Privacy Policy

1. Your Privacy: Overview

This privacy policy (this “Privacy Policy”) tells you about the information that SemperVirens Ventures LLC (“SV,” “we,” “us” or “our”) collects in connection with the operation of our websites, products, services and software (collectively, the “Service”), how the information is used and how you can access and correct certain information that we may collect.

Please note that this Privacy Policy applies only to information collected from you by SV via the Service. It does not apply to information obtained or disclosed in offline correspondence or through other personal contacts with SV representatives. Further, the Service may contain links to other entities’ websites that are not controlled or operated by SV. This Privacy Policy does not apply to such third party websites, and SV is not responsible for the content of such third party websites or the privacy practices of such third parties. Therefore, we encourage you to request and review the privacy policies of any third parties upon disclosing your information to such parties or visiting such third party websites. Furthermore, please note that if you are using a “jailbroken” device or have otherwise circumvented the encryption, security or other capabilities of your device used to access this website, we cannot guarantee that we will be able to meet the requirements of this Privacy Policy that result from your use of such a device.

This Privacy Policy is effective as of April 22, 2021

2. Collection of Your Information

Certain information (primarily your IP address) is automatically collected when you access the Service, as discussed in our Cookie Policy (see Section 7, below), unless you opt out of such collection. Otherwise, you can access some areas of the Service without submitting any personally identifiable information. SV collects additional personally identifiable information only if you choose to complete any online forms to contact us, complete an account profile (MyBenefits), post content, provide feedback, or request information or assistance through the Service. The personally identifiable information that SV collects through these portions of the Service may include your name, username, password, email address, address and telephone number and any other personally identifiable information that you choose to include in your account profile or in your submissions to us. You represent and warrant that you have the right and authority to provide any information provided by you. SV may also collect certain non-personally identifiable information in connection with the operation of the Service. Such information is maintained by SV or service providers acting on behalf of others. Users of the Service may be able to view your information.

3. Protection of Your Information

To prevent unauthorized access or disclosure, maintain data accuracy and facilitate the appropriate use of information, SV uses physical, technological and administrative procedures to attempt to protect the personally identifiable information we collect through the Service. Nevertheless, Internet transmissions are never completely private or secure. You understand that any messages or information you send to the Service may be read or intercepted by others. If you have any questions about the security of personally identifiable information collected by SV, please contact us at: contactus@sempervirensvc.com

4. Use of Your Personally Identifiable Information

Upon our collection of your personally identifiable information, SV may use such personally identifiable information internally, separately or in combination with pre-existing information, for the following purposes:

To provide any requested information, products or services;
To access your account profile (MyBenefits), as directed by you;
To troubleshoot problems with the Service;
To customize your experience on the Service;
To enforce our Terms of Service Agreement or compliance with this Privacy Policy; or
To contact you with more information about your SV products or services.

5. Disclosure of Your Information

We may disclose your personally identifiable information to our subsidiaries or affiliates and to third party partners whom we occasionally hire to provide services on our behalf, including support services, website services, delivering promotional materials, answering customer questions about our services and new services. SV will only provide those third party partners with the personally identifiable information they need to deliver the services to us and/or on our behalf, and they will be contractually prohibited from using that information for any other purpose. In the event that SV is involved in a transaction such as a merger, stock purchase or sale, or sale of substantially all of SV assets, your personal information may be transferred to the other party in such transaction.

SV reserves the right to disclose your personally identifiable information if required to do so by law or legal process or otherwise requested by any law enforcement officer or agency acting under color of law. In addition, SV reserves the right to disclose your personally identifiable information based on the good faith belief that such action is necessary or appropriate to: (a) protect and defend the rights or property of SV, or (b) act in urgent circumstances to protect the safety or security of the public or of users of the SV products and the Service.

6. Cross-Border Data Transfers

If you choose to use our Service from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personally identifiable information outside of those regions to the U.S. for storage and processing, which does not have the same data protection laws as your jurisdiction. When we transfer your personally identifiable information to the U.S., we take steps to comply with applicable data protection law, in particular legal requirements regarding adequate protection for data transfers. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Service. By providing any information, including personally identifiable information, on or to the Service, you consent to such transfer, storage, and processing.

