1. Introduction

Venbrook Group, LLC and Companies is committed to protecting the privacy of Internet users who visit our website. This Policy is meant to tell you how we collect, use, share, and otherwise process personal information about you, and the rights and choices that may be available to you with respect to your personal information (namely, any information that may identify, relate to, describe, reference, is capable of being associated with, or could reasonably be linked to you or your device, directly or indirectly). We will also address some other privacy issues and tell you how you can contact us.

2. What Is The Scope Of This Policy?

This Privacy Policy explains how Venbrook Group, LLC and Companies (“we,’” “our,” “us,” “our company,” “our companies”) processes personal information when you interact with us such as through our website (“Services”). This Privacy Policy applies to our collection, use, and disclosure of personal information in the business-to-business context and from consumers, website visitors, potential job applicants, and any other individuals about whom we obtain personal information, unless we specifically state otherwise. Our privacy practices with respect to our employees and contractors are addressed through internal policies and are outside the scope of this Policy. We also recommend that you review the Terms of Use governing use of this website and its content.

Children’s Privacy
You must be 18 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 18 years of age.

3. How Does Venbrook Collect Personal Information?

From you. We may collect personal information and other information that you provide when you use our Services, obtain insurance from us, sign up for emails from us, contact us, post a comment on our blogs, solicit an insurance policy quote, submit employment applications, or otherwise use our Services.

From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies” section below.

From third parties and publicly available sources. This includes personal information we collect from other public sources, including, but not limited to, websites that enable social sharing, social media sites, and websites from our service providers, vendors, affiliates, or other individuals and businesses.

4. What Types of Personal Information Does Venbrook Collect From You?

Depending on how you interact with us, we may collect the following information:

• Personal Information You Give Us Directly:
  • Contact Information, such as your name, home address, email address, telephone number, or other similar identifiers.
  • Biographic and Demographic Information, such as date of birth, age, gender, and photo.
  • Financial and Payment Information, such as credit card details, bank account number, financial information, and payment preferences.
  • Account Information, such as username and password and profile details you choose to provide.
  • Other Personal Information you provide, such as Social Security Number, driver’s license number, and the content provided either in your job application or in your communications with us, including interactions with us online, in person, or on the phone.
  • Inferences, such as inferences drawn from any of the personal information identified.

• Personal Information Collected Automatically When You Visit Our Site:
  • Internet Usage Information, such as browsing history, search history, web-based location, IP address, and any other Internet usage information our Services may automatically record when you visit.
  • Device Information, such as browser or device model and settings, operating system, and unique identifiers.
  • Log Data, such as the use of cookies on the website and a service provider to store such log data on our behalf.
  • Inferences, such as inferences drawn from any of the personal information identified.

• Aggregate Information:
  • We collect aggregate personal information in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated information for our own legitimate business purposes, such as viewing website traffic and website user behaviors.

If we ask you to provide any other personal information not described above, we will endeavor to make clear to you what personal information you are asked to provide, and why, when you are asked to provide it.

5. How Does Venbrook Use Your Personal Information?

We may use your information for the following reasons, depending on your relationship with us:

• To communicate with you, such as when we respond to your inquiries and send you communications regarding our products and services.
• To serve you targeted advertising or content.
• To provide, market, and develop our products and services, including to maintain our websites, troubleshoot, develop quality assurance, provide customer and technical support, conduct data analysis, conduct marketing research, and better understand the interests of our clients and visitors who use our services and products.
• To carry out any obligations arising from any contracts entered into between you and Venbrook.
• To allow you to participate in interactive features of our Services.
• To provide quotes regarding insurance.
• To understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns).
• To maintain the safety, security, and integrity of our Services; for example, by authenticating users, monitoring for illegal activity, and providing account security and fraud detection.
• To secure and debug our online systems and services.
• To send you news and/or marketing communications (by email or phone) subject to your consent, marketing preferences, and/or choices, including information about us or third-party offerings we think may be of interest to you.
• To comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services. This would include the use of your information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigations.
• To conduct internal business, including data analysis, audits, and enhancing our services. We may also use inferences drawn from personal information to create a profile reflecting your preferences so we can tailor our services to you.
• To process and complete transactions, including collecting payment and contact information to process your transactions.
• To process your employment application, including verifying statements made on your application (e.g., credit and employment history) and performing background and credit checks.
• We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development.

