Privacy Policy

Your privacy is critically important to us. At Venelabs Inc., we have a few fundamental principles:

• We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We aim to make it as simple as possible for you to control what information is shared publicly (or kept private), indexed by search engines, and permanently deleted.
• We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

Venelabs Inc. is the company behind the Funvene app. Our mission is to allow people to enjoy social, collaborative entertainment together.

This Privacy Policy applies to information that we collect about you when you use:

• Our mobile applications (including the Funvene mobile app for Android and iOS);
• Our websites (including funvene.com and venelabs.com)

This Privacy Policy also applies to information we collect when you apply for a job at Venelabs Inc.

Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products and services collectively as “Services.”

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Creative Commons Sharealike License

This Privacy Policy is available under a Creative Commons Sharealike license. It was adapted from the Privacy Policy of Automaticc. You can grab a copy of their original Privacy Policy at GitHub.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.

We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:

• Basic account information: We ask for basic information from you in order to set up your account. For example, we ask individuals who sign up for a user name and full name.
• Public profile information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a Funvene account, your username is part of that public profile, along with any other information you put into your public profile, like a photo or an “About Me” description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
• Payment and contact information: If you buy something from us we’ll collect the necessary information to process those payments and contact you.
• Communications with us (hi there!): You may also provide us with information when you respond to surveys, communicate with our Engineers about a support question, post a question in our public forums, or sign up for a newsletter. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
• Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
• Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that users perform on the app such as Funvene. In other words, who did what and when (e.g., [funvene user] started game “[name of game]” at [time/date]). We also collect information about what happens when you use our Services (e.g., page views,  features enabled for your website, interactions with other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
• Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
• Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions.
• Interactions with other users: We collect some information about your interactions with other users while you are logged in to your account with us, such as your “Invites” and the fact that you communicated with a particular user.

Information We Collect from Other Sources

Third-party services may give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). We use this information for marketing purposes.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, provide customer service, process payments and orders, and verify user information.
• To ensure quality, maintain safety, and improve our Services. For example, by monitoring and analyzing how users interact with our Services and each other, we can create new features that we think our users will enjoy.
• To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular subscription with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a subscription after receiving a marketing message), and understanding and forecasting user retention.
• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Venelabs Inc. and others, which may result in us, for example, declining a transaction or terminating Services.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, verify your payment; or share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
• To recruit and hire. For example, by evaluating job applicants and communicating with them.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our app on your device or charge you for a paid plan; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

(5) You have given us your consent.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below:

• Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes vendors that help us provide our Services to you (like payment providers, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations. We require vendors to have at least as strong privacy policies in order to share information with them.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Venelabs Inc., third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Venelabs Inc. goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so, like when you share information to a social media service through our app share features.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
• Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

We have a policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.

We may show ads on our sites or apps, and the revenue they generate lets us offer access to some of our Services.

Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly.

That means information like your public profile, posts, other content that you make public on our app or website are all available to others.

For example, the photo that you upload to your Funvene profile, or a default image if you haven’t uploaded one, along with other public profile information, like username, displays alongside the comments, “Invites” and “Likes” that you make.

Please keep all of this in mind when deciding what you would like to share publicly.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

Security

While no online service is 100% secure, we work to protect information about you against unauthorized access, use, alteration, or destruction.

Children’s Privacy

Funvene is intended for adults. We do not intentionally collect personal information from children. Accounts belonging to children are subject to deletion.

Choices

You have several choices available when it comes to information about you:

• Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information.
• Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps.
• Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.

The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

• Identifiers (like your username, name, profile picture, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as a user on the Funvene app);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Inferences we make (such as likelihood of retention or attrition).

We collect personal information for the business and commercial purposes. And we share this information with the categories of third parties described in the “Sharing Information section”.

If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

• Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
• Request deletion of personal information we collect or maintain;
• Opt out of any sale of personal information; and
• Not receive discriminatory treatment for exercising your rights under the CCPA.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to “How to Reach Us” to, well, find out how to reach us.

When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Controllers and Responsible Companies

Venelabs Inc.’s Services are worldwide. Venelabs Inc. is the controller (or co-controller) of personal information, which means that it is the company responsible for processing the information.

Venelabs Inc.

600 Broadway Ste 200 #478

Albany, New York 12207

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the “Your Rights section” above, please contact us via email on support@venelabs.com.

Other Things You Should Know (Keep Reading!)

Transferring Information

Because Venelab Inc.’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the “How and Why We Use Information section” above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Privacy Policy Changes

Venelabs Inc. may change its Privacy Policy from time to time. Venelabs Inc. encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Change Log

• July 7 2020. Initial version.