Privacy Policy

Privacy Policy

1. Who We Are

SOZA Ventures LLC ("SOZA Ventures", "we", "us" or "our") is a Florida limited liability company.

SOZA Ventures LLC

Florida Document No. L23000542724

18117 Biscayne Boulevard #1434

Miami, FL 33160

United States

Email: hello@sozaventures.com

For purposes of applicable privacy laws, SOZA Ventures is the entity responsible for personal information collected through sozaventures.com unless a different entity is expressly identified.

2. Scope

This Privacy Policy applies to personal information collected through sozaventures.com and in connection with Consulting Services purchased directly from SOZA Ventures.

SOZA Ventures may own, operate or be associated with other brands, businesses, subsidiaries, affiliates or Portfolio Businesses.

Separate websites, platforms or services may publish their own Privacy Policies.

Where another service has its own Privacy Policy, that policy governs information collected through that service.

3. Personal Information We Collect

Information You Provide

When you contact us, submit a form or communicate with us, we may collect:

• name;
• email address;
• telephone number;
• company name;
• organization;
• job title;
• country;
• business information;
• contents of communications;
• documents voluntarily supplied to us; and
• other information you choose to provide.

Consulting Client Information

If you purchase or participate in Consulting Services, we may also process:

• company information;
• business objectives;
• market information;
• technical information;
• marketing information;
• project information;
• meeting and scheduling information;
• business materials provided for review;
• communications relating to the engagement; and
• other information reasonably necessary to provide the Consulting Services.

Purchase and Transaction Information

When you purchase Consulting Services, we may collect:

• customer name;
• company name;
• billing address;
• email address;
• service purchased;
• transaction amount;
• transaction date;
• payment status;
• transaction identifiers;
• limited payment method information; and
• information relating to refunds, disputes or chargebacks.

Payment Card Information

Payments may be processed by third-party payment processors, including Stripe.

Complete payment card information is generally submitted directly to the payment processor.

SOZA Ventures may receive limited information relating to the payment, such as:

• payment status;
• payment method;
• card brand;
• limited card details;
• transaction identifier; and
• fraud or risk-related information.

SOZA Ventures does not need to receive or store complete card numbers or card security codes when using a properly configured third-party payment processor.

Information Collected Automatically

When you access the Site, we and our technical service providers may automatically process information such as:

• IP address;
• date and time;
• requested pages;
• browser type;
• device type;
• operating system;
• referring website;
• general technical information;
• error information;
• security information; and
• server logs.

4. Cookies and Similar Technologies

We may use cookies and similar technologies to:

• operate the Site;
• provide security;
• process payments;
• prevent fraud;
• remember preferences;
• understand Site usage; and
• support other functionality described in our Cookie Policy.

Non-essential technologies will be used in accordance with applicable consent requirements.

See our Cookie Policy for additional information.

5. Why We Process Personal Information

To Respond to You

We use contact information to:

• answer inquiries;
• respond to requests;
• discuss potential engagements; and
• continue communications initiated by you.

Where applicable, our legal basis may be legitimate interests or steps requested before entering into a contract.

To Provide Consulting Services

We process Client information to:

• establish the engagement;
• understand the Client's business;
• prepare for Consulting sessions;
• conduct Consulting sessions;
• provide recommendations;
• communicate with the Client;
• manage scheduling; and
• administer the Consulting relationship.

Where applicable, processing is necessary for performance of a contract or steps taken at your request before entering into a contract.

To Process Payments

We process transaction information to:

• process purchases;
• confirm payments;
• maintain transaction records;
• process refunds;
• detect fraud;
• respond to payment disputes; and
• comply with financial and accounting requirements.

To Maintain and Secure the Site

We process technical information to:

• operate the Site;
• detect security threats;
• prevent abuse;
• troubleshoot problems;
• prevent fraud; and
• protect our systems.

Where applicable, we rely on our legitimate interests in operating a secure and reliable service.

Business Administration

We may use appropriate information for:

• corporate recordkeeping;
• internal administration;
• managing Client relationships;
• managing service providers;
• financial administration; and
• maintaining appropriate business records.

Legal Compliance

We may process information where necessary to:

• comply with applicable law;
• respond to valid legal requests;
• comply with tax requirements;
• maintain required records;
• establish legal rights;
• enforce agreements; or
• defend legal claims.

Analytics

Where analytics technologies are used and consent is required by applicable law, we will request consent before activating non-essential analytics technologies.