If you are located in the European Economic Area (“EEA”) or the United Kingdom, we will comply with applicable EEA data protection law when transferring your personally identifiable information outside of the EEA. We may transfer your personally identifiable information to countries which have been found to provide adequate protection by the EU Commission (e.g., Switzerland and Canada), use contractual protections for the transfer of personally identifiable information, or transfer to recipients who have certified to the Privacy Shield or adopted Binding Corporate Rules. For more information about how we transfer personally identifiable information outside of the EEA, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us as specified below.

7. Cookies

SV uses cookies to gather information about your visits to the Service in order to enhance your experience. Through this process, we collect your IP address. A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the Service and that information helps us to understand your preferences and improve your experience with the Service. Cookies are also used for such activities as remembering your user name and password, if necessary. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Mozilla, Firefox, or Internet Explorer). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the Service.

8. Website Analytics

SV may use Google Analytics and other similar services to help analyze how you use the Service. These analytic services use cookies (as defined in Section 7 above). The information generated by the cookie about your use of the Service is transmitted to the service. This information is then used to evaluate various uses of the Service and to compile statistical reports on Service activity for us, and us alone.

9. No Spyware or Adware

We do not install any spyware or adware in connection with our Service or distribute any commercial message, or authorize any third party to distribute any commercial message, by means of spyware or adware. “Spyware” or “adware” is any software which has been downloaded to or installed on an Internet user’s computer or device, without the user’s actual consent, and facilitates the distribution of any commercial message to the user. If you feel you may have spyware from another company installed on your machine or device, there are various anti-spyware/adware software applications available on the Internet to identify if this has occurred.

10. User Generated Content

If you use a Service message board, chat room, instant messenger or post any User Generated Content (as defined in the Terms of Service) you are solely responsible for the content of your messages. You should be aware that when you voluntarily disclose personally identifying Information (for example, your name, street address, email address, or telephone number) on the Service, that information can be read, collected and used by other users of the Service and may result in unsolicited messages, both commercial and otherwise. You agree that by participating in such online public forums, you will not use such forums for any purpose that is unlawful or prohibited by the SV community guidelines that may be in effect from time to time in connection with the Service. We reserve the right to terminate your access to the Service or to take other protective steps if you violate these terms.

11. Privacy Notice for California Residents

This notice reflects our understanding of the law as of the date set forth above. We may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.

A. Applicability and Scope

This California Consumer Privacy Act Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to our other privacy policies or notices. In the event of a conflict between any SV policy (including other sections of this Privacy Policy), statement or notice and this Notice, this Notice will prevail as to Consumers and their rights under the CCPA.

This Notice covers the collection, use, disclosure, and sale of Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA.

For example, the CCPA does not apply to “protected health information” collected by a “covered entity” or “business associate” as those terms are defined in the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

This Notice sets forth our privacy practices as required by the CCPA in those limited circumstances where we are not providing you services that are subject to HIPAA or other applicable law that the CCPA exempts.

B. Collection of PI: Categories and Sources, and Purposes for Collection

We have collected PI in the past 12 months in the categories listed below, and may continue to collect PI about Consumers, including:

1. Identifiers

Category of PI

This may include but is not limited to: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Sources of PI

Third party systems and/or services used by Consumers
SV’s products and/or services selected by Consumers
Directly from Consumers
Activity on SV’s websites
Recruiting service providers
Employment screening service providers
City, State, Federal and other government agencies

Business Purposes for PI

Delivering Services to Consumers

Research and Development

Security and Fraud Prevention

Auditing transactions, data processing and/or provision of Services
Debugging systems and products

Sales and marketing for SV’s products and services
Consideration of applications for employment by individuals to SV
Meeting compliance and regulatory requirements.

2. Personal Records (listed in Cal. Civ. Code § 1798.80(e))

Category of PI

This may include information such as: physical characteristics or description, signature, telephone number, education, employment, employment history, insurance policy number, bank account number, or any other financial information, medical information, or health insurance information.

