The Privacy Policy was last updated June 20, 2024. 

Venables Bell + Partners LLC is an independent advertising agency specializing in integrated marketing campaigns, brand strategy, creative development, and media planning across various media. This Privacy Policy applies to Venables Bell + Partners LLC (referred to herein as “Venables,” We,” or “our”) and governs our practices regarding the collection, use and disclosure of personal information that we collect offline and online, including via our website at https://www.venablesbell.com (the “Website”), by email, marketing communications, social media, mail, telephone, or other methods. We may update this Privacy Policy from time to time, as specified in the “Changes to This Privacy Policy” section below. 

If you are a California or Texas resident, please the following sections of this Policy:

• California
• Texas

Your Consent 

Please review this Policy periodically. You should read this entire Policy before submitting information, including Personal Information, to us in any form or using our Website. Whenever you submit Personal Information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Policy.

All Personal Information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. 

Collection of Personal Information

We collect Personal Information using the following methods: 1) from you when you voluntarily provide it, including online when you visit our website, or when you interact with us in any other manner; 2) using automated technology, including when you visit our website or interact with our electronic advertisements or communications; and 3) using third party sources including but not limited to service providers and entities providing data analysis and analytics. To see a complete list of what we collect, how we use this data, please see Annex 1 [link].

Venables collects Personal Information, including contact information, your contact information, such as your name, mailing address, email address, phone number; employment information, education information and any other information You choose to provide to us.

In addition, We also collect Internet and Network Activity through your browser, computer hardware and software. We may collect and analyze information such as (a) IP addresses, location information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which You accessed the Website; and (b) information related to the ways in which You interact with the Website, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Website, the amount of time spent on particular pages, the date and time You used the Website, the frequency of your use of the Website, error logs, and other similar information.

How We use the information We collect

We may use the data we collect as follows:

• for the purposes for which You provided it;

• to recognize and authenticate You on the Website;

• to initiate or to provide the features available through the Website or to provide our services;

• to send You information about your relationship or transactions with us or other communications, such as newsletters, if any, to which You have subscribed;

• to process and respond to your inquiries or to request your feedback;

• for internal research and reporting;

• to improve the content and features of the Website or our services or develop new services;

• to enforce the legal terms that govern your use of the Website or our services;

• to administer and troubleshoot the Website or our services; and

• to send you communications required by law or which are necessary to inform you about changes to the services we provide and this Privacy Policy; and

• as otherwise specified at the point of Personal Information collection.

How We Disclose Your Information

We may disclose Your information as follows:

• To our parents, affiliates, subsidiaries, and other companies under common control and ownership.

• To consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host and support our website and data, security and fraud detection vendors.

• To third parties who help us gather information from you and communicate with you including for email communications and/or perform services on our behalf, including without limitation marketing, market research, customer support, data storage, data analytics, analysis and processing, and legal services.

• Where required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons:

  • (a) to comply with legal process i.e. if We are required to respond to subpoenas, court orders or are asked to respond to legitimate requests for Your personal information from law enforcement or government agencies. In such situations, we will release Your information to these organizations as we reasonably believe appropriate for us to comply with the law and to prevent against fraud. We will not provide You with these requests for information made by law enforcement or government agencies;

  • (b) to enforce this Privacy Policy or other contracts with You, including investigation of potential violations thereof;

  • (c) to respond to claims that any content violates the rights of third parties;

  • (d) to respond to Your requests for customer service; and/or

  • (e) to protect our rights, property, or personal safety and those of our agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

• As part of business transactions, (including in contemplation of such transactions, e.g., due diligence), such as buying, merging with, or partnering with other businesses or as part of an asset sale.

"Cookies" and Other Technology

Security and Data Retention

We have implemented reasonable administrative, technical, and physical security measures designed to protect against the loss, misuse, and/or alteration of your information. While We strive to protect your information, We cannot and do not guarantee that our efforts will prevent every unauthorized attempt to access, use, or disclose your information because no Internet and/or other electronic transmissions can be completely secure.

Whenever We collect your personal data, We’ll only keep it for as long as is necessary for the purpose for which it was collected unless a longer retention period is required or permitted by applicable law. At the end of that retention period, We will either delete your data or anonymize it, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning purposes.

Data Transfers

If you are located in Mexico, the European Union, Canada or elsewhere outside of the United States, please be aware that the information we collect may be transferred to and processed in the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.

Your Choices and Rights

We offer You certain choices in connection with the information We collect and in particular to update or correct your information or submit a request, You can contact us as described below in the How to contact us section.

If You shared your email address with us and receive our electronic communications, You can unsubscribe from such communications by clicking the “unsubscribe” link they contain. You may opt out of the use of Cookies as set forth in Section 1 above.

