Return To Venice, LLC Privacy Policy

Last Updated: January 8, 2021

This Privacy Policy (“Policy”) describes how Return to Venice, LLC (“RTV”) and their subsidiary and affiliated companies that are incorporated in the United States of America only (collectively, “we,” “us,” or “our”) collect, use, and otherwise process personal information about our customers and users of our websites and services. RTV is a New York corporation and whose main office is located at 28 Shore Road, Douglaston, New York, 11363.

1. Who We Are

RTV is an online education service providers that produce and deliver high-quality digital content for K-12 education and beyond, including streaming media, and other rich content. The services we offer enable teachers and students to participate in enhanced learning experiences. Depending on the context of the personal data you or your school provides, we may be the data “controller” or “business”, or “processor” or “service provider” of your personal data under applicable data protection laws. We are a “processor” or “service provider” of our customer data, personal data submitted to the Services or collected through the Services on behalf of or at the direction of the subscriber (the schools or school districts who are the “controllers” of the personal data), and personal data we receive or collect from the subscriber. When we are acting as a “processor” or “service provider”, we will only process the personal data on behalf of and subject to the terms of its contract with the subscriber, to the extent such contract exists, unless otherwise required by law. If you have questions about our processing of your personal data on behalf of a subscriber, please refer to the subscriber’s privacy policy.

2. Scope

We respect the privacy of our customers and visitors of our websites (identified below); users of our online subscription services and digital lessons; participants of our surveys; educators who attend training or Professional Development, and have developed this Policy to demonstrate our commitment to protecting your privacy. For the purposes of this Policy, the term “Websites” shall refer collectively to www.inthefootsteps.org as well as any other websites that we operate and that link to this Policy.

In order to deliver our Websites and Services to you, from time to time we collect personal information. This Policy describes:

  • The types of personal information we may collect or that you may provide when you visit our Websites or use our Services; participate in a survey or provide feedback, communicate with us; register for Professional Development;
  • Our practices for collecting, using, maintaining, protecting, and disclosing that personal information.
  • This policy DOES NOT apply to:
  • Personal information we collect offline or through any other means except as provided for herein.
  • Personal information we collect about job applicants, independent contractors, service providers, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of RTV.
  • Information that you provide to or is collected by any third party, including through any third-party application or content that may link to or be accessible from or on the Websites or Services. These third parties may have their own privacy policies, which we encourage you to read before providing information to them.

Our Websites and Services may contain links to third-party websites, which do not operate under this Policy. These third-party websites may independently solicit and collect personal information from you. While we strongly support the protection of privacy on the internet, we do not have control over, and cannot be responsible for, the actions of other third parties. We encourage you to review the privacy policies of all third-party websites you visit to understand their information practices before providing personal information directly to them.

In this Policy, “personal information” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information. Additionally, personal information does not include publicly available information, which is information that is lawfully made available from federal, state, or local government records.

Personal information is required for us to be able to provide the Services to you. In addition, some of the Services we provide require that we disclose your personal information to third parties, such as to companies that help us to provide our Services. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use our Services.

Please read this Policy carefully. It is your choice whether or not to provide personal information to us. If you choose not to provide your personal information to us, you may not be able to use our Websites and Services and we may not be able to communicate with you. If you do not agree with our policies and practices, do not access or use the Websites and Services. By accessing or using the Websites and Services, you accept and agree to be bound and abide by our Privacy Policy.

3. Information We Collect and How We Collect It

We may collect several categories of personal information from or about you, including information:

  • By which you may be personally identified, including your full name, email address, username, and/or image.
  • That is about you but individually does not identify you, including your grade in school, your age, what grade you teach, your feedback and survey responses on our Websites and Services, professional development, and training (e.g., how you feel about the quality and quantity of activities in the program, how likely you are to recommend the Websites or Services to others, or how you rate a particular digital lesson), and geographic location information (e.g., address, country, state, city and/or postcode).
  • About your internet connection, the equipment you use to access our Websites and Services and other usage details (e.g., session duration, number of actions per session, feature usage, and whether you complete videos or lessons).