Sources of PI

Third party systems and/or services used by Consumers or SV
SV’s products and/or services selected by Consumers

Directly from Consumers

Activity on SV’s websites

Recruiting service providers
Employment screening service providers
City, State, Federal and other government agencies

Business Purposes for PI

Delivering Services to Consumers

Research and Development
Security and Fraud Prevention
Auditing transactions, data processing and/or provision of Services
Debugging systems and products
Consideration of applications for employment by individuals to SV

Meeting compliance and regulatory requirements.

3. Consumer Characteristics

Category of PI

This may include, but is not limited to: sex, marital status, religion, veteran status, familial status, ethnicity and disability.

Sources of PI

Third party systems and/or services used by Consumers or SV
SV’s products and/or services selected by Consumers

Directly from Consumers

Activity on SV’s websites

Recruiting service providers
Employment screening service providers
City, State, Federal and other government agencies

Business Purposes for PI

Delivering Services to Consumers

Research and Development
Security and Fraud Prevention
Auditing transactions, data processing and/or provision of Services
Debugging systems and products

Consideration of applications for employment by individuals to SV

Meeting compliance and regulatory requirements

4. Customer Account Details / Commercial Information

Category of PI

This may include, but is not limited to: products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Sources of PI

Third party systems and/or services used by Consumers
SV’s products and/or services selected by Consumers

Business Purposes for PI

Delivering Services to Consumers
Research and Development
Consideration of applications for employment by individuals to SV

5. Biometric Information

Category of PI

This may include information that can be used to establish individual identity, such as fingerprints and face scans, from which an identifier template can be extracted, and other physical patterns such as sleep, health, or exercise data, that contain identifying info.

Sources of PI

Third party systems and/or services used by Consumers

Timekeeping service providers

Web forms submitted through SV’s websites
SV’s products and/or services selected by Consumers

Business Purposes for PI

Delivering Services to Consumers

Research and Development

6. Internet Usage Information

Category of PI

This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.

Sources of PI

Third party systems and/or services used by Consumers
SV’s products and/or services selected by Consumers

Activity on SV’s websites
Data processing and analytics service providers

Business Purposes for PI

Delivering Services to Consumers

Sales and marketing for SV’s products and services

Research and Development
Security and Fraud Prevention

Debugging systems and products

7. Geolocation Data

Category of PI

This may include, but is not limited to: physical location, IP addresses or other geolocation information.

Sources of PI

Third party systems and/or services used by Consumers
SV’s products and/or services selected by Consumers

Recruiting service providers
Employment screening service providers

Business Purposes for PI

Delivering Services
Security and Fraud Prevention
Debugging

8. Sensory Data

Category of PI

This may include, but is not limited to: audio recordings of customer calls, electronic, visual, or similar information.

Sources of PI

Directly from Consumers

Business Purposes for PI

Delivering Services to Consumers
Quality Assurance
Providing customer support

9. Professional or Employment Information

Category of PI

This may include, but is not limited to: professional, educational, or employment-related information.

Sources of PI

Third party systems and/or services used by Consumers

SV’s products and/or services selected by Consumers
Directly from Consumers
Recruiting service providers
Employment screening service providers

Business Purposes for PI

Delivering Services
Research and Development
Consideration of applications for employment by individuals to SV

10. Inferences from PI Collected

Category of PI

This may include, but is not limited to: creating a profile about a Consumer reflecting, among other things, the Consumer’s preferences, characteristics, behavior and aptitudes.

Sources of PI

Performance management systems
Recruiting service providers
Data processing and analytics service providers

Business Purposes for PI

Delivering Services to Consumers
Research and Development
Managing SV’s own employees

As permitted by applicable law, we do not treat de-identified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into de-identified data or aggregate consumer information. We have no obligation to re-identify such information or keep it longer than we need it to respond to your requests. This helps us practice data minimization, which we consider to be a privacy best practice consistent with our mission to respect our employees and customers.

C. Sharing of PI

We may share PI with our service providers, other vendors, and affiliates, as may be required in connection with the services that SV or any of its affiliates provides, including without limitation as follows:

1. Identifiers