We understand that your privacy and the security of your personal information is extremely important.

At Venture.com, we pride ourselves on providing you, the client, with a range of online services. As part of this process, we ask you to provide us with certain personal information, for example, your name, address, email address, and payment details.

This is our notice to you that informs you what we do with your personal information, what steps we take to keep it secure, from where and how we collect your information, and your rights (hereafter the "Policy").

This Policy applies if you interact with us through our website, over the phone, online, sign up for an account, or otherwise by using any of our websites through domain names that we own or manage, or interacting with us on social media (hereinafter our "Services").

Summary of Privacy Policy:

• Venture.com is a leasing platform for domain names located at #510-1231 Pacific Blvd, Vancouver, BC, V6Z 0E2.
• Your personal information is, where appropriate, shared within the Venture.com team to help provide you services.
• You have a number of rights over your personal information. How you can exercise these rights is set out in this Policy.
• We display online advertising relating to our products and services on websites across Venture.com’s website, other websites of domain names managed by Venture.com and online media channels.

For more details on who we are and what we do with your information, please read on:

Who Are We?

We are a domain name leasing platform operated by Reinvent, Inc. and our address is #510-1231 Pacific Blvd, Vancouver, BC, V6Z 0E2. You can contact us by regular mail at the above address, by email at legal@venture.com or by telephone at (778) 328-2866.

What Sort of Personal Information Do We Collect?

If you are merely visiting our Site, we collect and store only the following information about you:

• The IP address of the terminal from which you access the Internet.
• The IP address of the website from which you linked directly to our Site.
• The date and time you access our Site.
• The browser you used to access our Site.
• The operating system you used to access our Site.

We store the aforementioned information in log files. We use this information to measure the number of visitors to the different sections of our Site, and to help us make our Site more useful to visitors.

We will not obtain any other personally identifying information about you when you visit our Site, unless you choose to provide such information to us.

If you create an account or use our services we will also collect, store and use the following information:

• Your account login details for our services, including your user name and password.
• Information that you provide to us such as your name, address, telephone number, email address. If applicable, your bank account and credit card details as well as any feedback you give to us, including by phone, email, post, or when you communicate with us via social media.
• Information about the services that we provide to you (including for example, the things we have provided to you, when and where, what you paid, the way you use our products and services, and so on).
• Information regarding your purchase inquires, offers or other communications regarding a domain name purchase or sale.
• When you successfully lease a domain name through Venture.com, we collect additional information including name servers, administrative contacts, business identification, special registrar requirements, billing address and financial institution details. Bank account information is deleted when your transaction close.
• Information about whether or not you want to receive marketing communications from us.
• Information about any device you have used to access our Services (such as your device’s make and model, browser or IP address) and also how you use our Services. For example, if you use our websites, we try to identify when and how you use those websites.
• Your contact details and details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication.

Cookies and Similar Technologies

"Cookies" are more than just tasty desserts. We use cookies to help give you the best experience on our websites and to allow us and third parties to tailor ads you see on ours and other websites. Cookies allow the website to function, to collect useful information about visitors and to help to make your user experience better.

Cookies fall into four categories: Strictly Necessary, Performance or Analytical, Functionality, and Targeting.

We also use Google Analytics, a third-party tracking service, which uses cookies to track non-personally identifiable information about our visitors to our Site in the aggregate to capture usage and volume statistics. Some of our business partners (e.g., Google Analytics) use cookies on our Site.

In addition to cookies, we and our partners use similar technologies to analyze trends, administer the website, tracking users' movements around our Site, and to gather demographic information about our user base as a whole.

You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g. Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain site features and will have to enter your personally identifying information manually more often. If you choose to lease or make an offer on a domain name on our Site, we collect information about these behaviours.

