- Policy Introduction
- Policy Scope
- The Types of Information We Collect
- Our Legal Basis for Collecting Information
- The Specific Information We Collect
- How We Use Your Personal Information
- How We Protect Your Personal Information
- How We May Share Your Personal Information
- How Long We Keep Your Personal Information
- Your Rights and Choices Regarding How We Use Your Personal Information
- Other Important Privacy Information
- Contact Us
Last Updated: 09/26/19
We have always worked hard to keep our customers’ personal information private and protected. We use proven, up-to-date security systems, methods and business practices to secure data — both in transit and in storage. We do not sell, rent, share, or otherwise knowingly disclose your personal information to anyone except as necessary to provide the business services that we offer or as otherwise described in this Policy. If you ever have any questions or concerns about your relationship with us, please do not hesitate to contact us directly at [email protected] or by calling 1-800-968-0104.
This Policy applies to:
- Your use of our web sites (currently Slipxsolutions.com & Targard.com).
- All product purchases made via our web sites.
- Our actions in support of purchases you make of SlipX Solutions or TarGard products on any 3rd Party Online Marketplace (such as Amazon.com, eBay.com, Walmart.com or any of Amazon.com’s international marketplace sites) with which we partner.
Please note that this Policy does not cover or apply to actions taken directly by 3rd Party Online Marketplaces. We only partner with 3rd Party Services that share our respect for your privacy, but we cannot assume responsibility for our partners’ practices, methods, or privacy policies. We encourage you to carefully review the privacy policies of any 3rd Party Online Marketplace that you access so that you know exactly how they collect, use, and protect your information.
Venturi collects two basic types of information about individuals during our normal business operations — Non-Attributable Information and Personally Identifiable Information:
- Non-Attributable Information is data related to topics like web site behavior, browser types, product sales trends, and so on that cannot be associated with any individual site visitor or customer. We use this information to analyze overall trends and behavioral patterns across groups of visitors/shoppers/customers, in order to improve our customer experiences and our customer service.
- Personally Identifiable Information (“PII”) is information that relates directly to a natural person — For example, personal descriptors such as Name, E-mail Address, Phone Number, Account Number, or other factors specific to that natural person.
Specific legal regulations —including the European Union’s General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”) — govern the collection, processing, storage, and protection of PII. This Policy describes Venturi’s ongoing efforts to adhere to those rules and — more generally — to protect the valuable PII of all of our customers, regardless of where they live or conduct business with us.
Our legal basis for collecting and using your PII depends on the specific information we collect and the specific context in which we collect it.
When You Voluntarily Consent to Share Information
In many cases, we collect PII from you when you voluntarily consent to share it with us, by:
- Providing us with information via a web form
- Registering for — or updating — an online account with us
- Signing up for one of our e-mail newsletters
- Otherwise corresponding with us
Wherever we rely on your voluntary consent in order to capture and/or process PII, you have the right to decline or withdraw that consent at any time.
When You Purchase Products from Us
Whenever you purchase a product from us via one of our web sites, you enter into a contractual agreement with us in which we agree to supply you with product in exchange for payment. In such cases, we collect specific elements of PII (*described later in this Policy) in order to satisfy that contractual agreement, by fulfilling your order, delivering your purchases, and providing exceptional customer care after the fact.
Information We Collect When You Visit Our Websites
In an ongoing effort to improve the shopping experience on our web sites, we collect certain Non-Attributable Information about each site visitor, including things like the date and time you visited, the type of browser you used, the web pages you viewed on our site(s), the web page you visited just prior to navigating to our Services, your IP address, and so on. We do not associate this information with individuals in any persistent manner.
Information We Collect When You Submit a Web Form
You may voluntarily choose to provide us with certain PII through any one of our web forms. Example forms include:
- Customer Service “Contact Us” Form
- Product Return or Exchange Form
- Product Replacement Request Form
- B2B Wholesale Account Form
The type of PII we typically request and collect via web forms includes Name, E-mail Address, Order # (when applicable) and Phone Number. We also may ask you to submit similar PII if you choose to interact with us by posting a product review on our web site(s), participating in a customer survey, or signing up for a contest or other promotion.
PII provided to us via web forms is given voluntarily; by submitting it you give us consent to process and store that information as necessary in order to answer your questions and/or respond to your requests. You may rescind that consent at any time by contacting us at [email protected]turi-inc.com or 1-800-968-0104 and requesting that we delete any PII data provided via a Venturi-managed web form.