We collect this information:

  • Directly from you when you provide it to us, such as when you register to use our Websites and Services; register for training, professional development; participate in a survey or provide feedback; sign up to receive marketing communication and newsletters from us; or when you contact us.
  • From your school district, school, or a services provider in order to provide you with access to the Websites and/or Services.
  • From a colleague who may refer you to us.
  • From our marketing and research partners who help us connect with educators or conduct research and surveys on our behalf.
  • Automatically from your device when you access or use our Websites and Services.

A. Information Provided by You

We collect the following types of personal information from you when you access our Websites and Services. The most common of these circumstances where you would provide personal information and the categories of personal information we collect in those circumstances include the following:

  • Purchasing a Subscription or Membership. When you purchase a subscription or membership to our Services, we may collect information necessary to process your transaction, including your name, email address, mailing address, phone number, payment information, such as a credit card number and/or other related information that may be required from you to complete your purchase (“Financial Information”). Unless we tell you otherwise at the time of your purchase, we do not collect, store or maintain your Financial Information; rather this information is handled by our Service Providers. For more information on how your information is shared in these instances, please see the “Third-Party Payment Processing” Section below.
  • Using Our Websites and Services. In order to use certain features of our Websites and Services, you (or your school) may be required to create a password-protected user account and provide us with personal information, including first name, middle initial, last name, username (Logon ID), password, teacher ID, teacher email, student ID, student grade, parent/guardian name, and parent/guardian email. We will store and use this information to administer the Websites and Services in which you choose to participate.
  • Contacting Customer Service. When you contact our customer service, we may ask you to provide, or confirm, personal information, including your first and last name, job title, email address, phone number, city, state, school or district, so that we can better serve you.
  • Newsletters. For non-student users of the Websites and Services, we may collect your email address, first and last name, and zip code if you sign up to receive our newsletters.
  • Participating in a Survey or Providing Feedback. We may contact you to participate in surveys or provide feedback. If you participate in a survey, we may ask you to provide personal information, including your name, session ID, job title, grade level you teach, your school name, and your school district for internal analysis, research studies, and to support product and services development.
  • Promotional or Marketing Communications. If you sign up to receive promotional communications or notifications from us, we may ask you to provide personal information, including name and email address, so that we can provide these to you.
  • Featured Questions. From time to time, we may want to feature questions and comments we receive from you and your students. To submit a Featured Question, we collect the email address of the teacher, and the first name of the student and their grade system (e.g., United States grades). If the question is selected to appear, we will send you a permission form to obtain appropriate consent from the student’s parent or legal guardian for the student to appear in any featured video. Participation in any recorded video is optional, and we will never proceed without a signed consent form.
  • Interactive Features. We may offer interactive features such as commenting functionalities, “likes,” chat services, review forums, tips, and social media pages. We may collect the information you submit or make available through these interactive features. Any information you share on the public sections of these channels will be considered “public” and is not subject to privacy protections referenced in this Policy. We may access and use any of your public reviews along with your member profile name for any purpose, including marketing.
  • Professional Development, Training Conferences, Trade Shows, and other Events. We may host professional development and training events, and may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in us and/or the Services.
  • Registering for Events. When you register for an event, such as professional development, we may collect your name, job title, professional email address, phone number, mailing address, state, school district, and school name during the registration process.
  • Referrals. Some of our Services may allow you to refer other educators to use our Services by providing their names and email addresses. We will use the email addresses you provide to send an email inviting the recipient to use our Services. If the recipient does not respond to the invitation, we may send a single reminder email.

The above list provides examples of the personal information that may be collected when using our Websites and Services. If you do not want us to collect your personal information, please do not provide it to us.

B. Information that We Collect Automatically From You On Our Websites and Services, and the Technologies We Use to Collect It

We may automatically collect information from you when you visit or access our Websites and Services. We use this information to deliver our webpages to you upon request, to tailor our Services to the interests of our users, to learn how our Websites and Services are used, and to measure traffic and usages within our Websites and Services.