Our Legal Basis for Processing Your Personal Information

Whenever we process your personal information we have a "legal basis" for what we do. The different legal bases we rely on are:

• Consent: If you have told us you are happy for us to process your personal information for a specific purpose.
• Legitimate Interests: If the processing is necessary for us to conduct our business, but not where our interests are overridden by your interests or rights.
• Performance of a Contract: If we must process your personal information in order to be able to provide you with one of our products or services.
• Prevention of Fraud: Where we are required to process your data in order to protect us and our customers from fraud or money laundering.
• Public Information: Where we process personal information which you have already made public.
• Legal Claims: The processing of your personal information is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.
• Legal Obligation: We are required to process your personal information by law.

When You Submit an Offer or Inquiry Through Our Website or the Venture.com System

When you submit an offer or inquiry via our Site or the Venture.com system, we ask you for your name, contact telephone number and email address.

We use this information to respond to your offer or inquiry, including among other things, providing you with any requested information about the requested domain name and our services. We may also email or call you several times after your inquiry in order to follow up on your interest and ensure that we have answered it to your satisfaction. We will do this based on our legitimate interest in providing accurate information prior to a lease or transaction.

Your inquiry is processed and logged on a CRM system on a cloud server based in Canada; a country, which the EU says has adequate data protection laws in place to protect your data.

We do not use the information you provide to make any automated decisions that might affect you.

When You Lease a Domain Name through Venture.com

To fully use our services, you will need to register for an account. During this process, you are required to provide us with your contact information and other personal information such as your name, email address, and billing address.

When you lease a Domain Name online, we ask you for your name, address, contact telephone number, email address and credit card information or banking information. We also record your IP (Internet Protocol) address, which is the address of your computer on the Internet.

We will use your information to verify your credit card details to process your order and may provide certain information to a third-party escrow provider to handle the financial transaction. We may use your telephone number to contact you regarding your lease fee. We require this information in order to process your payment, deliver your products or services and fulfil our contract with you.

When you successfully lease a domain name, we may also collect some additional information including name servers, administrative contacts, business identification, and other information for registrars.

Your information is stored on our website and on our cloud server, both of which are based within the European Union. Your credit card details are passed to a third-party payment processor which is based in the USA and is certified to the EU-US Privacy Shield (which requires effective safeguards for your information). We do not retain your credit card information.

We do not use the information you provide to make any automated decisions that might affect you.

When You Submit a Review

When you submit a review about us we record your name, your email address and your IP (Internet Protocol) address, which is the address of your computer on the Internet.

We use this information to provide verified independent views about our services to potential customers. Your name and the content of your review (but not your email address or IP address) may be publicly displayed on our website. We will do this based on our legitimate interest in marketing our services.

We do not use the information you provide to make any automated decisions that might affect you.

Your personal data is stored for as long as we are marketing the product or services that the review refers to, after which it is deleted. You may ask us to remove your review at any time.

When You Take Part in a Feedback Survey

When you take part in our feedback survey, we record your name, your email address, your organisation name, your job role and your answers to questions we ask about your opinion of, and use of, our products and services.

We use this information to develop and improve our products and services and our customer relationships. Your name and title and some or all of your comments may be publicly displayed on our website as a testimonial. We will do this based on our legitimate interest in marketing our products and services.

We do not use the information you provide to make any automated decisions that might affect you.

Your personal data is stored for three years, or for as long as we are marketing the services that the review refers to, whichever is shorter. You may ask us to remove a testimonial that is based on your feedback from our website at any time.

Links to Other Sites

Our Site includes links to other web sites whose privacy practices may differ from those of our Policy. Please note that if you submit personal information to any of those sites, your information is governed by their privacy policies. Be sure to carefully read the privacy policy of any website you visit while online.

Your Rights as a Data Subject or Customer

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.

If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.

Also you may always submit a request regarding your personal data by email, post or telephone, please use the contact information provided below.

Your Right to Complain

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. To do so, please email legal@venture.com or call us at (778) 328-2866.

Updates to this Policy

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

We will update the date of this document each time it is changed.

Effective Date: January 27, 2020