Information We Collect When You Create or Update an Online Account with Us
Site users often choose to set up convenient Online Accounts with us, so that they can store profile information, save check out details for faster purchases, and/or easily reference past orders. To sign up for an Online Account, you voluntarily supply us with certain PII, and consent to Venturi’s capture, processing, and storage of that personal information. You may edit PII stored within your Online Account at any time, using the online My Account interface to make changes. You may also contact us directly at [email protected] and request that we make changes/deletions on your behalf. The PII typically shared and stored within a Venturi Online Account includes:
- Mailing and shipping addresses
- Email addresses
- Telephone numbers
Please note that while it is possible to enter Credit Card reference information for safe storage within one of our Online Accounts, Venturi does NOT store any full credit card number details within our systems. Instead, we partner with an experienced, proven 3rd party payment expert to keep your payment details safe and secure on Visa data center servers.
Information We Collect When You Sign Up for Our E-mail Newsletter Services
In order to sign up for one of our free online newsletter services, you must voluntarily provide a small amount of PII in order to facilitate the delivery of newsletter content. This PII is typically limited to:
- E-mail Address
This information you voluntarily provide — and thereby consent for us to use – will be used solely for the purpose of providing you digital newsletter content. E-mail information used to sign up for these services will never be rented, traded, sold or otherwise provided to a 3rd party without your permission.
PII We Collect When You Otherwise Communicate with Us
We do everything we can to provide exceptional customer service. If you contact us by phone, text message, email, live chat, social media, or some other means, we may keep a record of your contact information and the content of the communication for later reference. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our service levels.
PII We Collect When You Purchase from Our Websites
When you purchase products from Targard.com, Slipxsolutions.com or any other web site owned and controlled by Venturi, you enter into a contractual agreement with us whereby we agree to supply you with certain goods and services in exchange for certain information, including payment details. In order to process your order and deliver your purchase, we collect the following PII elements:
- Bill-To Address
- Ship-To Address
- Payment Information
- Please note that our payment processor, which is required by credit card issuers to meet specific, stringent security requirements, collects, stores and processes your credit card and other payment information on our behalf, using industry-standard security measures. Venturi does not retain or store any complete payment card information.
- E-mail Address (*in order to communicate with you regarding your order and related customer care issues like refunds or exchanges)
- Phone Number
PII We Process When You Purchase from 3rd Party Marketplaces
When you purchase SlipX Solutions or TarGard products on a non-Venturi Online Marketplace (such as Amazon.com or eBay.com), Venturi often participates in the processing and fulfillment of your order. When we do, we act as a Data Processor for the Online Marketplace, receiving from them only the PII necessary to fulfill, deliver, and track your order. We treat this PII in the same safe, secure manner that we treat PII associated with orders collected on our own web sites. For more details on individual Online Marketplaces collect, handle and protect your personal information, please refer to their posted Privacy Policies.
Other PII We May Collect
We use the Non-Attributable Information and PII that you share with us in order to:
- Provide and improve our web site shopping experiences
- Contact you about your orders or your online account(s)
- Provide you with offer information that you have voluntarily requested
- Provide you with the best possible customer service
- Detect, prevent, mitigate and/or investigate fraudulent or illegal activities
When you purchase products from us — either directly or through a 3rd party Online Marketplace — we use PII to in order to fulfill our contract with you, by:
- Providing payment processing services
- Preparing and shipping your orders
- Providing order-related communications such as order confirmations, receipts, and/or tracking information.
- Addressing any purchase-related customer requests that arise
Please note: We are based in the United States and the information we collect is governed by United States law. By accessing or using our web sites and services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States of America and other jurisdictions in which we operate.
We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption where logical and helpful. If you have any questions about the security of your personal information or the methods we use to protect it, please contact us with your specific questions at [email protected].
Sharing with Service Providers
In order to provide retail/commerce services to our customers, we may provide PII to certain contractors, agents, and service providers as necessary to enable them to perform certain services for us, including but not limited to:
- Payment processing
- Delivery services
- Web experience improvement
- Fraud monitoring
- Data security and analytics
- Law enforcement (as legally required)
These Service Providers may only process PII from Venturi pursuant to our instructions and in compliance both with this Policy and other applicable confidentiality and legal security regulations. In all cases, we attempt to minimize the amount of PII we disclose to what is directly relevant and necessary to accomplish each specified purpose above.