  • Usage Details. When you access and use our Websites and Services, we may automatically collect certain details of your access to and use of our Websites and Services, including, but not limited to, location data, time of visit, length of time your visit and of specific pages, page views, scroll depth, logs, scoring content that you are interested in, referring or exit website address, the content of any undeleted cookies that your browser previously accepted from us, and other communication data and the resources that you access and use on or through our Websites and Services.
  • Device Information. We may collect information about the device and internet connection you use to access our Websites and Services, including, but not limited to, the device’s unique device identifier, IP address, operating system, system configuration information, browser type, network information, internet service provider, JavaScript support, language preferences, screen resolution, and screen color processing ability.
  • Interacting with Social Media Sites. If you choose to join (or “like”) our page on a third party’s social media site, the social media site may provide us with certain information about you, including but not limited to your other “likes,” your email address, place of residence and other information from your public profile if you interact with our social media pages, Facebook, Twitter, LinkedIn, Pinterest, etc., so we can tailor our interactions to you. Please see the privacy policy for the applicable social media site to learn more about how these sites share your personal information.

We use various technologies to collect information from your computer or other device and about your activities on our Websites and Services, including:

  • Cookies. When you visit our Websites and/or Services, we may assign your device one or more cookies to help you navigate our Websites efficiently, to personalize your online experience, and to perform certain functions, including website traffic analysis. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign in to our Websites and Services, we will record your username (Logon ID), and the name on your user account in the cookie file on your computer. We store your unique user ID in a cookie for automatic sign-in. This cookie is removed when you sign-out. For security purposes, we will encrypt the unique user ID and any other user account-related data that we store in such cookies. In the case of sites and services that do not use a user ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as providing analysis and research on the effectiveness of our Website, content, and advertising. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Websites and/or Services may not function properly. To read more about how we use cookies, please review our cookie policy.
  • Google Analytics. We use Google Analytics provided by Google Inc. It uses cookies to collect certain information, for example, information about the operating system and the browser that you use, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to the Services. On subsequent repeated visits to the Websites or Services, frequently-used information is automatically displayed for you. We are able to track your usage patterns with the help of the cookies. The information generated by cookies about the use of the Websites or Services is transmitted to a Google server, which may be located within or outside of, the United States, and stored there. Google will use this information to evaluate your use of the Websites or Services. Google may transfer these rights to third parties insofar as it is required to do so by law or in order that data may be processed on Google’s behalf. For more information about Google’s data privacy practices, we encourage you to review “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/. By accepting this Policy, you consent to the processing of your data by Google.
  • We use Hotjar Analytics to take screen recordings of our website visitors. Hotjar is compliant with major data protection legislation such as the European GDPR legislation and the California Consumer Privacy Act (CCPA). When you enter any sensitive data into our forms (such as the contact form), HotJar will blur the details as to make them illegible on the screen recording. We cannot identify individual users from HotJar; IP Addresses are not collected. If you have any further questions regarding our use of HotJar, please email [email protected] or our web developer, [email protected]

C. Information Collected From Other Sources

We may also obtain both personal and non-personal information about you from the following categories of sources: your school, our marketing partners (including social media companies, and companies that license datasets of teachers, educators, and school administrators), our resellers or partners, advertising networks, and companies we work with to conduct research and surveys. We may combine this information with information we collect through our Websites, Services, or from other sources.

Third Party Payment Information. When you make purchases through the Services, we may process your payments through a third-party payment service provider. In these instances, the third-party payment service may collect certain Financial Information from you to process a payment on behalf of us, including your name, email address, address and other billing information in which case the use and storage of your Financial Information is governed by the third-party payment service provider’s terms, conditions and privacy policies. Our treatment of any Financial Information that we may process on your behalf, or that we receive from our financing partners, is subject to this Privacy Policy.

