Privacy Policy
Last Updated and Effective Date: October 6, 2024
Please read this Privacy Policy ("Privacy Policy") carefully. It provides information about how Venture23 Inc. ("Venture23", "we", "us", and "our") collects, uses, shares, and otherwise processes personal information. If you have any questions, comments, or concerns please contact us using the methods provided in the "Contact Us" section of this Privacy Policy below.
By visiting, accessing, or using our Services (defined below), you acknowledge and agree that you have received and reviewed this Privacy Policy. From time to time, we may update this Privacy Policy as described in the Privacy section below.
Please also review the applicable Terms of Service, which also apply to the use of our Services. Terms that are defined in the Terms of Service have the same meaning in this Privacy Policy unless this Privacy Policy specifies differently.
1. Scope of This Privacy Policy
This Privacy Policy applies to personal information that Venture23 collects, uses, shares, and otherwise processes when you:
- Access or use our website available at Venture23.xyz, or any other website operated or made available by Venture23 where this Privacy Policy is posted, including but not limited to websites with the domain Venture23.xyz and verulink.com (collectively, the "Website");
- Access or use any of the Venture23 services or functionality we make available through the Website (collectively, the "Products"); or
- Communicate with us, such as by sending us an email or communication through our Services.
For purposes of this Privacy Policy, we refer to our Website, Products, and any other online service we provide that links to this Privacy Policy as the "Services."
This Privacy Policy applies to:
- Visitors to the Website and any individuals who communicate with or receive communications from Venture23; and
- Individuals who access or use any of the Services.
2. Personal Information We Collect and How
As used in this Privacy Policy, "personal information" means any information that identifies or could be used to identify an individual person. For example, personal information may include name, email address, and phone number. It also includes other non-public information that we associate with such identifying information. Personal information does not include aggregated or anonymized information. We understand that many of our users value the anonymity available within a blockchain-based environment. We strive to limit the information we collect to anonymous information, but we do collect and process some personal information to enable and provide the Services.
The personal information we collect and how we collect it depends on how you use the Services. We collect the following types of personal information, as described below.
(a) Information You Provide
We collect information, including personal information, that you provide directly to us when you access or use the Services or when you interact with us. We collect information that you provide to us in the following ways:
- Support requests, inquiries, feedback, surveys, questionnaires, research.
- Submissions through our Products.
- Interactions through social media and other third-party platforms.
- Attending Events.
- Marketing communications and newsletters.
- Sweepstakes or Contests.
- Business Development and Strategic Partnerships.
You may choose not to provide personal information directly to us or to not use the Services. However, some personal information is necessary so that we can provide you with the Services you have requested. Failure to provide this information may prevent us from providing you with access to our Services.
(b) Information We Collect Automatically
When you access or use the Services, we or our third-party agents or service providers automatically collect information about the device you use to access the Services and your activity when you use the Services. Depending on your activity, the information may include:
- Device and Usage Information
- Cookies and Other Tracking Technologies
(c) Information from Third Parties
In some instances, and depending on the Services you use or how you use the Services, we collect and process personal information we receive from third parties, which can include the following:
- Venture23's Service Providers
- Venture23's Partners
- Analytics and Marketing Providers
(d) Public Blockchain Information
If you use certain Products made available through the Services, we may collect certain public blockchain information that you make available to us, such as your wallet address and crypto-asset transaction information related to your wallet address.
(e) Sensitive Personal Information
Venture23 does not intentionally collect sensitive personal information (e.g., social security numbers, racial or ethnic information, health information, religious information).
3. How We Use Personal Information
We use the personal information we collect in the following ways:
- To provide and operate the Services;
- To respond to your inquiries and requests, or otherwise communicate with you, and to provide you with assistance related to the Services;
- To provide technical support for, secure, and protect the Services, including to detect and prevent fraud, abuse, or security risks, and to track outages and troubleshoot;
- To conduct analytics related to the Services, such as to understand how they are being used and where improvements may be needed;
- To improve user experience with the Services;
- To update, improve, and/or enhance the Services, and develop new features, functionality, and Services;
- To send you newsletters and promotional and marketing communications that may be of interest to you;
- To conduct and administer promotions, sweepstakes, or contests if you have chosen to participate, in accordance with the terms of the promotion;
- To better understand your personal preferences and to enable us to provide you with improved and personalized communications and services;
- To compile aggregate data, such as about traffic and interaction with or on the Services;
- To provide transactional updates about our Services;
- To enforce our Terms of Service, resolve disputes or otherwise to carry out our obligations and enforce our rights, and to protect our business interest and rights of third parties;
- To audit our compliance with legal and contractual requirements and internal policies;
- To comply with legal and contractual obligations and requirements, law enforcement requests, and legal process;
- For our business transfers;
- To keep you updated about changes to policies related to our Services (including this Privacy Policy); and
- For any other purpose with your consent.
