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VENA SOLUTIONS PRIVACY POLICY

Last Updated: October 29th, 2020

 1.  Definitions
 2.  Scope
 3.  A Note About Children
 4.  Personal Information Collection and Use
 5.  Updating or Removing User Information
 6.  Information Collected on Behalf of our Clients
 7.  Law Enforcement; Subpoenas
 8.  Service Providers
 9.  Cookies and other Tracking Technologies
 10. Change of Ownership
 11. Data Retention
 12. Residents of the European Economic Area (“EEA”)
 13. Dispute Resolution
 14. Changes to this Privacy Policy
 15. Contact details


Vena Solutions Inc and its group of companies (“Vena”/”we”/”us”) respects
privacy and values the confidence of users of our services (“Clients”). This
Privacy Policy (the “Policy”) sets forth the privacy principles that Vena
Solutions follows with respect to the handling and treatment of Personal
Information, as defined below.


DEFINITIONS

For the purposes of this Policy, “Personal information” means any information or
set of information that identifies or could be used to identify an individual or
is otherwise associated with that information. Personal information does not
include information that is encoded or anonymized, or publicly available
information that has not been combined with personal information.

“Non-Personal Information” is information of an anonymous nature, such as the
domain used to access the Website or Services, and the type and version of
browser or operating system being used by visitors to access the Website or
Services. Aggregate information, such as demographic statistics of our users
(e.g. average age or geographical location of our users), number of visitors,
what pages users access or visit, and average time spent on the Website or
Services is not considered Personal Information. Similarly, business contact
information such as the name, title, business address, e-mail address, or
telephone number of a business or professional person or an employee of an
organization is not considered Personal Information.

Although the use of certain Non-Personal Information collected, used or
disclosed through the Internet as described herein is not restricted (and to the
extent that such is the case, the obligations under this Policy do not apply to
such information), we provide information in this Policy about the collection of
such information for the sake of transparency with respect to the operation of
the Website and Services. Such Non-Personal Information is collected or derived
by us in the course of operating this Website and our Services. For example, our
servers may automatically collect Non-Personal Information that is provided
through your browser or stored in a cookie.


SCOPE

This Policy applies to www.venasolutions.com (the “Website”) and our cloud
application run as Software as a Service (SaaS) owned and operated by Vena
Solutions (collectively, the “Services”). This Policy describes how Vena
Solutions collects and uses the Personal Information through the Services. It
also describes the choices available to you regarding the use of, your access
to, and how to update and correct your personal information. Unless otherwise
specified in this Policy, the use of Personal Information collected through our
Services shall be limited to the purpose of providing the services for which the
Client has engaged Vena Solutions.


A NOTE ABOUT CHILDREN

The Services are intended for use by business users. Accordingly, we do not
intentionally gather Personal Information from minors including from visitors
who are under the age of 16. If a child under 16 submits Personal Information to
Vena and we learn that the Personal Information is the information of a child
under 13, we will attempt to delete the information as soon as possible. If you
believe that we might have any Personal Information from a child under 13,
please contact us at privacy@venacorp.com.


PERSONAL INFORMATION COLLECTION AND USE

We collect Personal Information for the primary purpose of fulfilling our
contractual obligations under our Terms of Use to provide our Services to you
when you register to use the Services, including for the following related
purposes:

• To administer your account

• To contact and correspond with you;

• To enable your use of the Services;

• To understand your needs and develop and recommend suitable products and
services;

• To process transactions and payments;

• To facilitate and enhance your use of the Website;

• To understand how you interact with and use the Website and Services and
improve the Website and Services; and

• To meet legal and regulatory requirements.


For example, when using the Services, including registering for the Services,
you may be required to provide us with contact information or account
registration information which includes but is not limited to your name, email
address, phone number, and company name. The information you provide will be
used by us to administer your account, send you marketing emails, respond to
your questions, and fulfill your business requests while using our Services. If
you wish to subscribe to our newsletter(s), we will use your name and email
address to send the newsletter to you. You may choose to stop receiving our
newsletter or marketing emails by following the unsubscribe instructions
included in these emails, accessing the email preferences in your account
settings page, or you can contact us using the contact information found at the
bottom of this Policy.

We will share your Personal Information with third parties only in the ways that
are described in this Policy.


UPDATING OR REMOVING USER INFORMATION

You may, at any time, choose to correct or update the information you have
submitted to Vena, by updating your account on our Website or by contacting us
at privacy@venacorp.com.  You can also contact us at privacy@venacorp.com with
other requests related to your data. If your details are provided through a
corporate account, then you may need to contact the administrator of that
corporate account.

We will retain Personal Information we process on behalf of our Clients for as
long as needed to provide services to our Client(s) and to comply with our legal
obligations, resolve disputes, and enforce our agreements. If you cancel your
account, your Personal Information along with other information may be retained
in our archive or backup records. Please see Data Retention below.