6. Legal Bases Where GDPR or UK GDPR Applies

Where the GDPR, UK GDPR or similar laws require a legal basis, we may rely on:

Contract

Where processing is necessary to enter into or perform a contract with you.

Legitimate Interests

Where reasonably necessary for legitimate business interests such as:

• responding to business inquiries;
• operating our business;
• protecting our systems;
• preventing fraud;
• managing Client relationships; and
• defending legal claims,

provided those interests are not overridden by applicable individual rights.

Legal Obligation

Where processing is necessary to comply with applicable law.

Consent

Where we specifically request consent, including for certain cookies or similar technologies where required.

You may withdraw consent at any time where consent is the applicable legal basis.

Withdrawal does not affect processing lawfully performed before withdrawal.

7. How We Share Personal Information

We do not disclose personal information except where reasonably necessary for legitimate business, contractual or legal purposes.

Service Providers

We may share information with service providers assisting with:

• website hosting;
• cloud infrastructure;
• email;
• communications;
• scheduling;
• videoconferencing;
• contact forms;
• information security;
• IT support;
• website maintenance;
• analytics;
• accounting; and
• other business infrastructure.

Payment Processors

We may share or transmit transaction information to payment processors such as Stripe for:

• payment processing;
• payment authentication;
• fraud detection;
• refunds;
• payment management; and
• dispute management.

Portfolio Businesses and Affiliates

If you contact us concerning a particular business, brand, subsidiary or affiliate, we may forward the relevant communication where reasonably necessary to respond to you.

If another legal entity processes your information independently, its own Privacy Policy may apply.

Professional Advisers

Where reasonably necessary, information may be disclosed to advisers such as:

• attorneys;
• accountants;
• auditors;
• tax professionals; or
• insurance providers.

Corporate Transactions

Information may be disclosed in connection with an actual or proposed:

• merger;
• acquisition;
• investment;
• financing;
• reorganization;
• sale of assets;
• restructuring; or
• similar corporate transaction.

Appropriate confidentiality measures will be used where required.

Legal Requirements

We may disclose information where reasonably necessary to:

• comply with applicable law;
• respond to valid legal process;
• enforce agreements;
• investigate fraud;
• protect rights or property; or
• establish, exercise or defend legal claims.

8. Sale and Sharing of Personal Information

SOZA Ventures does not sell personal information.

SOZA Ventures does not currently share personal information for cross-context behavioral advertising as that term is defined under California privacy law.

We do not currently use information collected through sozaventures.com to deliver targeted advertising based on activity across unaffiliated websites.

If these practices change, this Privacy Policy will be updated and applicable rights or opt-out mechanisms will be provided.

9. International Processing

SOZA Ventures is established in the United States.

Personal information may therefore be processed in the United States and other countries where our service providers operate.

Those countries may have privacy laws different from those of your country.

Where applicable law requires safeguards for international transfers, appropriate mechanisms may include:

• an applicable adequacy decision;
• recognized data-transfer frameworks;
• European Commission Standard Contractual Clauses;
• the UK International Data Transfer Agreement;
• the UK Addendum to Standard Contractual Clauses;
• safeguards recognized under Swiss law; or
• another lawful transfer mechanism.

You may contact us for additional information concerning applicable safeguards.

10. Data Retention

We retain personal information only for as long as reasonably necessary for:

• the purpose for which it was collected;
• ongoing business relationships;
• contractual requirements;
• legal obligations;
• accounting requirements;
• tax requirements;
• security;
• fraud prevention; and
• applicable limitation periods.

Communications

General communications may be retained for a reasonable period after the last substantive exchange where necessary for business records or legal purposes.

Consulting Records

Records concerning Consulting engagements may be retained for the duration of the engagement and for a reasonable period afterwards for:

• Client service;
• business records;
• contract enforcement;
• dispute resolution; and
• legal claims.

Financial and Transaction Records

Transaction, invoice, accounting and tax records may be retained for the period required by applicable financial, tax, accounting, corporate and legal requirements.

Server and Security Logs

Technical and security logs are retained for periods reasonably necessary for:

• security;
• diagnostics;
• system administration;
• fraud detection; and
• incident investigation.

Information no longer reasonably required will be deleted, anonymized or otherwise disposed of in accordance with applicable requirements.

11. Your Privacy Rights

Privacy rights vary according to applicable law.

Depending on your jurisdiction, you may have rights to:

• access personal information;
• receive a copy of personal information;
• correct inaccurate information;
• request deletion;
• request restriction;
• object to certain processing;
• request portability;
• withdraw consent;
• opt out of certain sales or sharing;
• opt out of certain targeted advertising; and
• lodge a complaint with an appropriate authority.

