BONAVENTURE PRIVACY POLICY

Bonaventure is committed to protecting your privacy. Please read this Privacy Policy, as well as our Terms of Use Agreement, for more details about how we use information you submit to the Bonaventure Website located at WWW.BONAVENTURE.COM (the “Website”).  This Privacy Policy, together with the Terms of Use Agreement, constitutes the entire agreement between you and Bonaventure relating to the Website.  By your use of the Website, you consent to be governed by this Privacy Policy.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO USE THE WEBSITE.

Bonaventure may revise this Privacy Policy at any time.  Any Privacy Policy revisions will be effective upon posting to the Website.  You should review this Privacy Policy, each time you visit the Website to inform yourself of any revisions.  Your continued use of the Website will constitute your acceptance of the Privacy Policy as revised.  If you have any questions about this Privacy Policy, please contact webmaster@bonaventure.com.

Last Updated: 8/1/2023

WHAT TYPES OF INFORMATION DO WE COLLECT?

1. Personally Identifiable Information:

You may choose to provide personal information to utilize certain features of the Website, including Website applications online and possibly to conduct other activities on the Website (“Services”).  You may be required to register and provide accurate information about yourself to the Website to use such Services. Services may not work properly without accurate information.

When using the Services, we may ask you to provide all or some of the following information: your name, your address, your email address, and your telephone number (“Personal Information”).  It is Bonaventure’s intent to guard any Personal Information that you provide via the Website from unauthorized disclosure by reasonable technological measures.  Personal Information provided to Bonaventure is not, however, protected by encryption technology, and we cannot ensure that all of your Personal Information will never be disclosed in unintended ways.  We do not give or sell Personal Information that identifies you and that you provide to us to any third party, except as required by law or as necessary to provide services to our customers.  If you have any questions about your Personal Information, please contact webmaster@bonaventure.com.

2. Non-Personally Identifiable and Aggregated Information:

When visiting the Website or using the Services, and to evaluate the Website and ensure that we are providing content and Services of interest to you, we may collect and aggregate non-personally identifiable information (“Non-Personal Information”).  Non-Personal Information includes any information from which your identity is not readily ascertainable, and may include statistical information regarding how you use the Website, the numeric address assigned to the computer you are using (your “IP address”), browser, operating system, pages or content you access while visiting the Website and the date and time of such access.  The aggregated information we collect will not identify you personally, but we may share this aggregated, statistical information with third parties.

Cookies

From time to time Bonaventure may place a cookie on your computer.  A “cookie” is a small line of code that is stored in your browser when you visit a cookie-enabled website.  A cookie allows us to track and keep records of user activity.  Most browsers are initially set to accept cookies.  If you set your browser to reject cookies, some parts of the Website may not function properly.  Moreover, to use the Services, your browser must accept cookies.

In some cases we may also track or collect information about your use of the Website by small, 1-pixel gifs (Web bugs), your IP address, or by the URLs that you come from or leave to.  These methods allow us to analyze trends across the Website, to resolve server problems, and to administer the Website.  We use this information for internal analysis and do not associate this information with any other Personal Information that you may have provided us.

Web Analytics

Bonaventure uses web analysis services provided by third parties that utilize cookies to monitor website traffic.  Bonaventure uses these services to collect, track and examine data about the Website.  We may run reports based on the data we collect and we may share the data with other service providers.  Our web analysis service providers may use the data to personalize and customize the advertisements that are served to you from advertising networks. The Website does not respond to “Do Not Track Signals” from your browser.

Disclosure for Lawful Purposes

Bonaventure reserves the right to access and disclose Personal Information, Non-Personal Information or Aggregated Information to comply with applicable laws and lawful government requests, to operate its systems properly, or to protect itself or others. Bonaventure may attempt to obtain the prior consent of the individual before disclosing Personal Information, but it has no obligation to do so.

Links to Third-Party Sites

A small number of Bonaventure Website pages contain links that may take you outside of our Website to other Internet locations, such as third-party websites. Bonaventure’s Website application submission capability may be outsourced to a third party.  You should be aware that such third parties may collect data from or about you, which is beyond Bonaventure’s control.  Bonaventure is not responsible for any use or misuse of personal information by such third parties.  We recommend that you view the privacy policy posted on each website that you use to confirm that the site’s policies are acceptable to you.

Notification of Changes

Bonaventure reserves the right to modify this Privacy Policy at any time. Please review this Privacy Policy from time to time to ensure your familiarity with its terms. If you have any questions about this Privacy Policy, please contact webmaster@bonaventure.com.

Who We Share Your Information With

Bonaventure may share certain information to service providers we use to support our business.  All of our service providers are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.  Bonaventure may also share or transfer Personal Information you provide to us or that we collect with other entities that Bonaventure may acquire, or with entities that may acquire Bonaventure, or with entities with which Bonaventure merges or partners.

Retention of Your Communications to Bonaventure

Bonaventure may retain your questions and feedback in order to improve our Services.  Accordingly, do not send Bonaventure any information, ideas, suggestions, proposals or comments that you consider confidential or that you wish to be treated as confidential.