We may combine any of the information that we collect from you with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. We will use this information for the purposes described in this Privacy Policy.
4. How We Share Personal Information
We transmit, share, grant access, make available and provide personal information to or with the following types of third parties.
(a) Other Users of the Services
If you post or share content through the Services (for example projects, comments), that information is public and will be shared with other users of the Services. Venture23 is not a controller of that information once it is shared. By default, most of this information is shared anonymously. To the extent your personal information is associated with any content you post or share, please be aware that other users of the Services will be able to view and have access to it.
(b) Service Providers
We share personal information with our third-party vendors, consultants, agents, contractors, and service providers that help us provide our Services or with any of the purposes described in this Privacy Policy. Depending on how you use the Services, the following categories of Service Providers may collect data on our behalf, receive, or access personal information:
- Hosting service providers,
- Analytics providers,
- Marketing partners,
- Providers of business operations and communication tools, such as email and messaging software providers,
- Customer support service providers,
- Other third-party service providers that help us provide features and functions for the Services, and
- Professional advisors, agents and service providers, such as auditors, lawyers, consultants, accountants and insurers.
(c) Venture23 Partners
From time to time, we may work with other businesses to sponsor or host conferences or webinars, market related services, promote joint ventures or other similar collaborations. We might share personal information, such as your name and email address, with our partners in these situations.
(d) Sweepstakes, Contests, and Other Promotional Activities
If you participate in a promotion, sweepstakes, or contest (collectively, "Promotion"), we may disclose your personal information to any third parties affiliated with the Promotion or to the public in connection with conducting and administering the Promotion. For example, we may share personal information to select a winner, provide a prize, as required by applicable law (such as publishing a list of winners), or as permitted by the applicable terms and conditions or official rules of the Promotion.
(e) Legal, Compliance and Regulatory Purposes
We may share personal information if we believe that it is necessary to:
- comply with a law, regulation, legal process, or legitimate governmental request;
- protect the safety or security of the Services, users of the Services, or any person;
- investigate, prevent, or take action regarding illegal or suspected illegal activities;
- prevent spam, abuse, fraud, or other malicious activity of actors using or accessing the Services; or
- protect our rights or property or the rights or property of those who use the Services.
Non-public information about our users will not be released to law enforcement except in response to an appropriate legal process such as a subpoena, court order, or other valid legal process that has been reviewed by Venture23. However, if we receive information that provides us with a good faith belief that there is an exigent emergency, we may provide information to law enforcement trying to prevent or mitigate the danger, to be determined on a case-by-case basis.
(f) Business Transfers
We may share personal information with third parties we choose to acquire or with buyers, successors, or others in connection with a merger, divestiture, restructuring, reorganization, financing due diligence, initial public offering, dissolution, or other sale or transfer of some or all of our assets or transition of service to another provider, whether as a going concern or as part of bankruptcy, receivership, liquidation or similar proceeding, as permitted by law and/or contract.
(g) With Your Consent
There may be situations where you are asked to consent to share personal information with third parties for additional reasons not included in this Privacy Policy.
5. Cookies and Tracking Technologies
As described above in this Privacy Policy, we collect and may permit third parties to collect information using cookies and other similar technologies.
(a) What Are Cookies?
Cookies are small data files that are placed on your device set by us or by third parties when you visit a website or other online service. In addition to cookies, we may use other technologies that are similar in function, such as pixel tags, also called web beacons or single-pixel tags/gifs, local or web storage, and embedded scripts.
(b) Types of Cookies
Cookies are often described by who created and placed them and how long they last. Types of Cookies generally include the following:
- Persistent Cookies and Session Cookies
- First-Party Cookies and Third-Party Cookies
(c) What Types of Information Do Cookies Collect?
Cookies collect different types of information depending on the type of Cookie and its purpose. Some examples of information that may be collected by Cookies when you use our Services include:
- The pages or features you visit within our Services;
- The buttons you click on our Services;
- The date and time you visit our Services;
- The amount of time you spend on our Services;
- The Internet Protocol ("IP") address used to connect your device to the internet;
- Your device (such as computer, mobile phone) and connection information such as your browser type and version and operating system.
(d) How Do We Use Cookies?