6. How Does Venbrook Disclose Personal Information?

We may collect, use, retain, disclose, and store personal information collected from or about you with any of the following entities and for any of the following purposes:

• Venbrook Group of Companies. We may disclose personal information within the Venbrook group of companies.
• Service Providers and Advertising Partners. We may provide personal information to vendors, payment processors, contractors, business and service partners, or other third parties, such as advertising partners or other marketing partners who provide services to us, including analysis firms, advertisers, and others.

Insurance Companies and Intermediaries. We may provide personal information to insurance companies, payment processors, and intermediaries in the event you request a quote for issuance of an insurance policy or seek to purchase insurance through our Services.

• Government, Regulatory, or Law Enforcement Agencies. We reserve the right to disclose your information to respond to judicial requests and valid information requests from government authorities, to investigate potential fraud, and where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements, or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
• In Connection with a Merger, Acquisition, or Business Transfer. If we sell all or a part of our company, are part of a merger, consolidation, restructuring, and/or sale of assets or other corporate change, your information may be transferred as part of that transaction.
• At Your Direction. We may disclose your personal information at your direction or with your consent.
• Collaborators. We may share personal information with collaborators with whom we jointly develop or promote our services, including sponsorships and co-branded opportunities and promotions.
• The General Public. We may share personal information with the general public if you choose to share personal information when contributing content to our Services through forums, blogs, social features, or the like.
• Aggregate Data. We may disclose your personal information in an aggregated form or otherwise in a form that cannot reasonably be used to identify you.

7. Does This Privacy Policy Apply to Links to Third Party Websites?

We may provide links to websites and other third-party content that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy policies. We are not responsible for the privacy practices of these websites.

If you provide any personal information through a third-party site, your interaction and your personal information will be collected by and controlled by the privacy policy of that third-party site, not by this Privacy Policy. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.

8. What Are Personalized Ads?

When you use our Services, our third-party advertising partners, social media providers, and analytics providers may collect personal information about your online activity on our Services and on third-party websites.

These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third-party websites within their networks. If you would like more information about this practice, and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page or the Network Advertising Initiative’s opt-out page. Please note that you may continue to receive generic ads that are not based on your preferences.

9. How Is Your Information Secured?

We use commercially reasonable administrative, technical, and personnel measures designed to safeguard your personal information against loss, misuse or unauthorized access, disclosure, or modification. These safeguards include limiting access to data, storing personal information on servers and computers believed to be secure, using encryption, and having procedures for responding to a suspected breach of personal information. In addition, we maintain contractual data security and privacy obligations with our suppliers, and our employees are subject to confidentiality policies. However, no security controls are 100% effective, and the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet – when submitting personal information to us over the Internet, you do so at your own risk. If we believe the security of your personal information in our possession or control may have been compromised, we may seek to notify you by email, and you consent to our use of email as a means of such notification.

10. How Does Venbrook Use Cookies?

We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, web beacons, and similar tracking technologies (collectively, “cookies”). Some of these technologies store data in the browser or on your device. Other technologies use network-related information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a webpage: data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service, making your use of the website more convenient. You can find more information about cookies and how they work at www.allaboutcookies.org.

We and our partners may use cookies to gather personal information about how you view and use our Services and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.

Your web browser can be set to allow you to control cookies, such as whether you will accept or reject cookies or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising.

Do Not Track (DNT) is a privacy preference users can set if they do not want web services to collect information about their online activity. However, there is currently no universal standard for sending and receiving DNT signals. Due to this lack of universal standard, it would be impossible for us to promise that we comply with all known and unknown DNT standards. Therefore, we do not respond to DNT signals or other mechanisms that provide a choice regarding the collection of personally identifiable information about activities over time and across different websites or online services. If a universal standard for DNT becomes available, we will revisit our DNT Policy.

11. How Do You Select Your Marketing Preferences?

We may periodically send promotional materials or notifications related to our Services. If you do not wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email.

There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Services or policies.