Retention of Your Personal Information

We will retain your Personal Information as long as you remain registered with the Website, and as necessary to provide you with the Services or as otherwise set forth in this Privacy Policy.  We will also retain and use your Personal Information as necessary for the purposes set out in this Privacy Policy and to the extent necessary to comply with Bonaventure’s legal obligations, resolve disputes, enforce our agreements and protect Bonaventure’s legal rights.  Bonaventure also collects and maintains aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of Bonaventure, improve our Services or comply with legal obligations.

Your Rights

You have the right to be informed of the Personal Information processed by Bonaventure, and a right to the rectification, correction, and erasure, of certain Personal Information.  You may also opt-out of the processing of your Personal Information for purposes of targeted advertising, profiling, or the sale of your Personal Information. You also have the right to request from Bonaventure a structured, common, and machine-readable format of the Personal Information you provided to Bonaventure.  Bonaventure can only adhere to your request if you provide us Personal Information or data that enables us to confirm your identity and that you have used the Website or Services.  To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of personal data you may contact Bonaventure at webmaster@bonaventure.com. In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.

Security

Bonaventure will undertake reasonable steps to protect all information, including Personal Information, from unauthorized or accidental access, disclosure, misuse or processing, or from alteration, destruction, or loss.  However, because no security measures are perfect or impenetrable, we cannot guarantee the security of information you submit to us.

Children’s Privacy

The Website is not intended for children under eighteen (18) years of age, and Bonaventure does not knowingly collect personal information from children under eighteen (18) years of age.  If Bonaventure learns we have collected or received personal information from a child under eighteen (18) years of age, without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under eighteen (18) years of age, please contact us.

International Users

Bonaventure is based in United States and the Website and Services are intended for users in the United States.  If you are accessing the Website or using the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use and disclosure that differ from United States law, your continued use of the Website or Services are governed by United States law and these terms.  Moreover, your continued use of the Website and Services indicate your consent to transfer of your personal information to the United States.

California Privacy Rights (For California Residents Only)

Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of customers’ Personal Information with third parties.  These businesses are required to accept requests for disclosures of these policies from customers but are only required to honor one request per calendar year.  Businesses have thirty (30) days to respond to each inquiry to the designated address.  Each inquiring customer will receive an explanation of the categories of customer information shared and the names and addresses of any third-party businesses.  In limited circumstances, customers’ failure to submit requests in the manner specified will not require a response from the business.

If you are a California resident, you may request such information from us by sending a letter to the address listed below.  In your letter, please provide your name, address and email address, as well as a request that we provide such information to you, by using the following or similar language, “I request that Bonaventure provide its third party information sharing disclosures required by Section 1798.83 of the California Civil Code.”

California Privacy Rights – California Consumer Protection Act (“CCPA”) and California Privacy Rights Act (“CPRA”)

We abide by California law where applicable for any California residents using the Website.  Under the CCPA/CPRA, you may make certain requests about your Personal Information, including to request access to and/or revision of certain Personal Information by contacting us as described below.  If you wish to limit the emails you receive from us, you may let us know by contacting us as described below.

Bonaventure is not currently a business that falls under the CCPA or CPRA.  Accordingly, Bonaventure need not currently comply with CCPA/CPRA.  However, Bonaventure is informing you of your general rights under that law should an occasion occur when Bonaventure must comply with CCPA/CPRA.  California consumers have the right to:

1. Request disclosure of the categories and specific pieces of Personal Information that a business has collected about you.
2. Request disclosure of the categories of third-party sources, if any, from which a business has collected Personal Information about you.
3. Disclosure of the business or commercial purpose(s) for which your Personal Information has been collected.
4. Receive a list of the categories of third parties with whom a business has shared your Personal Information.
5. Request that a business delete any Personal Information that it has collected from you (subject to exceptions).
6. Not be discriminated against by a business (e.g. charged different rates, provided different levels of service, denied goods or services, or suggested any of the preceding) for exercising any of the individual rights granted above.
7. Designate an authorized agent to exercise any of the individual rights granted above, on your behalf.
8. Opt-out of the sale of the sale or sharing of their Personal Information, if applicable.

To exercise any of your rights as a California consumer, you may reach out to Bonaventure at webmaster@bonaventure.com.

If required, and before complying with your request, Bonaventure will need to verify that it is you that is making the request. To accomplish this, you (or your authorized agent) may be requested to (1) confirm specific pieces of Personal Information that Bonaventure already knows about you, or (2) provide Bonaventure with appropriate identification depending on the sensitivity of the information requested. California consumers are limited to two requests for Personal Information per twelve-month period.

Contact Information

If you have any questions regarding the information we collect or how we treat the information we collect pursuant to this Privacy Policy, or you wish to exercise your rights under this Privacy Policy, we encourage you to contact us at webmaster@bonaventure.com.  You may also reach us by telephone at 703-567-4590, or by mail at:

Bonaventure

Attn: Bonaventure IT Department

209 Madison Street, 4th Floor
Alexandria, VA 22314