INFORMATION COLLECTED ON BEHALF OF OUR CLIENTS

Vena Solutions collects information under the direction of its Clients, and has
no direct relationship with the individuals whose Personal Information it
processes. If you are a customer or employee of one of our Clients and would no
longer like to be contacted by one of our Clients that use our Services, please
contact the Client that you interact with directly.


LAW ENFORCEMENT; SUBPOENAS

Vena may disclose Personal Information, including the information you submit to
the application service, with or without notice (a) if required by a subpoena,
bankruptcy proceedings, similar legal process or other judicial or
administrative order, (b) where required by law, or (c) at our sole discretion,
where we deem it necessary to protect the safety of any individual or the
general public or to prevent violation of our agreements or the rights of Vena
Solutions or any third party.


SERVICE PROVIDERS

As at the date of this Policy, we share Personal Information about you in
respect of the Website and Services only with our service providers and partners
which include website hosting, cloud service providers, analytics providers,
email marketing providers and payment processors. Our service providers may host
data worldwide and accordingly your Personal Information may be available to
governments worldwide under a lawful order, irrespective of the safeguards we
have put in place for the protection of your Personal Information. In
particular, Vena Solutions uses the following third-party service providers that
process Personal Information on its behalf:

 * Amazon Web Services – Vena Cloud hosting provider
 * WPEngine – Marketing website hosting provider
 * GSuite – Corporate Email services
 * Marketo - Marketing service provider
 * Salesforce – CRM provider
 * SalesLoft – Sales engagement provider
 * Zendesk – Customer service provider

From time to time we may employ third parties to help us improve the Website
and/or the Service. These third parties may have limited access to databases of
user information solely for the purpose of helping us to improve the Website,
and/or the Service and they will be subject to contractual restrictions
prohibiting them from using the information about our members for any other
purpose. Unless we tell you differently, such third parties do not have any
right to use the Personal Information we share with them beyond what is
necessary for them to provide the tasks and services on our behalf.


COOKIES AND OTHER TRACKING TECHNOLOGIES

As is true of most websites, we gather certain information automatically. This
information may include Internet protocol (IP) addresses, browser type, internet
service provider (ISP), referring/exit pages, operating system, date/time stamp,
and/or clickstream data.

We and our partners use cookies or similar technologies to analyze trends,
administer the website, track users’ behaviour around the website.

System Logs & Cookies: Cookies are used by us to track content usage and traffic
on the Website. A cookie is a feature of your web browser that consists of a
text file that is placed on your hard disk by a web server. Cookies help us
compile aggregate statistics about usage of this Website and the Services, such
as how many users visit the Website, how long users spend viewing the Website,
and what pages are viewed most often. This information is used to improve the
content of the Website and App. You can set your browser to notify you when you
are sent a cookie. This gives you the chance to decide whether or not to accept
it. If you disable cookies, you may not be able to take advantage of all the
features of the Website, App or Services.

Your IP address is reported by your web browser whenever you visit a page on the
Website. This information is recorded together with your registration
information on our databases.



CHANGE OF OWNERSHIP

We may also disclose your Personal Information in connection with a corporate
re-organization, a merger or amalgamation with another entity, a sale of all or
a substantial portion of our assets or stock, including any due diligence
exercise carried out in relation to the same, provided that the information
disclosed continues to be used for the purposes permitted by this Privacy Policy
by the entity acquiring the information.


DATA RETENTION

We will keep your Personal Information for as long as it remains necessary for
the identified purpose or as required by law, which may extend beyond the
termination of our relationship with you. We may retain certain data as
necessary to prevent fraud or future abuse, or for legitimate business purposes,
such as analysis of aggregated, non-personally-identifiable data, account
recovery, or if required by law. All retained personal information will remain
subject to the terms of this Privacy Policy. If you request that your name be
removed from our databases, it may not be possible to completely delete all your
Personal Information due to technological and legal constraints.


RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”)

We generally process Personal Information in order to fulfill contracts we have
with our customers and to pursue our legitimate business interests listed above.
Otherwise, Vena Solutions will obtain consent from an individual in respect of
processing of Personal Information if required by law to do so. Further,
individuals located in the EEA have certain rights under European law (including
under the General Data Protection Regulation) (“EU Data Protection Law”) with
respect to Personal Information, including the right to request access to,
obtain, correct, amend, delete, or limit the use of your personal data.
Individuals located in to the EEA who wish to exercise these rights, should
contact Vena at privacy@venacorp.com. Individuals also have the right to make
complaints to regulatory authorities in respect of our privacy practices.