Not every right applies in every jurisdiction or circumstance.

Requests may be subject to legal exceptions.

12. Exercising Privacy Rights

Requests should be sent to:

hello@sozaventures.com

Please identify the right you wish to exercise and provide sufficient information for us to understand your request.

We may request reasonable information to verify your identity.

If a request is made through an authorized representative, we may require appropriate evidence of authorization.

We will respond within the period required by applicable law.

13. European Economic Area

To the extent the GDPR applies to our processing, individuals may have rights including:

• access;
• rectification;
• erasure;
• restriction;
• objection;
• portability; and
• withdrawal of consent.

Where processing is based on legitimate interests, you may have a right to object based on your particular circumstances.

You may also have the right to complain to the competent data protection supervisory authority in the country where you live, work or believe a violation occurred.

14. United Kingdom

To the extent UK GDPR applies, individuals may have equivalent rights under UK data protection law.

You may also have the right to submit a complaint to the UK Information Commissioner's Office (ICO).

15. Switzerland

To the extent Swiss data protection law applies, individuals may exercise applicable rights under Swiss law and may have the right to contact the competent Swiss data protection authority.

16. California Privacy Rights

This section applies to the extent that California privacy law, including the California Consumer Privacy Act as amended, applies to SOZA Ventures and the information concerned.

Where applicable, California residents may have rights to request:

• information regarding categories of personal information collected;
• specific pieces of personal information;
• categories of sources;
• purposes of processing;
• categories of recipients;
• correction;
• deletion; and
• portability.

California law may also provide rights relating to:

• sale of personal information;
• sharing for cross-context behavioral advertising; and
• certain uses of sensitive personal information.

SOZA Ventures does not currently sell personal information or share it for cross-context behavioral advertising.

We will not unlawfully discriminate against a person for exercising an applicable privacy right.

17. Global Privacy Control

Where applicable law requires recognition of a legally valid browser-based opt-out preference signal, we will process such signals in accordance with applicable requirements.

Because we do not currently sell personal information or share it for cross-context behavioral advertising, such a signal may not result in a material change to our current processing practices.

18. Colombia

To the extent Colombian privacy law, including Ley 1581 de 2012 and applicable regulations, applies to our processing, individuals may have applicable rights including the right to:

• know personal data;
• update personal data;
• rectify personal data;
• request evidence of authorization where applicable;
• obtain information concerning use of personal data;
• access personal data in circumstances established by law;
• request deletion where legally available;
• revoke authorization where legally available; and
• submit complaints to the Superintendencia de Industria y Comercio after completing any required prior procedure.

Privacy requests may be submitted to:

hello@sozaventures.com

SOZA Ventures will process applicable consultations, petitions and claims within the procedures and timeframes established by applicable Colombian law.

19. Children

The Site and Consulting Services are intended for businesses and professionals.

They are not directed to children.

Consulting Services may not be purchased by anyone under 18.

We do not knowingly solicit personal information through the Site from children under 13.

If we learn that information has been collected from a child in circumstances where it should not have been collected, we will take appropriate steps to delete it.

20. Information Security

We use reasonable administrative, organizational and technical measures designed to protect personal information against:

• unauthorized access;
• unauthorized acquisition;
• loss;
• misuse;
• disclosure;
• alteration; and
• destruction.

The Site is intended to use HTTPS encryption.

No Internet transmission or information system can be guaranteed to be completely secure.

We therefore cannot guarantee absolute security.

21. Data Breaches

Where a security incident involving personal information occurs, SOZA Ventures will investigate and take reasonable remedial measures.

Where applicable law requires notification to affected individuals, regulators or other authorities, we will provide such notification in accordance with applicable legal requirements.

22. Automated Decision-Making

The Site does not currently use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects concerning individuals.

If this changes and applicable law requires additional notice or rights, this Policy will be updated.

23. Third-Party Websites

Our Site may contain links to third-party websites.

SOZA Ventures is not responsible for the privacy practices of websites that it does not operate.

You should review the relevant Privacy Policy before submitting information to another website.

24. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in:

• our business;
• our services;
• technology;
• service providers; or
• applicable law.

The "Last updated" date identifies the current version.

Where required by applicable law, additional notice will be provided before a material change takes effect.

25. Contact

Privacy questions and requests may be sent to:

SOZA Ventures LLC

18117 Biscayne Boulevard #1434

Miami, FL 33160

United States

Email: hello@sozaventures.com