Privacy Policy
VENICE, with its principal place of business in Dublin, Ireland, including its Founders and affiliates takes its responsibilities under applicable data protection law including the General Data Protection Regulation (EU) 2016/679 and implementing legislation ("Data Protection Law") very seriously.
The purpose of this notice is to inform you of the data relating to you that we may collect and use and the uses (including disclosures to third parties) we may make of your data, which includes the provision of business services, and sending you invitations to events, briefings, training programmes and master classes.
VENICE is the controller in respect of the data we collect and we take all reasonable steps to ensure the safety and privacy of all information and, where appropriate, enter into contracts with any third-party processors to protect the privacy of any personal data processed by us.
Sources of data
As well as collecting data directly from you or other professional service providers, in some cases your personal data has been supplemented by information obtained from publicly available sources such as LinkedIn and in some instances from your employer's website, for the purposes of confirming your current professional position. We will create some data internally (e.g. when we exchange correspondence with you). We will also collect additional personal data throughout the period you remain a client or you continue to interact / work with us.
What information do we collect
We collect personal data that you voluntarily provide to us, for example when you communicate with us via email, when you sign up for or ask us to send you briefings or other materials and when you sign up for an event. Such data may include:
- your name, job title and name of employer and any personal data you send to us to provide you with VENICE business services;
- your contact details, including your home address (where you have provided this to us), business address, email address and telephone number;
- records of invitations and briefings sent to you and of your attendance at VENICE events;
- special dietary requirements and the name of your spouse or partner (in limited circumstances);
- on occasions where public health concerns warrant it, and you are visiting our offices or attending an event hosted or organised by us, information about your exposure to particular diseases and viruses; and
- information relating to particular areas that may be of interest to you.
If we are in regular contact with you, we may collect more information about our relationship with you.
Purposes of processing and legal bases
- Your personal data is used by us and by third party service providers acting on our behalf for the following purposes:
- A.1 providing you with VENICE business services;
- A.2 for administration and billing purposes and for other purposes which are reasonably incidental to the services being provided;
- A.3 sending or providing you with access to information, and invitations to events and programmes;
- A.4 maintaining our list of contacts; and
- A.5 safeguarding the health and safety of our personnel, visitors to our offices and of attendees at events hosted or organised by us.
- The legal bases on which we collect, process and transfer your information in the manner described above are:
- (a) For A.1 and A.2
- (i) your consent (where we have sought it and you have provided it to us), and in which case, you can withdraw your consent at any time;
- (ii) where any such processing is necessary for the performance of a contract with us; and
- (iii) our legitimate interests in conducting our business in a responsible and commercially prudent manner.
- (b) For A.3 and A.4
- (i) Our legitimate interest in maintaining a business relationship and communicating with you, as a business contact, about our events and providing you with information about new developments.
- (c) For A5
- (i) your consent to our use of your health data for the purposes described above.
- We may process special categories of data, such as accommodating any special dietary requirements you may have for any events that you register to attend. Any use of such information is based on your consent.
Sharing your data
We may disclose your personal data to third party recipients acting on your or our behalf, for the purposes of providing VENICE services to you and for providing you with information which we believe you may be interested in. Our information technology systems are operated by VENICE, but some data processing is carried out on our behalf by a third party. Where processing of personal data is carried out by a third-party data processor on our behalf we endeavour to ensure that a data processing agreement is in place and that appropriate security measures are in place to prevent unauthorised disclosure of personal data.
Disclosure of personal data to a successor organisation or affiliate
We may transfer personal data to an affiliate, successor organisation, company or corporation which acquires the business carried on by VENICE or enters into a business relationship with VENICE. If this happens, we will require the affiliate, organisation, company or corporation to which we transfer personal data to observe standards of data protection and privacy no less secure than those set out in this Notice.
Save as described in this Notice, personal data will be retained by us and will not be sold, transferred or otherwise disclosed to any third party, unless such disclosure is required by law or court order.
Change of purpose
We will only use personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Transfers abroad
Where relevant and necessary for the VENICE’s business including providing services to you, we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include (i) entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or (ii) seeking and obtaining your explicit consent to the transfer or (iii) where the transfer is necessary for the establishment, exercise or defence of legal claims.
Retention
We will only retain personal data for as long as is it is reasonably necessary to provide you with VENICE services, including for the purposes of satisfying any legal, accounting, or reporting requirements. If you are a business contact, we will retain your personal data for as long as we consider you to be a business contact and we will give you the opportunity to unsubscribe if you no longer wish to receive communications and invitations from us.
Security measures to keep your personal data safe
We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We carry out risk assessments on all third-party service providers to make sure the personal data they hold is secure. We regularly review our security policies and procedures to ensure our systems are secure and protected.
Your rights
In certain circumstances, by law you have the right to:
▪ Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
▪ Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
▪ Request erasure of your personal data - provided that we are not required to retain the data for the performance of your employment contract or to comply with our legal obligations. Any deletion of personal data may impact on our ability to provide a reference for you.
▪ Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground.
▪ Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
▪ Request the transfer of your personal data to another party.
If you want to exercise any of the rights set out above, or wish to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact our data privacy team
patrick@venicefounders.com in writing. We will respond to your request as soon as possible and in any event within one month of receipt.
In circumstances where you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email
patrick@venicefounders.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We are required to keep all personal data accurate and up to date. To assist us in doing so, we ask you to contact your usual business contact at VENICE or email dataprotection@ VENICE .com with any relevant changes, such as change of address or contact telephone numbers.
Complaints
If you are not happy with the way we have used your information or addressed your rights, please contact us at
patrick@venicefounders.com. You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (
mailto:info@dataprotection.ie).
Unsubscribe
If you no longer wish to receive further marketing communications and/or invitations from us, you can unsubscribe at any time by emailing us at patrick@venicefounders.com.
Changes to this Notice
We may change this Notice from time to time and we will provide you with a new Notice where any substantial updates are made. The current version will always be available from us in hard copy or on our website.
Last updated: 6th June 2024.