EU Data Protection Law sets out a number of different reasons for which we may
collect and process your personal data in certain circumstances. Where EU Data
Protection Law applies, the legal bases we rely upon include

 * Consent: We can collect and process your data with your consent, where
   required by the EU Data Protection Law. We will explain how we intend to use
   your personal information where we ask for your consent, and will only use it
   for that purpose. For example, if you have given your consent to receiving
   marketing material from us then we will provide you that marketing material.
   You can withdraw your consent at any time.
 * Contractual obligations: We need your personal data to comply with our
   contractual obligations. For example, where you have provided us with your
   email address to receive access to our Services, we will use this information
   in order to effectively deliver and communicate information to you in regard
   to such products and services. This type of information includes that set out
   in the “Personal Information Collection and Use” section above.
 * Compliance with legal obligations: If the law requires us to, we may need to
   collect and process your data for legal compliance reasons. For example, we
   can pass on details of people involved in fraud or other criminal activity.
 * Legitimate interest: We may require your data to pursue our legitimate
   interests or those of a third party in a way which might reasonably be
   expected as part of running our business and which does not materially impact
   your rights, freedom or interests. For example, it is in our legitimate
   interests to (a) ensure that content from our Websites are presented in the
   most effective manner for you and your computer and that we provide you with
   the information, products and services that you request from us, (b) to keep
   our Website and our Services safe and secure;(c) for measuring or
   understanding the effectiveness of advertising we serve to you and others,
   and to deliver relevant advertising to you (including individual and
   pseudonymous analysis and profiling); (d) to allow you to participate in
   interactive features of our Services (if applicable), and (e) to use
   marketing related information about you that we have lawfully collected.

If you are an EEA citizen, Personal Information hosted on our behalf is stored
in Ireland, however the Personal Information that we process in relation to you
may be transferred and stored by our third party service providers at
destinations outside the EEA that may not be subject to equivalent data
protection law. It may also be processed by staff situated outside the EEA who
work for us or for one of our suppliers.

We may transfer your personal data outside the EEA:

 * in order to host or store it;
 * in order to enable us to provide goods or services to and fulfil our contract
   with you or the company you work for;
 * where we are legally required to do so;
 * in order to facilitate the operation of our group of businesses, where it is
   in our legitimate interests and we have concluded these are not overridden by
   your rights.
 * Where your information is transferred outside the EEA, we take steps
   reasonably necessary to ensure that your data is subject to appropriate
   safeguards, such as where applicable relying on a recognised legal adequacy
   mechanism and contracts, to help ensure your rights and protections travel
   with your data and that your personal data is treated securely and in
   accordance with this Policy.

If you are an EEA Citizen, you have the following additional rights under
certain circumstances:

 * to be provided with a copy of your personal data held by us;
 * to request the rectification or erasure of your personal data held by us;
 * to request that we restrict the processing of your personal data (for
   example, while we verify or investigate your concerns about your
   information);
 * to object to the further processing of your personal data, including the
   right to object to marketing; and
 * to request that your personal data be moved to a third party.

In order to exercise these rights, you may contact us using the contact details
set out below. We may ask for further information to clarify your identity and
location. If you are a customer or employee of one of our Clients, please
contact the Client that you interact with directly, as in that circumstance we
will be acting as a data processor, not a data controller.


DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of personal
information should be directed to Vena Solutions at privacy@venacorp.com. Vena
Solutions will investigate and attempt to resolve complaints and disputes
regarding use and disclosure of Personal Information in accordance with the
principles contained in this Policy.


CHANGES TO THIS PRIVACY POLICY

This Policy may be amended from time to time, and appropriate public notice will
be given concerning material amendments or changes to this Policy. If we make
any material changes we will notify you by email (sent to the e-mail address
specified in your account) or by means of a notice on the Website prior to the
change becoming effective. We encourage you to periodically review this page for
the latest information on our privacy practices.

Access and Accuracy: You have the right to access the Personal Information we
hold about you in order to verify the Personal Information we have collected in
respect to you and to have a general account of our uses of that information.
Upon receipt of your written request, we will provide you with a copy of your
Personal Information although in certain limited circumstances, we may not be
able to make all relevant information available to you such as where that
information also pertains to another user. In such circumstances we will provide
reasons for the denial to you upon request. We will endeavor to deal with all
requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate
and up-to-date, and we will provide you with mechanisms to update, correct,
delete or add to your Personal Information as appropriate. As appropriate, this
amended Personal Information will be transmitted to those parties to which we
are permitted to disclose your information. Having accurate Personal Information
about you enables us to give you the best possible service.

Upon request Vena will provide you with information about whether we hold, or
process on behalf of a third party, any of your Personal Information. To request
this information please contact us by telephone or email.


CONTACT DETAILS

If you wish to contact us regarding our processing of your personal information,
you may may do so using any of the following:

email:privacy@venacorp.com.

phone: 1.855.434.2814

address: 2 Fraser Avenue, Suite 200, Toronto, ON, Canada, M6K 1Y6

Why Vena
Platform Capabilities Reporting & Analytics Modeling Workflows Collaboration
Scalability & Security Central Database
Microsoft Excel Power BI Microsoft 365
Integrations Developers
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Solutions Financial Planning & Analysis Budgeting & Forecasting CapEX Planning
Revenue Planning Workforce Planning Allocations Scenario Planning Cash Flow
Planning Rolling Forecast
Sales Performance Management Sales Planning Incentive Compensation Management
Financial Close Management Financial Consolidation Account Reconciliation
Financial Reporting Management Reporting Profitability Analysis Variance
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Higher Education Healthcare Professional Sports Not for Profit Professional
Services
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