1.2. Data Controller
1.3. Applicability to Payments
Controller (the “Payments Data Controller”) of your information related to the Payment gateways. In all cases, Ventura payment gateways are fully regulated and may process any personal information according to enforced regulations and lawsenforced by State Bank of Pakistan and the Government of Pakistan. Please see the Contact Us section below for contact details of the Data Controllers and Payments Data Controllers.
- COLLECTED INFORMATION
Given below are general categories of information we collect.
2.1. Mandatory Information
This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
Account Information. When you sign up for an Ventura Account, we require certain information such as your first name, last name, email address, and date of birth.
Profile and Listing Information. To use certain features of the Ventura Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
Payment Information. To use certain features of the Ventura Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via Ventura Payment gateways).
Communications with Ventura and other Members. When you communicate with Ventura or use the Ventura Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.
2.2. Information given by choice
Additional Profile Information. You may choose to provide additional information as part of your Ventura profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Ventura Platform, like inviting them to use Ventura.
Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Ventura Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us (such as through Host Stories), or use other features
of the Ventura Platform.
2.3. Information that is necessary for the use of the Payment gateways.
The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment gateways:
Payment Information. When you use the Payment gateways, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
Identity Verification and Other Information. If you are a Host, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment gateways to you, and to comply with applicable law.
2.4. Information Automatically Collect from Your Logs
Geo-location Information. When you use certain features of the Ventura Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Ventura may also collect this
information even when you are not using the app if this connection is enabled through your settings or device permissions.
Usage Information. We collect information about your interactions with the Ventura Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Ventura Platform.
is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business
partners may also use these tracking technologies on the Ventura Platform or engage others to track your behavior on our behalf.
Payment Transaction Information. Ventura does not collect your payment credentials and only uses billing information to clear its accounts with guests and hosts.
2.5. Information from Third Parties.
Ventura and Ventura Payments may collect information, including personal information, that others provide about you when they use the Ventura Platform and the Payment gateways, or obtain information from other sources and combine that with information we collect through the Ventura Platform and the Payment gateways. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
2.6. Children’s Data.
Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.
3. USE OF INFORMATION
We may use, store, and process personal information to (1) provide, understand, improve, and develop the Ventura Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Ventura Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.
We process this personal information for these purposes given our legitimate interest in improving the Ventura Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
We may use the personal information as a part of Payment gateways such as to:
Enable you to access and use the Payment gateways.
Detect and prevent fraud, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with legal obligations (such as anti-money laundering regulations).
Enforce the Payment Terms and other payment policies.
With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences. The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment gateways and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
4. SHARING & DISCLOSURE
4.1. Advertising and Social Media; Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Ventura Account or when you participate in promotional activities conducted by Ventura partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Ventura Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal information are not controlled or supervised by Ventura. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask Ventura to cease processing your data for these
direct marketing purposes by sending an e-mail given on our website.
4.2. Sharing between Members.
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
When you as a Guest submit a booking request, certain information about you is shared with the Host (and Co-Host, if applicable), including your profile, full name, the full name of any additional Guests, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist
with coordinating the trip, like your phone number.
When you as a Host (or Co-Host, if applicable) have a confirmed booking, certain information is shared with the Guest (and the additional Guests they may invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and
Accommodation or Experience address.
When you as a Host invite another Member to become a Co-Host, you authorize the CoHost to access and update your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation address, calendar, Listing information, Listing photos, and email address.
When you as a Guest invite additional Guests to a booking, your full name, travel dates, Host name, Listing details, the Accommodation address, and other related information will be shared with each additional Guest.
When you as a Guest initiate a Group Payment Booking Request certain information about each participant such as first name, last initial, profile picture as well as the booking details is shared among all participants of the Group Payment Booking Request. We don’t share your billing and payout information with other Members.
4.3. Profiles, Listings, and other Public Information.
The Ventura Platform lets you publish information, including personal information, that is visible to the general public. For example: Parts of your public profile page, such as your first name, your description, and city, are
publicly visible to others.
Listing pages are publicly visible and include information such as the Accommodation or Experience’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time),
and any additional information you choose to share.
After completing a booking, Guests and Hosts may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Ventura Platform (such as the Listing page).
If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Ventura Platform, that content is publicly visible.
4.4. Additional Services by Hosts.
Hosts may need to use third party services available through the Ventura Platform to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services or lock providers. Hosts may use features on the Ventura Platform to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third party service providers for the purposes of coordinating the stay, managing the Accommodation, or providing other services. Hosts are responsible for third party service providers they use and ensuring those service providers process Guest information securely and in compliance with applicable law
including data privacy and data protection laws.
4.5. Compliance with Law and Legal Requests.
Ventura and Ventura Payments may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary. These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Ventura Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
4.6. Collection and Remittance of Occupancy Taxes.
In jurisdictions where Ventura facilitates the Collection and Remittance of Occupancy Taxes, Hosts and Guests, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Hosts’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and Occupancy Taxes to the relevant tax authority.
4.7. Government Registration.
In jurisdictions where Ventura facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through the Ventura Platform in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, if applicable,
periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.
4.8. Information Provided to Enterprise Customers.
If you have linked your Ventura Account to the Ventura Account of a company or other organization (an “Enterprise”), added your work email address, or have a booking facilitated via another party (such as the future employer or other entity) or used a coupon in a similar capacity in connection with an Enterprise (such as using a coupon to pay for an accommodation for an enterprise related event like employment onboarding, orientation, meetings, etc.) through one of our Enterprise products, that Enterprise will have access to your name, contact details, permissions and roles, and other information as required to enable use by you and the Enterprise of such Enterprise products.
4.9. Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5. OTHER IMPORTANT INFORMATION
5.1. Analyzing your Communications.
We may review, scan, or analyze your communications on the Ventura Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and
references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on Ventura’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2. Linking Third Party Accounts.
You may link your Ventura Account with your account at a third party social networking service. We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
5.3. Third Party Partners & Integrations
The Ventura Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Ventura doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner,
Ventura, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. YOUR RIGHTS
Consistent with applicable law, you may exercise any of the rights described in this section before
your applicable Ventura Data Controller and Payments Data Controller.Please note that we may
ask you to verify your identity and request before taking further action on your request.
6.1. Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your Ventura Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2. Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Ventura Account).
6.3. Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. We may retain some of your personal information as necessary for our legitimate
business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Ventura Account for fraud or safety reasons, we may retain certain information from that Ventura Account to prevent that Member from opening a new Ventura Account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Ventura and Ventura Payments may keep some of your
information for tax, legal reporting and auditing obligations. Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Ventura Platform, even after your Ventura Account is cancelled.
However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the Ventura Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.4. Lodging Complaints.
You have the right to lodge complaints about our data processing activities by filing a
complaint with our Data Protection Officer who can be reached by the “Contact Us”
section below or with a supervisory authority.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls.
9. CONTACT US
© 2020 Ventura, Inc. All rights reserved.