4. Purposes for Processing Personal Information

Purposes for using personal information. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.

  • Provide and deliver the Services you request, license or purchase.
  • Personalize and improve our Websites and Services and your experiences when you use our Websites and Services, including to develop new products and services.
  • Process and complete a transaction or service requested by you.
  • Contact you in response to sign up forms such as Contact Us, and to provide you with customer support.
  • Communicate with you about programs, products, and Services that we think may interest you; offers (such as a free-trial of a product or services); updates on new or popular content, features and Services; training and professional development opportunities; connecting you with other educators; special events; educational programs; and news from us. (If you prefer that we not contact you in this manner, please follow the Opt-Out instructions in this Policy). We do not contact students for this purpose.
  • For service administration where we need to contact you for reasons related to our Websites and Services (for example, where we need to send you a password reminder, to notify you about services updates or amendments to our Terms of Use, Cookies Policy, or Privacy Policy).
  • For marketing purposes, including helping us create and publish content most relevant and impactful to you; developing and displaying content and advertising tailored to your interests on our Websites and Services; measuring and improving the effectiveness of our advertising campaigns; and developing sales and business development leads.
  • To aggregate and/or de-identify information about users or to use suggestions, comments, and ideas that are not personally identifiable. We are free to use and disclose through any means and use for any purpose information that is not personally identifiable in our sole discretion.
  • Monitor and analyze trends, usage, and activities in connection with our Websites and Services.
  • For surveys, research and development, and analytics (including sales and marketing research).
  • Ensure that our own processes, procedures and systems are as efficient as possible.
  • Enforce our Terms of Service.
  • Manage our business operations and perform functions as otherwise described to you at the time of collection.
  • Keeping our Websites, Services, products and IT systems secure.
  • Protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
  • For legal compliance purposes.

5. Sharing of Personal Information with Others

We share your personal information as necessary to provide the services you request, including sharing information with third party service providers; when required by law; to protect rights and safety; and with your consent.

We may share personal information with:

  • Authorized Service Providers: We may share your personal information, including name, unique personal identifier, IP address, email address, job title, other similar identifier, usage details, profile reflecting a consumer’s preferences, characteristics, behavior, abilities, and aptitudes and device details with our authorized service providers that perform certain services on our behalf. These services may include delivering our Websites or Services to you; providing customer service and support to you; providing marketing, advertising, and business development; performing marketing, business and sales research and analytics; supporting our Websites and Services functionality; conducting surveys and research for product development and improvement; processing payments through a third-party payment service provider; and supporting challenges, contests, promotions, sweepstakes, surveys and other features offered through our Websites and Services. The research reports and white papers do not contain personal information.
  • GOOGLE API USAGE

    In The Footsteps of History’s webapp use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy
    including the Limited Use requirements.

  • RTV. Between and among RTV, our affiliates, subsidiaries and the companies under our control and ownership, we may share personal information such as name and contact details of our customers’ primary point of contact and end users of the Services, users’ usage details of the Services, customer’s sales history and account information, and information collected through our Websites and Services by tracking technologies (as described above) for the following purposes: identifying business development opportunities, our marketing and advertising activities, conducting research and analytics, and improving our Websites, Services and product development.
  • Corporate and Non-Profit Education Partners. We partner and collaborate with corporate and non-profit education partners to provide teachers with professional development and training; introduce students to careers and educational experiences; develop educational websites for educators, children, and parents; integrate digital content provided by the corporate and non-profit education partners into the Services; underwrite and sponsor RTV Services for certain schools;
    • We share aggregate or de-identified information and statistical reports relating to usage of the Website and Services with our corporate and non-profit education partners (e.g., aggregate counts of schools with access to the Services, aggregate counts of students who have logged in and used the content in the Services, and aggregate counts of clicks on content in the Services). These reports do not contain personal information.
  • Referrals. If you choose to refer colleagues and other contacts to use our Services by providing their names and email addresses, we may share your name with your colleagues in the initial referral email and one-time follow-up email.
  • Resellers and Partners. We may share or receive your personal information with business partners and resellers in order to provide you with access to our Websites and Services. If you purchase Services through a partner or reseller, that organization may provide you with information about related products and services that may be of interest to you in accordance with the partner or reseller’s privacy policy.
  • Other situations. We also may disclose your information:
    • In response to a subpoena, document request, or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to prosecute or defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
    • When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms and conditions or other agreements or policies.
    • In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
    • When you provide us with your consent to share your information with third parties.

