service providers, cannot guarantee that our safeguards will be effective in every situation and that your information will remain 100% secure.

6. Your Privacy Rights and Choices

Inveniam recognizes that every user of our Website and services is entitled to:

Right to be Informed: The right to know how your personal data is being collected and used.
Right to Access: You have the right to request copies of your personal data and information about how we process it.
Right to Rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
Right to Erasure (Right to be Forgotten): You have the right to request that we erase your personal data, under certain conditions. For example, we may not be able to fulfill your request if we need to retain your information to comply with a legal obligation.
Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions, particularly where we are processing your information for direct marketing purposes.
Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.
Right Regarding Automated Decision-Making: You have the right not to be subject to a decision by Inveniam based solely on automated processing, including profiling, which may affect your legal rights or have other significant effects on you.

If you do not want to receive communications from us, you can adjust your customer communication preferences or opt out of distribution lists by using the “unsubscribe” link in any marketing emails we send you. If you do not want us to use personal information that we gather to allow third parties to personalize advertisements we display to you, please adjust your advertising preferences.

Privacy Rights in Certain U.S. States and Localities

Residents of certain states, such as California and Virginia, have specific rights regarding their personal information. Inveniam honors these rights for all our users and attempts to comply with the requirements of our customer’s local regulations whenever possible.

California Residents

California Consumer Privacy Act (CCPA) (Cal. Civ. Code §1798.100 et seq.)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.

• Right to Delete: You have the right to request the deletion of your personal information.

• Right to Correct: You have the right to request the correction of inaccurate personal information.

• Right to Opt-Out of Sale or Sharing: You have the right to direct us not to sell or share your personal information. Click here to manage your preferences: Do Not Sell or Share My Personal Information.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

California's "Shine the Light" law (Cal. Civ. Code §1798.83 et seq.)

The Shine the Light Law permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information in Section 10 of this Privacy Policy.

Virginia Residents

Virginia Consumer Data Protection Act (VCDPA) (Va. Code Ann. § 59.1-575 et seq.)

If you are a Virginia resident, you have the following rights under the Virginia Consumer Data Protection Act (VCDPA):

To confirm whether or not we are processing your personal data and to access such personal data.
To correct inaccuracies in your personal data.
To delete personal data provided by or obtained about you.
To obtain a copy of your personal data in a portable format.
To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

7. Children's Privacy

Our Services are not advertised to or intended to be used by anyone under the age of 13. We do not authorize the use of any of our Services by anyone under the age of 13. We do not knowingly collect, solicit or use any personally identifiable information from anyone under the age of 13 and we do not knowingly provide any personally identifiable information, regardless of its source, to any third party for any purpose whatsoever from anyone younger than 13 years old.

Parents who become aware of any unauthorized use of our Services by a child of theirs should contact our Data Protection & Privacy Officer using the contact information in Section 10 of this Privacy Policy to review such information, instruct the deletion of such information and prevent the continued collection of such information. If a parent or any other source makes us aware that we have inadvertently collected information from someone under the age of 13, we will take steps to promptly delete such information permanently.

If we ever change our business practices or policies in a way that affects anyone under the age of 13 and their data, we would implement verifiable parental consent safeguards (e.g., obtaining a signed consent form, verifying a government ID, or using a payment method verification) and would implement technologies to protect the information collected using industry standards and best practices that are consistent with our various data protection and cybersecurity certifications.

The contact information provided in Section 10 includes the name, address, email address, and telephone number of the operator collecting or maintaining any inadvertently collected children's information.

8. International Data Transfers

Inveniam is headquartered in the United States, and we may transfer your information to service providers located in other countries. When we transfer information from within the European Economic Area (EEA) to countries that have not been deemed to provide an adequate level of data protection, we rely on safeguards that we believe are appropriate, such as the Standard Contractual Clauses that have been approved by the European Commission.

9. Information for Subscribers and Customers

Subscribers and Customers may have certain rights or additional rights to those described in this Privacy Policy. Please refer to any business contracts you have with us, or addenda to such contracts.

10. How to Exercise Your Rights & Contact Us

If you choose to visit our Website or use our Services, then your visit and any dispute over privacy is subject to this Privacy Policy and other posted terms of use, which may include limitations on damages, provisions regarding the resolution of disputes, and explaining the application of the law to the Servies we provide. If you have any concern about privacy while using our Services of the privacy of a child of yours under the age of 13, please contact us with a complete description using the following contact information:

Email to legal@inveniam.io and include in the subject line: “Data Protection & Privacy Officer” to route your email to our supervisory Data Protection & Privacy Officer who can address your concern.

Phone: +1 (212) 220-6681

Address:

Inveniam Capital Partners, Inc.

Attn: Data Protection & Privacy Officer

39500 High Pointe Blvd, Novi, MI 48375

Our business may change over time and our Privacy Policy is also expected to change over time to address changes in the law and its application to our business. We may email periodic reminders of our notices and conditions. If we make substantial material changes, we will inform you by email or by posting a prominently displayed notice on our website which we expect to do in advance of the change becoming effective whenever possible. We encourage you to check our website frequently to be informed of any changes in our Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We stand behind the promises we make. We will not materially change our policies and practices to make them less protective of your information we collected in the past without your consent.

You have the right to contact a regulatory authority regarding any concerns about our privacy practices that we have not been able to address to your satisfaction. You may contact your state's Attorney General or the U.S. Federal Trade Commission (FTC), whose contact information is provided below, or any other competent data protection or consumer protection authority in your jurisdiction. The FTC can be contacted at https://reportfraud.ftc.gov or +1 (877) 382-4357.