Links to Other Sites

Our Website may contain links to other websites (e.g. Instagram, LinkedIn, Medium) that may collect personal information from you. Our Privacy Policy does not extend to those third-party Websites and We are not responsible for these parties’ policies in particular in connection with their data protection practices. This applies to any information you submit to third parties such as BambooHR through the Website. To have further information on such policies, please consult said third party’s website.

Do Not Track Notice

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track feature or setting you can activate to signal your preference that your on-line browsing activity data are not monitored and collected. There is no uniform technology standard for recognizing and implementing Do-Not-Track signals. This application does not support Do-Not-Track signals.

Governing Law

This Policy and our privacy practices will be subject exclusively to the laws of the State of California, United States of America. We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.

Children’s Privacy

Our Website and services are intended for general audiences and not for children under the age of 13. If We become aware that We have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13, We will take reasonable steps to delete it as soon as practical. If You believe that a child under the age of 13 has provided us with personal information, please contact us as specified in the How to contact us section below.

How to Contact Us

If You have any questions regarding our privacy practices, You may contact us by email at privacy@venablesbell.com and legal@venablesbell.com; by mail at Venables Bell + Partners, 201 Post Street Ste 500, San Francisco, CA 94108, attn: Legal Department.

Change of Policy

We reserve the right to make changes to this Privacy Policy at any time; in which case, We will post such changes on the Website. Your continued use of the Site following the posting of any changes to this Privacy Policy means you accept such changes.

Terms and Conditions of Use

Your use of the Website is governed by and subject to the Terms and Conditions of Use posted on the Website. This Privacy Policy is incorporated into such Terms and Conditions of Use.

This Privacy Policy was last updated June 20, 2024.

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please review our Privacy Policy (“Policy”) above for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy. 

PERSONAL INFORMATION COLLECTED, SOLD OR SHARED

Information Collected

We collect the categories of personal information about California consumers as described in Annex 1. To review these categories, see Annex 1 [link].

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. See Annex 1 [link] for more details.

Information Sold or Shared

We have not sold or shared personal information in the preceding 12 months.

We have disclosed the following categories of personal information for a business purpose in the preceding 12 months:

• Personal Identifiers

• Internet Activity

For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1, below. 

CPRA RIGHTS AND REQUESTS 

Under the CPRA, you are entitled to certain rights, where you can make certain requests with regard to those rights as follows: 

Right to Know about the Categories of Personal Information Collected (“Right to Know”)

Right to Request Deletion of Personal Information (“Right to Delete”)

Right to Correct or Rectify Inaccurate Information about you (“Right to Correct”)

HOW TO MAKE YOUR REQUESTS TO KNOW, DELETE, OR CORRECT.

You have the right to make requests for the aforementioned rights (Request to Know; Request to Delete; or a Request to Correct (a “Request”)).

To make a Request for any of the information set forth above, please submit a verifiable consumer request pursuant to the instructions below. The Request must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, shared, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. We will acknowledge your Request within 10 business days and will attempt to respond substantively within 45-90 days.

You may make a Request by emailing privacy@venablesbell.com.

Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identification.

We will review all information provided by you to us, to determine whether we can respond to your Request. We will inform you of our decision to deny or grant your Request.

For any Requests to Know, you may make such Requests twice within a 12-month period. 

For Requests to Correct, you will need to provide evidence supporting the inaccuracy of the current information, and we reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

We will retain correspondence, documents and information related to any Request for 24 months as required by law.

ADDITIONAL CPRA RIGHTS 

The following are additional rights afforded to you under the CPRA. 

Right to Know Sensitive Personal Information Collected

We do not collect or process sensitive personal information.

Right to Opt Out of Sharing and Selling 

You have the right to opt out of sharing or selling of your personal information, as those terms are defined under the CPRA. We have not sold or shared your personal information in the preceding 12 months. 

Right to Non-Discrimination for Exercising Consumer Privacy Rights

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

AUTHORIZED AGENT INFORMATION

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

Authorized agents can make requests under the California Consumer Privacy Act by emailing us at email address: privacy@venablesbell.com . We will require authorized agents to provide proof of the consumer’s identity and proof of designation as the authorized agent. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.

We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent. 

California Do Not Track Notice: Because there are not yet common, industry-accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow third parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above and as described in Annex 1 below. 

CONTACT FOR MORE INFORMATION

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at privacy@venablesbell.com.

Changes to This Privacy Policy

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.

TEXAS DATA PRIVACY AND SECURITY ACT NOTICE 

The Notice below applies only to residents of Texas. Please visit our Privacy PolicyPrivacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

RIGHT TO CONFIRM, ACCESS, AND DATA PORTABILITY

You have the right to confirm whether or not we are processing your personal data and to access such personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means. 