Aggregated and Non-personal Information:

We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Policy. We may share aggregated information with third parties, including advisors, corporate and non-profit partners, and potential customers, for the purpose of conducting general business analysis. For example, we may tell future advertisers the number of visitors to our Websites and Services and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

6. How Long We Retain Your Personal Information

RTV will retain your personal information for as long as is needed to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements).

Upon expiration or termination of any subscriber agreement, RTV destroys personal information previously received from the subscriber, customer, and/or user when the subscriber, customer, or user signed up for the Services along with information relating to the subscriber, customer, and/or user’s use of the Services no later than sixty (60) days following such termination, unless a reasonable written request is submitted by the subscriber or customer to us to hold such personal information.

RTV retains the information it collects for an unrestricted period of time subject to requests for deletion.

7. Your Privacy Rights

You may have certain rights in relation to your personal information. If you would like to exercise any of them, please contact us (contact details below).

We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

How You Can Access or Request to Delete Your Information

If you have an online account with us, you have the ability to review and update your personal information online by logging into your account. You can also review and update your personal information by contacting your school.

If you are a user of the Services, you may request to have your personal information that you provided when you subscribed along with the information relating to your use of the Services removed from our databases by submitting a request to our contact information set forth at the end of this Policy, and insert “Privacy Rights Request” in the subject line. We will remove such information as soon as practicable for us, however, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Websites or our users, or take other actions otherwise permitted by applicable law. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information may be subject to those third parties’ policies.

Your Choices About Collection and Use of Your Information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Websites and Services because such information may be required in order for you to access features of our Websites, participate in a contest, survey, or sweepstake; ask a question; contact customer support; or otherwise initiate other transactions on our Websites and Services.

Opt-Out

At any time you can choose to no longer receive commercial or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication or on our Websites and following the instructions or contacting us. Non- student users of the Services may be given a choice as to whether you want to receive email messages about products and services related to your interest. You may modify your choice at any time by using the “Opt-Out” link as described above.

You also will be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future. It may take up to ten (10) days for us to process an opt-out request. We may send you other types of transactional and relationship email communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us.

Even if you opt-out of receiving promotional or marketing communications, you may continue to receive emails and notifications relating to your subscription, service announcements, administrative notices, surveys, and/or other business-related communications.

8. Children’s Personal Information

RTV does not collect personal information from students at this time.

In most instances, RTV will only request the first name and email address of a child under 16 years old in order to complete an immediate request from the child. For students using the Services, any personal information that may be provided, which may include, but is not limited to, first and last name, grade and school, will be provided by the school district, individual school, or individual using the Services.

Use of Personal Information Collected from Children

When we collect personal information from children under 16 years old, we will only use that information for the express purpose for which it was collected. The personal information will not be used for any other purpose.

Sharing of Personal Information Collected from Children

Except as provided in this Section, we do not share personal information collected from children under 16 years old with any third parties. We may, however, share a child’s personal information that we have collected from the child’s school district, school or from the child in the following limited instances:

  • We may share such information with our authorized service providers who help us maintain our Websites and Services and provide other services to us. We seek to ensure that these service providers may not use the personal information for any other purpose. These service providers have agreed to maintain the confidentiality, security and integrity of the personal information.
  • We may disclose a child’s personal information to third parties if we believe we are required to do so in order to comply with law (including court orders and subpoenas); to comply with requests from law enforcement agencies or the government; to enforce our Terms of Use; to protect our rights, privacy, safety or property and the rights, privacy, safety or property of our employees or others; to protect our operations; and to permit us to pursue available remedies or limit the damages that we may sustain.

