Privacy Policy

Last updated August 30, 2023

Welcome to https://vengreso.com and its associated websites and sub-domains (collectively, the “Website”), owned and operated by Vengreso, Inc., a Delaware corporation (the “Company” or “We”). This website privacy policy (this “Privacy Policy”) governs your use of the Website and describes the types of information we may collect from you and the Company’s practice for collecting, using, maintaining, protecting and disclosing that information. 

This Privacy Policy creates a binding legal agreement between you and the Company, and your access to the Website is subject to this Privacy Policy. By accessing or using the Website, you are accepting and agreeing to the terms of this Privacy Policy. 

The Company reserves the right to update and change this Privacy Policy. Your continued access and use of the Website after we make changes is deemed to be acceptance of those changes, therefore you are advised to check the Privacy Policy from time to time for any updates or changes.

1. Data Collected by the Company.

The types of personal data we collect about you depends on your particular interaction with our Website and our services. We obtain the categories of personal information listed below either directly from you (such as from forms you complete or products and services you purchase from the Company), or indirectly from you (such as from observing your actions on our Website).

  • Personal Identifiers and Information: A real name, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers; as well as signature, physical characteristics or description, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
  • Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other similar networking activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

2. Use of Your Information.

We use information that we collect from you or that you provide to the Company to:

  • To present our Website and its contents to you.
  • To provide you with information, products, support or services.
  • To create, maintain, customize and secure your account.
  • To process your requests, purchases, transactions, and payments. 
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email. 
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. 

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain types of information listed above. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). You have the ability to manually opt out of behavioral tracking on this Website through your browser. 

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
    • Click here to learn more about managing cookie settings in Mozilla Firefox;
    • Click here to learn more about managing cookie settings in Google Chrome;
    • Click here to learn more about managing cookie settings in Microsoft Internet Explorer;
    • Click here to learn more about managing cookie settings in Safari;
    • Click here to learn more about managing cookie settings in Microsoft Edge.
  • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Click here to learn more about Google API Services Disclosure.

3. Disclosure of Your Information.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. The Company has disclosed the following categories of personal information, as outlined in Section 1 of this Privacy Policy, for a business purpose: Identifiers, Commercial information, and internet or other similar network activity.

If you do not want us to use your personal data for us to market to you, and/or to pass on to third parties for marketing purposes, please use the Contact Us details at the end of this Privacy Policy. You will also be able to unsubscribe from any marketing emails sent to you by the Company using a link provided in such emails. We do not sell your personal data.

4. Your Rights and Choices.

You have certain rights relating to your personal data, subject to local data protection laws. Certain consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Depending on the applicable laws, these rights may include the right to:

  • Be informed
  • Access your personal data
  • Correct or rectify inaccuracies
  • Erase your personal data (‘be forgotten’)
  • Restrict our processing of your personal data
  • Obtain and reuse your personal data
  • Object to the processing of your personal data
  • Not to be subject to a decision based solely on automated processing, including profiling
  • Withdraw your consent
  • Right to report or complain

You may access, update and correct inaccuracies in your personal data in our custody or control at any time, subject to limited exceptions prescribed by law.   You can also request access, corrections or updates other personal data in our records by contacting us as set out below. We may request certain personal data for the purposes of verifying the identity of the individual seeking access to their personal data records. You may request your data be withdrawn (forgotten); this type of request can be performed assuming the Company is in a legal position to fulfill such a request. Should the Company be able to comply with your request, only the personal data you provided will be forgotten. Non-personal data will be maintained regardless.

Please note that these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it means that we are not able to meet our contractual obligations and provide our services to you. We will keep you informed as to the actions that we can take when you make your request.

We are not responsible for the privacy practices of our third-party service providers and recommend that you review their privacy policies carefully. We may communicate with our third-party service providers, to the extent permitted by law, when you make a request based on your personal data rights that involves the data collected by our third-party service providers. We will keep you informed on the status of your request in such cases.

Please use the Contact Us details at the end of this Privacy Policy to exercise your rights and choices under this Privacy Policy. 

5. Children’s Online Privacy Protection Act. 

We are committed to protecting the privacy of children.  The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet.  Our Website and services are not directed to children under the age of 18, nor is information knowingly collected from children under the age of 18.  No one under the age of 18 may access, browse, or use the Website or provide any information to or on the Website.  If you are under 18, please do not use or provide any information on the Website (including, for example, your name, telephone number, email address, and username).  If you believe we might have any information from or about a child under the age of 18, please contact us using the contact information provided below.

6. Data Security.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers. Any payment transactions will be processed using trusted third-party merchant platforms, whose terms regarding the processing payments are incorporated herein by reference. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

7. Proprietary Rights. 

All content on the Website, including but not limited to any intellectual property, text, graphics, images, audio, video, and data, is the property of the Company and shall remain the property of the Company. 

