Venturu Privacy Policy

Last Updated: September 21, 2026

Welcome to Venturu, Inc. (“Venturu,” “we,” “us,” or “our”). We recognize the importance of protecting your personal information and strive to be transparent in how we handle data. This Privacy Policy describes how we collect, use, share, and safeguard information when you visit or use our website www.venturu.com and other related online and offline services that link to this Privacy Policy (collectively, the “Service”).

By using our Service, you agree to the collection, use, disclosure, and processing of personal information as described in this Privacy Policy. If you do not agree with our practices, please discontinue use of our Service. If you are in New Zealand, section 9.2 applies to personal information covered by the Privacy Act 2020, and it prevails where it differs from another part of this Policy.

1. Introduction

Venturu provides a digital marketplace and transaction platform that helps buyers, sellers, brokers, and other stakeholders connect around small and medium-sized businesses (SMBs). We also partner with various third parties, including MLS services, identity verification providers (such as Onfido), and payment processors to facilitate listings, transactions, and additional services.

2. Information We Collect

We collect personal information that you provide directly, information that is automatically collected when you interact with our Service, and information from third parties where permitted by law.

2.1 Information You Provide

1. Contact and Identification Details

   • Name
   • Email address
   • Phone number
   • Login credentials (username, password)
   • Identity verification documents and information (e.g., driver’s license, passport) that may be processed by Onfido on our behalf

2. Business Information

   • SMB details (e.g., business type, location, industry)
   • Financial statements, tax records, or related business documents
   • Other documentation necessary for listings, valuations, or sales/purchases

3. Payment Information

   • Payment card details, billing and shipping addresses (processed through a secured third-party payment service)
   • Bank account information if relevant for certain transactions or payouts

4. Communications

   • Information you provide when contacting customer support or communicating via email, phone, or live chat
   • Content of messages and attachments you send to us

5. Preferences and Other Information

   • Any preferences you set for receiving communications or for how we handle your data
   • Any other information you choose to provide to us

2.2 Automatically Collected Information

When you access or use our Service, we automatically collect certain data about your device and usage:

• Device and Usage Details: IP address, browser type, operating system, mobile network information, device identifiers, and other diagnostic data.
• Log Data: Date and time of your visits, pages viewed, features used, and referral URLs (the webpage you visited before landing on our Service).
• Analytics: We may use third-party analytics tools (like Google Analytics) to collect information about your use of the Service, such as pages visited, time spent, and links clicked.
• Location Data: With your consent, we may collect precise geolocation information. Otherwise, approximate location data may be inferred from your IP address.

2.3 Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to:

• Recognize you and store your preferences
• Track interactions with our Service
• Analyze trends and gather demographic information
• Provide customized content and advertising

You can manage cookies in your browser settings or through our “Cookie Preferences” tool (if provided on our website). However, disabling cookies may limit certain features or functionality of our Service.

3. How We Use Your Information

We use personal information collected for a variety of legitimate business interests, including:

1. Service Provision and Operation

   • Creating and managing user accounts
   • Listing and displaying SMBs for sale or acquisition
   • Processing transactions, including verifying identities through Onfido and facilitating payments

2. Business Transactions

   • Enabling communication between buyers, sellers, brokers, and other interested parties
   • Providing escrow, inspection, or other transaction-related services

3. Customer Support and Communication

   • Responding to inquiries, troubleshooting issues, and providing technical assistance
   • Sending confirmations, updates, or administrative messages

4. Legal and Regulatory Compliance

   • Complying with applicable laws, regulations, legal processes, or enforceable governmental requests
   • Meeting requirements from MLS boards and other regulatory bodies

5. Fraud Prevention and Security

   • Detecting, investigating, and preventing fraud, spam, abuse, or other unauthorized activity

6. Service Improvement and Personalization

   • Conducting analytics, research, and surveys to improve or personalize the user experience
   • Maintaining and enhancing the safety and security of our Service

7. Marketing and Advertising

   • Sending marketing communications about our products and services
   • Showing you relevant content or ads based on your activities, subject to your choices
   • Important Note: We do not use confidential SMB documents (such as financial statements or tax records) for marketing or advertising purposes unless you explicitly instruct us to do so.

8. Other Purposes

   • Fulfilling any other purpose for which you provided the information
   • For any other purpose disclosed to you at the time we collect your information

4. Data Storage and Security

We take reasonable and appropriate measures to protect personal information from loss, theft, and unauthorized use, disclosure, or modification:

• Encryption: Data in transit is encrypted using TLS (Transport Layer Security). Sensitive data at rest (e.g., financial records) is encrypted on AWS S3.
• Access Controls: Only authorized personnel have access to personal data; access is granted based on role and business need.
• Regular Assessments: We conduct periodic security reviews and monitor systems for potential vulnerabilities.