Note to Parents and Legal Guardians

Please contact RTV at any time regarding privacy questions or concerns, or to request to review what personal information we have collected from a child. Parents may also contact us at any time to request that we delete the personal information of a child or a parent and/or refuse to permit further collection or use of a child’s information. We will take steps to verify that any person contacting us for a child’s information is that child’s parent or guardian.

Return to Venice, LLC
28 Shore Road
Douglaston
New York
11363
Tel: 718-986-5104
Email: [email protected]

9. Other Important Information

Below, you will find additional privacy information you may find important.

Security

The security of your personal information is important to us. We follow generally accepted standards (including by taking physical, electronic and procedural measures) to protect the personal information that we collect and process.

While we are focused on the security of your personal information and follow strict standards, processes and procedures that are designed to protect your personal information, you must remember that the internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.

You should also take care with how you handle and disclose your personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov for information about how to protect yourself against identity theft.

No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

Changes to this Policy

We will occasionally update this Policy to reflect material changes in our privacy practices. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by posting the modified Policy on our Websites and Services and indicating at the top of the Policy the date it was last updated. We may also notify you by sending you an email. We encourage you to review the Policy each time you visit one of our Websites and Services to see if this Policy has been updated since your last visit to make sure you understand how your personal information will be processed.

10. Age Screening

If we become aware that we have inadvertently received personal information from a child under the age of thirteen other than in a legally permissible situation, we will delete the information from our records as soon as we discover it.

Do Not Track Disclosure

RTV does not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

  • A. United Kingdom/European Union/European Economic Area

If you are an individual located in the United Kingdom, European Union or European Economic Area, you may have the following rights regarding your personal information:

You have the right to request access to your personal information, and the rectification of inaccurate personal information concerning you and obtain a copy of the personal information held by us. You have the right to obtain the deletion or the restriction of processing of your personal information in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when we are required by law to maintain or otherwise process your personal information, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person. You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications. In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance. You also have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law.

If you would like to make such a request, please email: [email protected] and insert “Privacy Rights Request” in the subject line or call this number: 718-986-5104. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.

Our Legal Basis for Processing Personal Information

Our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it. We rely on the following lawful bases for processing personal information: necessary for the performance of a contract, your explicit consent, and our legitimate interests, and compliance with legal obligations.

When we have collected your personal data to provide you with Services that you have requested, our legal basis for the processing of that personal data is that it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. If you refuse to provide us with your personal data, you may be unable to obtain the products and services from us that you requested.

We also collect and process personal data about you as necessary to operate our business, sales, account management, provide direct marketing, product development and improvement, product usage analytics, meet our contractual and legal obligations, comply with federal, state, and local laws, and/or fulfill our other legitimate interests (when not overridden by your data protection interests or fundamental rights and freedoms).

When you participate in a survey, challenge, competition, sweepstake, promotion, and/or contest, our legal basis for the processing of your personal data is your explicit consent. Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided below.

International Transfer of Information

Your personal information may be transferred to, stored, and processed within the United States. Additionally, we may transfer your personal information to other countries in certain circumstances, for example because a server or third party service provider is located there. BY

PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO ANY TRANSFER, STORAGE, AND PROCESSING IN ACCORDANCE WITH THIS POLICY.

There are potential risks to you associated with transferring your information to the United States and other countries due to the absence of an adequacy decision and appropriate safeguards. These risks include the risk that you will not be able to exercise your data protection rights under applicable law to protect yourself from unlawful use or disclosure of your information. The data protection and privacy laws of certain countries, including the United States, may not afford you the same level of protection as those in your own country.

11. Contact Us

If you have any questions about this Policy or our privacy practices, please contact us by email or postal mail as follows:

Return to Venice, LLC
28 Shore Road
Douglaston
New York
11363

Email: [email protected]