8. Sub-Processors.

The Company may engage “Sub-Processors” (third party service providers that process

personal data under the instruction or supervision of the Company) to process personal data on your behalf. You hereby authorize the Company to engage Sub-Processors listed at: https://vengreso.com/sub-processors (which may be updated from time to time). All Sub-Processors have either entered into written agreements with the Company that bind them by data protection obligations substantially similar to those herein, or contain their own terms which the Company has agreed to.

9. Contact Information.  

If you have any questions or comments about this Privacy Policy, the ways in which the Company collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Vengreso, Inc.

Attn: Legal

1547 Palos Verdes Mall, Suite 250

Walnut Creek, CA 94597

legal@vengreso.com

10. Specific terms for users from the state of California only. 

According to California Consumer Privacy Act (“CCPA“), businesses have to describe certain information and rights California residents have regarding their personal data. In this section we provide such information, this Notice applies only to California residents and does not substitute any part of our Privacy Policy.

What Information Do We Collect

This Privacy Policy provides a comprehensive list of information our software collects and how this data is used and shared.

Under the CCPA we are also providing additional information on that matter, including “categories” of personal information used for business and improving user experience purposes. Here is the list of these categories:

– identifiers – name, email address or account in the specific social network, profile data;

– business data – payment transactions information;

– financial information – payment method or connected financial accounts;

– network and device activity – IP addresses used to connect to the software, usage information;

– location – where your device you are using to access the Vengreso website, applications, and services is located;

– user inferential data;

– other information that may be used to identify the user or reasonable be associated with the user.

These categories of data may be used by us or our service providers due to the various business and commercial needs. All these topics are discussed in the corresponding sections of the Privacy Policy.

You should also understand that we may use the above-mentioned data categories of personal information to comply with laws and regulations applicable in different countries. Also, we may aggregate such information or de-identify it to prevent or limit the disclosure of any user or device data to other parties.

Rights And How to Exercise Them

As a California resident, you have certain rights. The local law allows you requesting us to:

– give you an access and/or a copy of a specific information we have regarding you and your account;

– provide a summary of the data categories of your personal information collected and processed by us or disclosed to third parties in the period of the last twelve months;

– the categories of the sources of this data;

– the reasons and business purposes under which such information is collected;

– the categories of third parties that this data made be shared with;
delete certain information we have about by your request.

Also, under the CCPA, you have a right to receive information about the financial incentives we may offer to you (if there are any). Moreover, California residents have the right not to be discriminated for exercising some of their rights. This means that if you will require us to delete certain information we collect to provide you with access to the Website, the Application and Services, you may lose an opportunity to access the Website, Application, and Services.

– If you want to send us a CCPA-related request (to get an information about your personal data we collect or request us to delete it) you may send a request via email to legal@vengreso.com.

– Remove your personal data by cancelling your account with Vengreso. To do so, you should log in to your account associated to one of the Vengreso products and click the delete profile link. If one is not available, you may send a request via email to legal@vengreso.com.

We may ask you to provide sufficient information to verify your identity prior to processing your request. You may also designate an authorized agent to make a request on your behalf. This agent will have to provide us with written authorization from you. In this case you will need to verify your identity directly with us anyway.

The CCPA lists a list of obligations for companies that “sell” personal information. However, according to the definition of “selling” implied by the law, Vengreso does not participate in such activity. Also, we did not participate in such activity in the last twelve months and have no plans to for doing so in the future.

However, we may share certain information about you and allow third parties to collect a specific information about you, for example through cookies. We thoroughly describe all such cases in corresponding sections of the Privacy Policy.

Sending Other Requests

As a California resident, you may send us a request to get a list of third parties who’ve received your information for marketing purposes during the previous calendar year. This list will also contain the types of information shared. Please contact us at:

Vengreso Inc.

Attn: Legal

1547 Palos Verdes Mall, Suite 250

Walnut Creek, CA 94597

11. Specific terms for United Kingdom and European Economic Area.  

Persons located in the European Economic Area (EEA), United Kingdom, and Switzerland have certain rights with respect to their Personal Information, including the right to access, correct or delete Personal Data that we process through your use of the Website, Application, and/or Services.

If you are a user based in the EEA or Switzerland you can:

Send requests concerning your personal information. To do so, you can submit a request to legal@vengreso.com. The report will include your personal data we have, formatted and displayed in a human-readable way. Prior to processing your request, we will ask you for additional information to verify your identity.

– Correct or delete your personal data. You can update your personal information, including name, email address, and payment details through your Vengreso account settings. If you have any issues updating this data, send us an email to legal@vengreso.com.

– Manage our processing of your personal information. We send any communications to EEA users only with their consent. You may ask us to stop sending you promotional materials by clicking Unsubscribe button within the Vengreso email letters. Also, you can manage your email preferences and decide what type of communication you would like to receive. Still, you will receive some transactional emails regarding our Services.

– File a regulatory complaint. Users based in the EEA who believe that we have not complied with the current data protection regulation and laws, have the right to file a complaint to their local regulatory organization.

If you have other questions or do not have a Vengreso account yet, contact us via email: legal@vengreso.com.