Please note that no method of transmission or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

5. Information Sharing and Disclosure

We may share your information with third parties in certain circumstances:

5.1 Service Providers

• Identity Verification Providers: Onfido for verifying government-issued documents.
• Cloud Hosting: Amazon Web Services (AWS) for data storage and hosting.
• Payment Processors: To handle payments, refunds, or payouts securely.
• Communication Tools: Email, SMS, or chat service providers.

5.2 Business Partners

• Buyers, Sellers, Brokers: To facilitate transactions, where you have indicated interest, made a request, or otherwise provided consent.
• MLS and Affiliated Platforms: We may list relevant information about a business (excluding sensitive personal data) on affiliated marketplaces or MLS platforms if applicable.
• Professional Advisors: Lawyers, accountants, or auditors, but only to the extent necessary for them to provide services to us.

5.3 Legal Requirements and Protection

We may disclose data if necessary to comply with legal obligations, protect our rights, or respond to lawful requests by public authorities (including to meet national security or law enforcement requirements). Examples include:

• Law enforcement agencies
• Regulatory bodies
• Courts and government authorities

5.4 Business Transactions

In the event of a merger, acquisition, reorganization, or sale of assets, your data may be transferred as part of that transaction, subject to appropriate confidentiality and data protection measures.

5.5 With Your Consent or At Your Direction

We may share your information with other third parties when you provide explicit consent or request us to do so.

6. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request details about the personal information we hold about you.
• Correction: Ask us to correct inaccurate or incomplete information.
• Deletion: Request deletion of personal data, subject to legal exemptions.
• Withdrawal of Consent: Where processing is based on consent, you can withdraw it at any time.
• Opt-Out of Marketing: Unsubscribe from marketing communications by following instructions in the message or contacting us.
• Data Portability: In certain cases, request a copy of your data in a machine-readable format.
• Objection or Restriction: Object to or request the restriction of processing under certain circumstances.
• Lodge a Complaint: File a complaint with a supervisory authority, if applicable in your jurisdiction.

You can often update or delete account information by logging in to your account or by contacting us directly at privacy@venturu.com. If you are in New Zealand, section 9.2 describes your access and correction rights and how quickly we will respond.

7. Data Retention

We retain personal information as long as it is necessary to fulfill the purposes for which it was collected, or as required by relevant laws and regulations. Retention periods vary depending on operational, contractual, and legal obligations. Once retention is no longer required, we will securely delete or de-identify the information. Where the Privacy Act 2020 applies, we will not keep personal information for longer than is required for the purposes for which it may lawfully be used.

8. Children's Privacy

Our Service is not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If you become aware that a minor has provided personal information to us, please contact us at privacy@venturu.com so we can remove the information.

9. International Data Transfers

Your information may be processed in the United States or in other countries where our service providers have operations. Those countries may have different data protection rules than your country of residence. Where a law requires a specific safeguard or authorisation before we send personal information overseas, we follow that law. Sections 9.1 and 9.2 describe the additional rules for the European Union, the European Economic Area, and New Zealand.

9.1 GDPR and EU/EEA Residents

If you are located in the European Union (EU) or European Economic Area (EEA), we will process your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable laws. Where necessary, we will rely on appropriate legal bases (e.g., your consent, the necessity to perform a contract, or our legitimate interests) for the processing of your personal data. We also implement safeguards (such as Standard Contractual Clauses) for cross-border data transfers, if required.

Our Data Protection Officer is Luis Merchan. You can contact him at luis@venturu.com.

9.2 New Zealand — Privacy Act 2020

If you are in New Zealand, or we collect or hold your personal information while carrying on business in New Zealand, the Privacy Act 2020 applies. This section is our notice under information privacy principles 3 and 3A.

Who collects and holds your information. The agency is:

Venturu, Inc.
2112 Alton Road
Miami Beach, FL 33140, USA

Our privacy officer under section 201 of the Privacy Act 2020, who is also our Data Protection Officer, is Luis Merchan. Email: luis@venturu.com. You may also email privacy@venturu.com.

What we collect, and why. We collect the information described in section 2 for the purposes in section 3. We collect it from you when you give it to us. We may also collect it from someone else, such as a broker, another party to a listing, a public source, or a service provider.

Who may receive it. We may disclose it to the recipients in section 5, including buyers, sellers, brokers, and service providers. Some of those recipients are outside New Zealand. The overseas-disclosure rules below apply to that disclosure.

Whether you must provide it. Providing personal information is voluntary, unless a particular law requires it. If you do not provide information we ask for, we may be unable to open your account, verify your identity, publish a listing, send an inquiry, take a payment, or provide the part of the Service that needs that information.

If we collect it from someone else. When we collect personal information about you from someone other than you, we will take reasonable steps to make sure you know the matters in this section, unless the Privacy Act 2020 does not require us to. Examples include where the information is publicly available, you have already been told, or telling you would not be reasonably practicable.

