PRIVACY POLICY [En Español]

Last Modified: April 6, 2009

A. Ventanabierta Privacy Policy
Ventanabierta, Inc. and its affiliates (collectively, "we", "our", "us" or "Ventanabierta") is committed to your privacy. This Privacy Policy applies to and governs data collection and usage on the Ventanabierta website (www.ventanabierta.com, the "Site"). It is intended to describe for you our practices regarding: We encourage you to read this Privacy Policy carefully when using the Site, or when providing information to us through the Site. You understand that by using Site you are accepting our practices as described in this Privacy Policy.

B. Our Collection and Use of Your Information
The following paragraphs describe the type of information that we collect on the Site, the reasons why we collect this information, and with whom we may share such information. By continuing to use the Site after having an opportunity to review this Privacy Policy, you have consented to our collection, use and sharing of the information as described in this Privacy Policy.
  1. Collection of Information


    1. Information You Provide to Us to Request Services Through the Site
      On our Site we make certain services available to you, and you have the option of providing us with your personally-identifiable information to request those services. These services may include, but are not limited to, information about various financial and other products and services offered by third parties.


    2. Correspondence Received Through The Site or Email
      If you correspond with us via email or through other communication channels we may make available on or through the Site, we may retain such correspondence and any information (including personally-identifiable information) contained therein (including, but not limited to, your email address). Since we cannot guarantee the confidentiality or security of information that you provide to us in an email that may travel over public networks, we recommend that you do not include information that you would consider to be confidential (such as your social security number) in an email that you send to us. If you do send an email, you agree that you do so in accordance with the terms and conditions of our Terms of Use.


    3. Cookies, Web Beacons, and Your Navigation Information
      Cookies are pieces of data that a website transfers to a user's hard drive to identify your computer as a unique user for record-keeping purposes. However, cookies cannot read data off of your computer's hard-drive. Web beacons are used in combination with cookies. A web beacon is an often-transparent graphic image, which is placed in an email or on a website. The information collected can be correlated to individual subscribers. We may also collect information about your IP address. When you request pages from the Site, our servers will log your IP address. With limited exceptions (specified in Section 2(c), below) we do not link IP addresses to any personally-identifiable information, which means that your session will be logged, but you remain anonymous to us.


  2. Our Use and Sharing of the Information Collected


    1. Information You Provide to Us to Request Services Through the Site
      If you provide us with personally-identifiable information to request products and services through the Site, we may share the information that you provide to us with third parties in support of your request for these services if you consent for us to do so. Our sharing of the personally-identifiable information that you provide to us in these instances will be governed and limited by the scope of the consent that we receive from you when you provide us with this information. When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.


    2. Correspondence Received Through The Site or Email
      We may use the information that we collect from your correspondences to us to respond to your inquiry and/or to notify you of various products and services, conferences, news or other Ventanabierta-related opportunities or those of our third party partners. Importantly, email and other contact information is never sold, given, or otherwise shared or disclosed to third parties except as set forth herein. If you do not wish to receive such notifications, you may express your preference to not be so contacted by sending a letter the Ventanabierta Corporate Offices at the contact information below informing us of your preference, or with respect to emails, by following the opt-out link contained in our emails.


    3. Cookies, Web Beacons, and Your Navigation Information
      Our Site may use cookies to provide enhanced functionality on the Site (e.g., user ID and password prompts) and aggregate traffic data (e.g., what pages are the most popular). Similarly, we may use web beacons to aggregate data to analyze the performance of an email and our Site. Although some information collected through the use of web beacons can be correlated to individual users of the Site, we use this data for internal marketing purposes only and do not share this data with third parties. We use information that we collect about your IP address to help diagnose problems with our server and to administer our Site, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. As is noted in Section 1(c), above, we do not normally link IP addresses to any personally-identifiable information. However, we can and will use IP addresses to identify you when we feel it is necessary to enforce compliance with our Terms of Use for this Site or to protect our service, Site, or others.

      You have many choices with regards to the management of cookies and web beacons on your computer. For example, all major browsers allow you to block or delete cookies from your computer. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.


    4. To Create Aggregated Data
      We may use any and all information that we collect on the Site, including:

      1. All personally-identifiable information that you provide to us to (A) request services from us or third parties or (B) in a correspondence to us through the Site or in an email; or


      2. All information (whether personally-identifiable information or otherwise) that we collect about your use or navigation of the Site through the use of cookies, web beacons, or the tracking of your Site navigation to compile aggregated, anonymous data for research and bench-marking purposes ("Aggregated Data"). We compile such Aggregated Data from the information described above, which we then render anonymous and not personally-identifiable by removing your name, address, e-mail address, and any other data that would personally identify you as an individual. We may share or otherwise disclose this Aggregated Data with our partners, service providers, advertisers and/or other third parties for marketing, research or promotional purposes.


  3. Other Restrictions on Disclosing Personally-Identifiable Information to Third Parties


    We are careful to limit the sharing of any personally-identifiable information that we collect on this Site. In addition to the instances specified in Section 2, above, we may reveal personally identifiable information about you to third-parties if: (a) the information is provided to comply with the law, enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; or (b) the information is provided to our agents, vendors or service providers who perform functions on our behalf (and who do so pursuant to agreements with us that prohibit their ability to use your information except to provide services for us).

    For the sake of clarity: the limitations specified in this Section 3 only apply to our sharing of your personally-identifiable information. We reserve and retain the right to share Aggregated Data (which is not personally identifiable) in accordance with the terms of Section 2(d), above.

C. Inapplicability of Privacy Policies of Any Linked Sites or Other Third Parties
This Privacy Policy only addresses our use and disclosure of information that we collect on or through this Site. This Site may contain links to other websites, and when you click on such links you are leaving this Site and entering the other websites. Please be aware that this Privacy Policy does not govern the privacy practices of any third party sites that may be linked to this Site. We are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of your personally-identifiable information. We encourage you to be aware that when you go to another website you should carefully read their privacy policy before using that site.

D. Our Security Measures to Protect Information
To help protect the privacy of data and personally-identifiable information you transmit through use of this Site, we maintain commercially reasonable physical, technical and administrative safeguards. We restrict access to your personally-identifiable information to those employees who need to know that information to provide benefits or services to you.

E. Children's Privacy
Our website is a general audience site, and we do not intend to market to or collect, nor do we knowingly collect, personal information from children under the age of 13. Unfortunately, we cannot always determine the age of a visitor to our Site or the sender of an email.

F. Conditions of Use, Notices and Changes to Our Privacy Policy
By using this Site, you agree to the terms and conditions contained in this Privacy Policy. If you do not agree to any of these terms and conditions, you should not use this Site or any Ventanabierta benefits or services. You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the Commonwealth of Massachusetts. Any legal action or proceeding relating to this Privacy Policy or your access to or use of this Site shall be instituted in a state or federal court in the Commonwealth of Massachusetts. You agree to submit to the jurisdiction of, and agree that venue is proper in these courts.

G. Revisions to This Privacy Policy
We reserve the right to amend the Privacy Policy and Terms of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on this Site. You should check our Site frequently to see the current Privacy Policy that is in effect and any changes that may have been made to it. The provisions contained herein supersede all previous notices or policies regarding our privacy practices that govern the use of this Site.

H. Questions Regarding the Privacy Policy and Conditions of Use
If you have any questions about our Privacy Policy or any concern about privacy at the Ventanabierta or the use of this Site in general, please send correspondence to the following address:

Privacy Matters
c/o Ventanabierta, Inc.
Cherokee Station
P.O. Box 20073
New York, NY 10021-0061

Privacy Policy Last Updated: April 6, 2009