Sharing with Your Consent
We may choose to share PII in specific ways after having secured your voluntary consent to do so.
Sharing We Do Not Allow
We do not sell, rent, or otherwise knowingly disclose your PII to third parties for their marketing purposes without your prior consent.
In the Event of a Change in Ownership
If Venturi is subject to a merger or acquisition with/by another company, or undertakes corporate business transaction such as a joint venture, corporate reorganization, insolvency or bankruptcy, we may share PII with other parties involved in the transaction, in accordance with our established privacy standards. Should such an event occur, we will require that the new entity follow this Policy with respect to safeguarding your PII.
If we intend to process your PII for any purpose not specifically covered in this Policy, you will receive notification from us regarding the processing, along with information about how you may opt out.
We retain PII for as long as necessary to provide essential services such as executing customer orders, providing immediate and longer-term customer services, resolving disputes, and complying with financial and/or legal obligations.
How long we retain PII can vary significantly based on context and our legal obligations. The following factors typically influence our retention periods:
- How long is the PII required in order to provide basic services? This includes such things as maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most of our data retention periods.
- Is the personal information sensitive? If so, a shortened retention time is generally appropriate.
- Have you provided consent for a longer retention period? If so, we will retain data in accordance with your consent.
- Are we subject to a legal, contractual, or similar obligation to retain your personal information? Examples can include mandatory data retention laws in an applicable jurisdiction; government orders to preserve data relevant to an investigation; or personal information retained for the purposes of litigation.
We respect your right to access, correct, and/or request the deletion of the PII that we maintain about you as provided by applicable law.
You have the right to know what personal information we maintain about you. We will provide you with a copy of your PII in a structured, commonly used and machine-readable format upon receipt of a verifiable request. Our report to you will include:
- The categories of PII that we have collected about you.
- The sources from which the PII has been collected.
- The business purpose(s) for which we have collected the PII.
- Any third parties with whom we have shared your PII, and why we have shared it.
- The specific pieces of PII we have collected.
If your PII is incorrect or incomplete, you have the right to ask us to update it.
You have the right to object to our processing of your PII. Please note that your objection could limit our ability to provide you with specific services that you have requested from us.
You also have the right to ask us to delete or restrict how we use your personal information, but this right is determined by applicable law. Such a request may also impact our ability to provide some services to you.
In order to access, correct, update, export, or delete your personal information, you may email us at [email protected] with a detailed, verifiable Subject Access Request (“SAR”), and we will respond within thirty (30) calendar days. You may also contact us by phone (800-968-0104) or physical mail, using the contact information found at the end of this Policy.
What is a Verifiable Subject Access Request?
In order for Venturi to act on your SAR, we will need to first verify that you, as requestor, are inquiring about your own PII. This process will involve us asking you for a limited amount of information that only you would know. This information will be used only to verify your identity, and will not be stored or otherwise associated with you in our records after your SAR request has been prepared.
Where a SAR may implicate the personal data of another individual in addition to you, we must balance your request against the risk of violating another person’s privacy rights. We will comply with all SARs to the extent required by applicable law. If you are a citizen of the EU, you also have the right to lodge a complaint with a recognized Supervisory Authority.
Options for Accessing and Correcting Your PII
Venturi customers have the ability self-manage any information that they have voluntarily stored in their Online Accounts at any time, simply by logging in and accessing their My Account page. To remove an Online Account completely, please e-mail us at [email protected].
Subscribers to any of Venturi’s e-mail newsletters may unsubscribe at any time by following the Unsubscribe link contained within every newsletter. Unsubscribing will result in the deletion of your e-mail address from our newsletter service records, preventing all future mailings.
You may request that Venturi summarize, correct, collect and/or delete any other PII about you in our systems by sending a detailed request to [email protected]. We will do everything we can to accommodate your request in a timely manner. Please note, however, that where you have a statutory right to request access or request the modification or erasure of your personal information, we may still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws.
Our websites are general audience websites and not intended for children. We do not knowingly collect PII of any kind from children under the age of 13, in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you have questions concerning our information practices with respect to children, or if you believe a child under the age of 13 has provided us with PII, please email us at [email protected].
Attention — Privacy Officer
2299 Traversefield Drive
Traverse City, MI 49686
United States of America