Access and correction. You may ask whether we hold personal information about you, and you may ask for access to it. You may ask us to correct it. If we do not make the correction, you may give us a statement of the correction you want and ask us to attach it so that it will be read with the information. We will respond as soon as reasonably practicable, and within 20 working days, unless the Act allows more time. If we grant access, we will tell you that you may request a correction. Email luis@venturu.com or privacy@venturu.com. We may need to confirm your identity first.

Use, accuracy, security, and retention. We use and disclose personal information for a purpose it was collected for, or a directly related purpose, or where the Privacy Act 2020 otherwise allows it. Before we use or disclose it, we take reasonable steps to check that it is accurate, up to date, complete, relevant, and not misleading. We protect it with reasonable security safeguards against loss, unauthorised access, use, modification, or disclosure, and other misuse. We do not keep it longer than those purposes require.

Unique identifiers. We may assign an account identifier where we need it to operate the Service efficiently. We do not adopt, as our own identifier, a unique identifier that another agency has assigned to you. We will not require you to disclose a unique identifier assigned by another agency except for a purpose for which that identifier was assigned, or a directly related purpose.

Overseas disclosure. We disclose personal information to a person or organisation outside New Zealand, including in the United States, only where information privacy principle 12 allows it. That means either:

• we believe on reasonable grounds that the recipient must protect the information in a way that, overall, provides comparable safeguards to the Privacy Act 2020, including under a contract with us; or
• you authorise that particular disclosure after we expressly tell you that the recipient may not be required to protect the information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020.

Accepting this Policy is not, by itself, that authorisation. Where we need your authorisation, we will ask for it separately and include that warning. Where a service provider holds information only as our agent and only to provide a service to us, we treat that information as the Privacy Act requires for agents, and we require the provider not to use or disclose it for its own purposes.

Commercial electronic messages. We send a commercial electronic message to a New Zealand address only with consent under the Unsolicited Electronic Messages Act 2007. The message identifies Venturu and includes a working unsubscribe option. You may also opt out by emailing us. You may complain to the Department of Internal Affairs.

Notifiable privacy breaches. If a privacy breach has caused, or is likely to cause, serious harm, we will notify the Office of the Privacy Commissioner and affected individuals as soon as practicable, as Part 6 of the Privacy Act 2020 requires.

Complaints. Please contact Luis Merchan at luis@venturu.com first. You may also complain to the Office of the Privacy Commissioner (privacy.org.nz). If that process does not resolve the complaint, you may be able to take it to the Human Rights Review Tribunal.

How we collect. We collect personal information by lawful means, and by means that are fair and do not intrude to an unreasonable extent on your personal affairs. That includes collection from children or young persons, though the Service is not directed to anyone under 18.

10. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or for other operational reasons. If we make material changes, we will notify you by revising the “Last Updated” date at the top of this Policy or by other appropriate means. We encourage you to review this page periodically.

11. California and Other U.S. State Privacy Rights

Certain states grant additional privacy rights to residents. Below is a summary (note that your specific rights depend on your state of residence):

1. Right to Know or Access: You can request details about the personal information we’ve collected about you and how we have processed or shared it.
2. Right to Delete: You may request that we delete your personal information, subject to certain exceptions.
3. Right to Opt-Out of “Sales” or “Sharing” for Targeted Advertising: We do not sell personal information for monetary consideration. However, some of our advertising practices may be considered “sharing” or “sale” under state laws. You can opt out of such tracking or targeted advertising by adjusting your cookie preferences or emailing us.
4. Right to Correct: You can request corrections to inaccurate personal data we maintain about you.
5. Right to Non-Discrimination: We will not discriminate against you for exercising your state-specific privacy rights.

To exercise any of these rights, please email privacy@venturu.com or use any self-service tools we may provide. We will verify your request by matching information you submit with data in our systems.

12. Third-Party Tracking and Advertising

We may allow third parties to set cookies or use similar technologies on our Service to collect information about your online activities over time and across different sites for the purpose of delivering targeted advertising. You can control interest-based advertising and the use of cookies through:

• Browser cookie settings
• Our “Cookie Preferences” tool, if available
• Opt-out tools provided by industry groups such as the Network Advertising Initiative or the Digital Advertising Alliance

13. Do Not Track

We do not respond to “Do Not Track” signals at this time. You can manage your tracking preferences using browser settings and third-party opt-out tools.

14. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Venturu, Inc.
2112 Alton Road
Miami Beach, FL 33140, USA

Privacy Officer and Data Protection Officer: Luis Merchan
Email: luis@venturu.com

Privacy inbox: privacy@venturu.com
Phone: +1 (917) 232-1610

Thank you for reading our Privacy Policy. By continuing to use our Service, you acknowledge that you have read and understood this Policy.