Privacy Policy

Information you provide to us

Personal information you may provide to us includes:

• Contact data, such as your name, email address, mailing address, and phone number.
• Business data, such as your company name, job title, role, and business contact details.
• Account data, such as the username and password you set for an account on the Service, and your preferences.
• Company assessment information. If you participate in our company data opportunity assessment, we collect information about your company, your role and business contact details, the software tools your company uses, approximate record counts and data volumes, and descriptions of available business records. The assessment does not require the underlying records or personal information contained in them.
• Referral data. If you participate in our referral program, we collect information about the companies and people you refer or invite, your referral activity, and any contact lists or connection exports you choose to upload.
• Information from our browser extension. If you use our browser extension, we receive page content from the tools you choose to measure, such as text, links, buttons, and figures, which may include names, email addresses, messages, or other information visible in those tools; screenshots of those tabs when needed to read a figure; the account email shown in each tool; measurement results and supporting evidence; and information about how you use the extension. See Browser Extension and Tools below.
• Payment and tax data, such as bank account details, payment preferences, and tax information (including a taxpayer identification number on an IRS Form W-9 or W-8) needed to pay referral fees or commissions. Some of this information is collected directly by our payment providers.
• Communications data, based on our exchanges with you, including by email, phone, text, video call, chat, or social media. Where permitted by law and with any required notice or consent, we may record and transcribe calls and meetings with you.
• Marketing data, such as your preferences for receiving our marketing communications and your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data about others

Our referral features let you refer companies and invite other people to join the referral program. When you do, we collect the contact details you provide so we can contact them. Please do not refer someone or share their contact details with us unless you have their permission to do so.

Third-party sources

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government and business registries, public records, company websites, and publicly accessible professional and social media profiles.
• Data providers, such as business information services and contact enrichment providers.
• Referral partners and connectors who introduce you or your company to us.
• Business partners, such as prospective data licensing partners and event co-sponsors.
• Service providers that help us operate the Service or our business.

Automatic data collection

We and our service providers may automatically log information about you, your device, and your interaction with the Service and our communications, such as:

• Device data, such as your operating system, browser type, device type, IP address, unique identifiers, language settings, and general location (such as city or state) inferred from your IP address.
• Online activity data, such as pages you viewed, how long you spent on them, the website you visited before, navigation paths, and access times.
• Communication interaction data, such as whether you open or click our emails, which we may detect using pixel tags embedded in our messages.

Tracking technologies

Some of this automatic collection uses cookies, local storage, web beacons (pixel tags), and similar technologies. Third-party chat or analytics tools on the Service may also use these technologies to operate their features and help us understand how the Service is used.

When a company licenses its data to us under a data license agreement, the records it provides may include personal information about the company's employees, customers, contacts, or others, such as names, business contact details, job titles, and communications or activity records. We receive this information from the company, not directly from those individuals.

We may process this information to review, organize, de-identify, format, and package datasets, and we may license, sell, or otherwise make datasets available to Buyers, including for training, evaluating, and improving AI models, as permitted by the applicable data license agreement and applicable law. Once data has been used to train a model, it may not be possible to remove it.

The company that licenses its data to us is responsible for providing any notices and obtaining any consents required to share that data with us. If you believe your personal information is contained in a dataset we received and you want to make a request about it, contact us at [email protected] and include the name of the company involved, if you know it. We will respond as required by applicable law, which may include working with the company that provided the data.

Our browser extension and related tools (the "Tools") help you measure how much data your company keeps in its software tools. You choose the tools, and the extension opens them in tabs in your own browser, using the accounts you are already signed into. It acts only when you start a measurement.