12. How Do You Access, Correct, or Remove Your Personal Information?

If you would like to review your personal information, correct the personal information you have provided to us, and/or request that we remove your information from our records, contact Venbrook Compliance via the contact detail noted below with the access, correction, or removal request. Each request will be reviewed and responded to in accordance with applicable laws.

Additional Information for California Residents

California residents have certain rights with respect to their Personal Information, as described below. This section provides information for California residents in connection with the California Consumer Privacy Act (“CCPA”). Under the CCPA, and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident. Please note that we do not sell or share California residents’ Personal Information, as defined by California law.

What We Collected and Disclosed

We disclose (or have enabled you to disclose) and collect the following categories of Personal Information. These are the categories of Personal Information we have collected about you in the preceding 12 months:

Sensitive Personal Information. We do not process “sensitive” Personal Information for purposes other than those specified in the CCPA (such as to provide the Services and for security purposes).

Data Retention. We will retain your Personal Information for the length of time necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Purposes

We may use the Personal Information we collect for the following purposes, including commercial purposes, as described in more detail in the “How Does Venbrook Use Your Personal Information” section above:

• To operate, manage, and maintain our business.
• To provide our Services.
• To accomplish our business purposes and objectives, including:
  • Developing, improving, repairing, and maintaining our Services;
  • Advertising and marketing;
  • Conducting research, analytics, and data analysis;
  • Maintaining our facilities and infrastructure;
  • Quality and safety assurance measures;
  • Conducting risk and security controls and monitoring;
  • Detecting and preventing fraud;
  • Performing identity verification;
  • Performing accounting, audit, and other internal functions;
  • Complying with the law, legal process, and internal policies;
  • Maintaining records; and
  • Exercising and defending legal claims.

We collect Personal Information directly from California residents themselves and from our Service Providers, including from referrals, joint marketing, co-branding, co-promotional activities, and devices you use to interact with us. All sources of Personal Information collected are noted in the “How Does Venbrook Collect Personal Information” and “What Types of Personal Information Does Venbrook Collect From You” sections above.

Sources of Personal Information

We collect Personal Information directly from California residents themselves and from our Service Providers, including from referrals, joint marketing, co-branding, co-promotional activities, and devices you use to interact with us. All sources of Personal Information collected are noted in the “How Does Venbrook Collect Personal Information” and “What Types of Personal Information Does Venbrook Collect From You” sections above.

Additional California Privacy Rights

California residents have certain rights with respect to their Personal Information, as described below.
We are required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. This requires us to request from you two (2) pieces of Personal Information so that we may match the same with Personal Information maintained by Venbrook. Failure to verify your identity may result in your request not being processed. Where required by applicable law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request.

Right to Access Personal Information: You may request to access information we have collected and maintain about you; we will send you a copy of your data. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Right to Limit Use of Personal Information: You may request that we do not use ethnicity, financial, or identification information in analysis, and that we limit the use and disclosure of your sensitive Personal Information. You may request that we do not process your Personal Information (customer information, such as purchase history, or browser information, such as cookies) to inform any advertising.

Deletion of Personal Information: You may request that we delete all Personal Information we have collected from you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate Personal Information that we have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under the CCPA.

To Exercise Rights

In order to exercise your rights described above, please contact Compliance by completing our Privacy Request form.

 Authorized Agent

California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of a California resident, please contact us at the contact information below with supporting verification information, which includes proof that you have access to the consumer’s interface and proof of your own identify.

13: Shine the Light Disclosure

We do not disclose personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) with third parties, other than our affiliates, for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by completing the Privacy Request form or writing to the contact information below. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the Privacy Request form or mailing address referenced above.

14: Updates to the Policy

We may update this policy from time to time. Any changes to our privacy policy will be posted to the website and will become effective upon posting. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change. The provisions contained in this Policy supersede all previous policies regarding our privacy practices. You should periodically check this page to stay informed about our privacy practices.

15: Contact Information for Questions, Comments, and Requests

If you have any questions or concerns about data privacy, data security, or the handling of your Personal Information, or if you wish to make a request to access your Personal Information, please contact Venbrook Compliance by completing our Privacy Request form or by mail to Venbrook Companies, Attention: Compliance, 6320 Canoga Avenue, 12th Floor, Woodland Hills, CA 91367.