We have collected the categories of Personal Information about Texas consumers as described in this Notice in Annex 1. To review these categories, click here. [LINK to Annex 1].

Information Sold or Used for Targeted Advertising

We have not sold your personal information in the preceding 12 months. 

RIGHT TO REQUEST DELETION OF PERSONAL DATA

You have the right to request the deletion of your personal data provided by or obtained about you (“Request to Delete”), subject to certain exceptions permitted by law.

RIGHT TO CORRECT

You have the right to request that we rectify inaccurate information about you. 

RIGHT TO OPT OUT OF DATA PROCESSING FOR TARGETED ADVERTISING

We have not processed your data for purposes of targeted advertising in the preceding 12 months. 

RIGHT TO OPT OUT OF PROFILING 

You have the right to opt out of the processing of your personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects (“Request to Opt Out of Profiling”). We do not process your personal data for profiling purposes.

HOW TO MAKE YOUR REQUESTS TO CONFIRM, ACCESS, DATA PORTABILITY, CORRECT, DELETE, AND OPT OUT OF TARGETED ADVERTISING

You can make a Rights Request by emailing us at privacy@venablesbell.com.

We will acknowledge your Request within 10 days and will attempt to respond substantively within 45-90 days.

You must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.

Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity. We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

OPT-OUT PREFERENCE SIGNALS

We honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information for targeted advertising purposes without first seeking your explicit consent. 

COOKIES

As explained in our “Cookies” section (add link to the Cookies section in the main Privacy Policy), you can opt out of cookies using your browser. You may also exercise your right to opt-out of cookies using our Cookie Preference Center (add link).

Please Note:

• Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.

• Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.

• We may still share your Personal Information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.

• You may still receive ads from us that are not tailored to your interests.

ADDITIONAL OPTIONS TO OPT OUT OF SALE OR TARGETED ADVERTISING

In addition to the above options to opt out of the “sale” or processing of your personal data for targeted advertising as described above, you have controls and choices with respect to collection and use of your data by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation.

Advertising Opt-Out

You can opt out of sharing your data with third-party companies engaged in targeted advertising including social networking sites such as Google and Facebook using the following tools: 

• For Websites [hyperlink: https://optout.aboutads.info/?c=2&lang=EN]

• For Mobile Apps [hyperlink: https://youradchoices.com/appchoices ]

Google Opt-Out

If you would like to opt out of Google Analytics and Ads, you can. If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on here [https://tools.google.com/dlpage/gaoptout], and you can opt out of interest-based Google ads using this link [https://adssettings.google.com/u/0/authenticated.

Facebook Ad Preferences

To understand more about Facebook advertising and manage your preferences, please visit Facebook Ads [https://www.facebook.com/about/ads]. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.]

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right not to receive discriminatory treatment for exercising your privacy rights , including by exercising the rights specified herein. As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.

AUTHORIZED AGENT

You may designate an authorized agent to make a request on your behalf to opt out of the sale of personal information.

Authorized agents may make requests under the TDPSA on behalf of consumers by emailing privacy@venablesbell.com. We will require authorized agents to provide proof of the consumer’s consent to and designation of the authorized agent for purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the consumer who is the subject of the request. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request. 

RIGHT TO APPEAL 

You have the right to appeal our decision to deny any of your privacy rights requests above. Within 60 days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. 

Texas if your appeal is denied, you may submit a complaint to the Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint

Making an Appeal

You can make an appeal by emailing us at privacy@venablesbell.com.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as it is necessary for the purposes set out in the Privacy Policy [LINK] and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Annex 1

Category	Examples	Collected From	Purposes	Disclosed to	Sold or Shared	Retention Period
Personal Identifiers	Contact information, including name, phone number and email address.	You when you visit our Website and provide your information for our newsletter or to contact us or communicate with us in person, via phone or email or other methods.	To send promotional communications or offers regarding our services (unless you have requested that we not send such communications);  For marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations (e.g., hosting or operating our website, data collection, reporting, ad response measurement, website metrics and analytics, data analysis, delivering marketing messages and advertisements) who have agreed to keep the information confidential and use it only to provide the applicable services;  Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics; Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of our company or its affiliates including any negotiation thereof. * No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Sharing of Personal Information with third party partners excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.	No	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Internet/ Network Activity	IP address, your device information, domain name, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicks, transactions entered into and site-navigation patterns.	Your computer or mobile device, through your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our Site, and on our social media channels or through our third-party sources.  Third-party sources include third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.	Analyze and track usage of our services and products including our Site and social media accounts; Improve our Site, services, and products; Provide you with a customized user experience; For other marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations;  Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of our company or its affiliates including any negotiation thereof.	No	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Business-to-Business (“B2B”) Information	Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.	You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.	For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.	We do not disclose B2B Information outside our business relationship without your consent.	No	We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.