• What it reads. To find each data-volume figure, the extension reads page content in the tabs it opens, such as text, links, buttons, and figures, and may take screenshots of those tabs. This content can include names, email addresses, messages, or other information visible in your tools. It also reads the account email shown in each tool to confirm you are signed into your company's account.
• Where it goes. The extension sends that content to our servers and to our AI and other service providers, which help decide where to click and help read the figures. This can happen before you choose to save a result.
• What we save. When you save results, we store the measurements, supporting evidence, the scope of each reading, and the account that approved it with your company's Ventra account.
• Downloads. If you choose to download data from your tools, either manually or automatically, the files are saved on your own device.
• What it doesn't do. The extension does not collect your passwords for the tools you measure or export their session cookies.
• How we use it. We use information from the extension to provide and improve its measurement features, evaluate potential data licensing opportunities, communicate with you about them, and secure the service.
• Your choices. You choose which tools and accounts to measure, can stop a run at any time, can revoke the extension's site access in your browser settings, and can uninstall the extension. Uninstalling does not delete measurements already saved to your company's account. To request access to or deletion of saved information, contact us.
• More detail. Our Extension Privacy Notice explains in more detail how the extension works.
• Chrome Web Store. The use of information received through our Chrome extension will adhere to the Chrome Web Store User Data Policy, including the Limited Use requirements.

We may use your personal information for the following purposes or as otherwise described at the time of collection.

Service delivery and operations

• provide, operate, secure, and improve the Service;
• create and maintain your account;
• evaluate potential data licensing opportunities, assess prospective partner interest, communicate with company representatives, and administer introductions and transactions;
• administer the referral program, including tracking referrals and sub-partner invitations, calculating referral fees, and paying you;
• communicate with you about the Service, including service announcements, security alerts, and support messages;
• respond to your requests, questions, and feedback; and
• prevent fraud and protect the security of the Service.

We do not use company assessment information to train AI models. Any later collection of a company's underlying records requires a separate agreement with that company.

Payments and tax compliance

We use payment and tax data to pay referral fees and commissions, verify identity and eligibility, and meet tax reporting obligations, such as issuing IRS Forms 1099.

Research and development

We may use personal information to analyze and improve the Service. We may also create aggregated, de-identified, or anonymized data and use and share it for any lawful business purpose. We will not attempt to re-identify de-identified data, except to test whether our de-identification processes comply with applicable law.

Marketing

We may send you marketing communications about Ventra and the referral program and may personalize them based on your interests. You can opt out at any time as described below.

Compliance and protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as subpoenas, court orders, and requests from government authorities;
• protect our, your, or others' rights, privacy, safety, or property, including by making and defending legal claims;
• audit our internal processes for compliance with legal and contractual requirements;
• enforce the terms that govern the Service, including our Terms of Service and Referral Program Terms; and
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, or illegal activity.

With your consent

In some cases, we may ask for your consent to collect, use, or share your personal information for other purposes.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

• Buyers of licensed data. When a company licenses its data to us, we may license, sell, or otherwise make that data, including any personal information it contains, available to Buyers for training, evaluating, and improving AI models and for other purposes permitted by the applicable data license agreement.
• Prospective data partners and buyers. If you submit a company data assessment or your company is referred to us, we may share relevant company information, representative names and business contact details, and assessment details with prospective data licensing and distribution partners, AI developers, and research organizations to evaluate potential opportunities. We require these recipients to protect confidential assessment information and limit their use to evaluating the opportunity. Ventra may receive compensation if an introduction results in a transaction.
• Affiliates. Our affiliates, which may operate parts of the Service and our Tools on our behalf.
• Referral partners. If you were referred to us, we may tell the referral partner who referred you, and any partner who invited them, about the status of the referral, such as whether it resulted in a transaction.
• Service providers. Third parties that provide services on our behalf, such as hosting, information technology, customer relationship management, communications, email and text delivery, call recording and transcription, data enrichment, analytics, and customer support.
• Payment and tax providers. Payment processors and tax compliance providers that help us pay you and meet tax obligations, which may use your information under their own privacy policies.
• Artificial intelligence platforms. Third-party AI providers that power certain features of the Service.
• Professional advisors, such as lawyers, accountants, auditors, bankers, and insurers.
• Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith is necessary for the compliance and protection purposes described above.
• Corporate transactions. Parties to an actual or prospective investment, financing, sale, merger, reorganization, or similar transaction involving our business, and any acquirer, successor, or assignee.
• Third parties you designate. Other parties when you direct us or consent to the sharing.

SMS and text messaging

Mobile phone numbers collected for text messaging, and consent to receive text messages, are not shared or sold to third parties or affiliates for their marketing purposes. We use mobile numbers only to communicate with you about your inquiry, referrals, or transaction. Message frequency varies. Message and data rates may apply. Reply STOP to opt out at any time. Reply HELP for assistance.