Venture23 uses Cookies for purposes such as providing content or features on our Services, helping us remember you and your preferences, and improving your user experience by making our Services more efficient and relevant to you. We, our service providers, and/or agents acting on our behalf, use the following persistent and session Cookies (which may be first-party or third-party Cookies) on our Services:
- Strictly Necessary Cookies: These Cookies are essential because they enable our Services to work properly, and they cannot be disabled. Without these Cookies, some of our Services cannot be provided. These Cookies do not gather information about you for advertising purposes.
- Functional Cookies: We use functional Cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. We do not use functional Cookies for online advertising.
- Performance or Analytics Cookies: These Cookies help us understand how our Services are being accessed, used, or are performing.
(e) How to Manage or Delete Cookies
You can exercise your preferences concerning Cookies served on our Services by taking the steps outlined below:
- Browser Settings
- First-Party Cookies
- Third-Party Cookies
- Preferences Tools
- Privacy plug-ins
- Google Analytics
- DAA
- NAI
- Web Beacons and Pixels
To learn more about how to manage Cookies and opt-out of Cookies being placed on your devices, please visit www.allaboutcookies.org.
6. "Do Not Track" Preferences
The Services do not monitor for or behave differently if your browser or device transmits a "Do Not Track" or similar message. For information about "Do Not Track" please visit All About DNT.
7. Third-Party Links
We may provide links to other websites or resources with which we do not have a contractual relationship and over which we do not have control ("External Websites"). We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies.
8. Third-Party Social Media Plugins
The Services may offer Social Media Platform sharing features and other integrated tools. If you are logged in to your account with the third party, the third party may be able to link information about your interactions with the Services to your account with them. Please refer to each third party's privacy policies to learn more about its data practices.
9. Children's Privacy
Our Services are not intended for use by anyone younger than the age of 18 or under the applicable legal age of the relevant country. We do not knowingly collect personal information from children younger than the age of 18 without the consent of a parent or legal guardian, as required under applicable law.
10. Your Choices
(a) Marketing Preferences
To stop receiving, or opt-out of, promotional email communications from Venture23, click on the "unsubscribe" link or follow the relevant opt-out instructions within the marketing communication.
(b) Third Party Analytics
Venture23 uses third-party analytics providers to provide us with information regarding the use of the Services. For more information about the tracking technologies that these third parties use and your options, please see the cookies section above.
11. How Long We Retain Personal Information
We retain personal information for the purposes stated in this Privacy Policy and as required under applicable law. To determine how long we keep personal information, we consider the amount, nature, and sensitivity of personal information, the reasons for which we collect and process the information, and applicable legal requirements.
12. How We Protect Personal Information
At Venture23, we take our responsibility to protect the security and privacy of personal information seriously. We have implemented what we believe to be reasonable and appropriate security measures designed to prevent personal information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way.
13. California "Shine the Light" Disclosure
The California "Shine the Light" law gives residents of California the right under certain circumstances to opt-out of the sharing of certain categories of personal information with third parties for their direct marketing purposes. We do not currently share personal information with third parties for their own direct marketing purposes.
14. Notice to Nevada Residents
Under Nevada law, Nevada consumers may opt out of the sale of covered personal information. Venture23 does not currently sell covered information of Nevada consumers as defined under applicable Nevada law.
15. International Data Transfers
The personal information that we collect or receive may be transferred to and processed in countries located outside of your country of residence. Whenever we transfer personal information internationally, we take steps to protect it as required under applicable law.
16. Notice to European and Non-U.S. Residents
This notice supplements the information provided in this Privacy Policy and applies only to individuals located in the EEA, UK, Switzerland, or another country with a comprehensive data protection law who are within the scope of this Privacy Policy.
(a) Legal Basis for Processing
Venture23 processes personal information where there is a legal ground to do so, as described below:
- Performance of a Contract
- Legitimate Interest
- Legal Obligation
- Consent
(b) Your Data Rights
Under the GDPR and relevant local data protection laws, you have certain rights regarding your personal data, including:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision-making and profiling
- Withdraw Consent
- File a complaint
(c) Exercising Your Rights
For each of the rights described above, and for any complaints you may have, please contact us. We respond to all requests we receive from individuals wishing to exercise their data rights in accordance with applicable data protection laws.
17. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the "Last Updated and Effective Date" at the top of this Privacy Policy and post a link to the updated Privacy Policy on our Website. Changes to this Privacy Policy are effective when they are posted. If we make any material changes, we will provide you with notice as required under applicable law.
18. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us: By email at contact@verulink.com.