• Access or update your information. If you have an account, you may review and update certain account information in your account settings.
• Opt out of marketing. You may opt out of marketing emails by using the unsubscribe link in any email or by contacting us. You may continue to receive service and transaction messages, such as referral and payment updates.
• Cookies. Most browsers let you remove or reject cookies. If you disable cookies, the Service may not work properly.
• Blocking images. Most browsers and devices let you prevent images from loading, which stops pixel tags from detecting that you opened an email.
• Do Not Track and Global Privacy Control. We do not currently respond to browser "Do Not Track" signals. Where required by law, we honor legally recognized browser-based opt-out preference signals, such as Global Privacy Control.
• Declining to provide information. If you do not provide information we require, we may not be able to provide certain services, such as paying referral fees.

Depending on where you live, you may have rights under state privacy laws, such as the Texas Data Privacy and Security Act, including the right to confirm whether we process your personal information, to access, correct, or delete it, to obtain a copy in a portable format, and to opt out of targeted advertising, the sale of your personal information, or certain profiling. To exercise these rights, contact us at [email protected]. We may need to verify your identity before responding. You may use an authorized agent where the law allows. We will not discriminate against you for exercising your rights.

If we decline your request, you may appeal by emailing [email protected] with the subject line "Privacy Request Appeal." We will respond to your appeal within the time the law requires. If you are not satisfied with our response to an appeal, you may contact your state attorney general.

Some state privacy laws do not apply to information collected about individuals acting in a business or professional capacity, and we may rely on those exceptions where they apply. These rights also apply, as required by law, to personal information we receive in licensed company datasets.

We generally keep personal information for as long as needed to fulfill the purposes for which we collected it, including to administer transactions and referral payments, to satisfy legal, accounting, tax, and reporting requirements, to establish or defend legal claims, and to prevent fraud. To decide how long to keep information, we consider the nature and sensitivity of the information, the risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements.

The Service may link to websites and services operated by third parties. We do not control them and are not responsible for their practices. Please read their privacy policies.

We use technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no internet or information technology is completely secure, and we cannot guarantee the security of your information.

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other places where privacy laws may not be as protective as those where you live.

The Service is not intended for anyone under 18. If you believe we have collected personal information from a minor, please contact us and we will delete it as required by law.

We may update this Privacy Policy from time to time. We will post the updated version with a new "Last Updated" date and, for material changes, may notify you by email or through the Service.

Ventra Holdings LLC
539 W. Commerce St #2851, Dallas, TX 75208
[email protected]
Support page

Controller. Ventra Holdings LLC is the controller of the personal information covered by this Privacy Policy. See "How to Contact Us" above for our contact details.

Legal bases for processing. We process personal information on the following legal bases:

• Contractual necessity, where we need to perform a contract we have entered into or are about to enter into with you, such as the Referral Program Terms.
• Legitimate interests, where processing is necessary for our legitimate interests, such as evaluating data licensing opportunities, operating the referral program, and securing the Service, and your interests and fundamental rights do not override those interests.
• Compliance with law, where we need to comply with a legal or regulatory obligation, such as tax reporting.
• Consent, where we have your specific consent for the processing in question.

Sensitive personal information. Please do not provide sensitive personal information, such as information about racial or ethnic origin, political opinions, religion, health, sex life or sexual orientation, trade union membership, or criminal convictions, through the Service.

Automated decision-making. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

Your rights. Depending on where you live, you may have the right to access, correct, delete, restrict, or object to our processing of your personal information, to receive a portable copy of it, and to withdraw consent where we rely on it. To exercise these rights, contact us at [email protected]. We may need to verify your identity. If we decline a request, we will explain why, subject to legal restrictions.

Complaints. You may lodge a complaint with the data protection regulator where you live. For users in the European Economic Area, contact details for each regulator are available at https://edpb.europa.eu/about-edpb/board/members_en. For users in the United Kingdom, you can contact the Information Commissioner's Office at https://ico.org.uk/make-a-complaint/.

Data processing outside your country. We are a U.S.-based company, and many of our service providers are also based in the United States. If you use the Service, your personal information will be processed in the United States and may be transferred to other countries.