This policy replaces our previous privacy policy dated 14 September 2022.
Who We Are
Centurica Ventures LLC (“Centurica”, “we”, “us”, “our”) provides due diligence, quality of earnings and bookkeeping services for buyers and sellers of online businesses. We are the data controller responsible for the personal information described in this policy.
You can reach us about anything in this policy by email at info@centurica.com, by phone on +1 (406) 215-1022, or by post at 1910 Thomes Avenue, Cheyenne, WY 82001, United States.
What This Policy Covers
This policy applies to:
- our website at centurica.com, including all forms, bookings and purchases made through it;
- our client dashboard at app.centurica.com, including Marketwatch;
- the due diligence, quality of earnings, bookkeeping and advisory services we deliver to clients, however that work is carried out; and
- our email, scheduling and other business communications with you.
Where we link to a service operated by someone else, their own privacy policy governs what they do with your information. This policy does not cover those services.
Information We Collect
Information you give us as a website visitor or enquirer. When you complete a form, book a consultation, subscribe to updates or contact us, we collect your name, email address, telephone number, company name, and whatever else you choose to tell us about your business or your enquiry.
Information we collect automatically. When you use our website or dashboard we collect your IP address, device and browser type, operating system, referring page, the pages you view, and the dates and times of your visits. We collect this through cookies and similar technologies, described below.
Information we collect to deliver our services. Due diligence and bookkeeping work requires us to examine business records in detail. Depending on the engagement, we and our engagement teams may receive, review or be given access to:
- financial statements, profit and loss records, management accounts and bookkeeping files;
- bank and credit card statements and underlying transaction records;
- tax returns and filings;
- invoices, contracts, supplier and customer records;
- marketplace, advertising, payment processor, analytics and e-commerce platform accounts, including read access or screen-shared access to those accounts;
- correspondence, and information about the owners, officers and personnel of a business under review.
Some of this material contains personal information about people other than you, including your staff, your customers and your counterparties. Where you provide it to us, you are responsible for having a lawful basis to share it, and we handle it as described in this policy.
Account information. If you are given access to our client dashboard we hold your account credentials in hashed form, your access permissions, and records of your activity in the dashboard.
Payment and contract information. When you purchase a service or hold a subscription with us, we hold records of what you bought, when, the amounts, and your billing details. Card details are collected and processed directly by our payment providers and we do not receive or store full card numbers. Where you sign an engagement letter or other agreement electronically, we hold the signed document together with the signature record, including the signing timestamp and IP address.
Why We Use Your Information, and Our Legal Basis
- To deliver our services and perform our contract with you, including carrying out engagements, producing reports, answering questions, and managing your account. Legal basis: performance of a contract.
- To take payment and administer subscriptions. Legal basis: performance of a contract.
- To respond to enquiries and provide quotes. Legal basis: our legitimate interest in responding to people who approach us, or steps taken at your request before entering a contract.
- To send marketing emails and updates. Legal basis: your consent, or our legitimate interest in marketing to existing clients about similar services. You can withdraw at any time using the unsubscribe link in any email or by emailing us.
- To operate, secure and improve our website and dashboard, including analytics, fraud prevention and troubleshooting. Legal basis: our legitimate interest in running a secure and effective business, and your consent where cookies require it.
- To meet our legal, tax, accounting and regulatory obligations, and to establish, exercise or defend legal claims. Legal basis: legal obligation, and our legitimate interest in protecting our position.
We do not sell your personal information, and we do not share it with third parties for their own direct marketing. We do not use your information to make automated decisions that produce legal or similarly significant effects.
Cookies and Similar Technologies
Cookies are small files stored on your device. We use them to keep the site working, to remember your preferences, to understand how the site is used, and to measure our advertising.
We group them as strictly necessary cookies, which are required for the site and dashboard to function and cannot be switched off; analytics cookies, which tell us how visitors use our pages; and advertising cookies, which help us measure and target our campaigns.
You can accept or reject non-essential cookies through the consent banner shown when you first visit, and you can change your choice at any time through the cookie settings link on our site or by clearing cookies in your browser. Rejecting non-essential cookies will not stop you using the site. Most browsers also let you block cookies entirely, though some parts of the site and dashboard may not work properly if you do.
Some browsers send a “Do Not Track” signal. There is no common standard for how these should be handled, and we do not currently respond to them. We do honour Global Privacy Control signals where required by law.
Who We Share Information With
We share personal information only where we need to, and only with organisations that are bound to protect it. This includes:
- Our engagement teams, including employees, contractors and specialist analysts working on your engagement, who are bound by confidentiality obligations.
- Technology providers who operate our systems on our behalf, covering website and dashboard hosting, security monitoring, backups and site management, email delivery, form handling, electronic signature, scheduling, customer relationship and email marketing, analytics, and advertising measurement.
- Payment providers, who process card and account payments directly.
- Professional advisers such as our accountants, auditors, insurers and lawyers, where they need the information to advise us.
- Authorities and other parties, where we are required to disclose by law, court order, subpoena or regulator, or where disclosure is necessary to investigate suspected wrongdoing, to enforce our terms, or to protect the rights, property or safety of Centurica, our clients or others.
- An acquirer, if our business or its assets are sold, merged or reorganised. Any acquirer remains bound by this policy in respect of information transferred to it.
We may produce aggregated or anonymised statistics that cannot identify any individual, and we may publish or share those. We do not sell or license identifiable personal information.
International Transfers
We are based in the United States and our systems and service providers are located primarily in the United States. If you are outside the United States, your information will be transferred to and processed there, and in other countries where our providers operate.
Where we transfer personal information out of the European Economic Area or the United Kingdom, we rely on an approved transfer mechanism, which is normally the European Commission’s Standard Contractual Clauses together with the UK Addendum, or transfer to a provider certified under the EU-US Data Privacy Framework. You can ask us for details of the safeguards that apply to your information.
How Long We Keep Information
We keep personal information only as long as we need it for the purposes set out above, and to meet our legal and professional obligations. In general:
- Enquiries that do not become engagements are kept for up to three years from our last contact with you.
- Marketing contacts are kept until you unsubscribe or ask us to remove you.
- Engagement records and deliverables, including our reports and working papers, are kept for up to seven years after the engagement ends, in line with professional and tax record-keeping requirements.
- Source material provided for an engagement, such as bank statements, tax returns and platform exports, is retained only for as long as it is needed for the engagement and our record-keeping obligations, and is then deleted or securely destroyed.
- Payment, invoicing and signed contract records are kept for at least seven years to meet tax and accounting requirements.
- Website analytics data is retained for up to fourteen months.
- Dashboard account records are kept for the life of the account and for a reasonable period afterwards to handle queries and disputes.
Where we no longer need information, we delete it or anonymise it. Copies may persist for a limited period in encrypted backups before those backups are cycled out.
How We Protect Your Information
We take the security of client material seriously, particularly the financial records entrusted to us during an engagement. We encrypt data in transit using TLS, restrict access to client material to the people who need it for their work, require authentication for our dashboard, log administrative activity, keep our systems patched, and use security monitoring and malware scanning on our website.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us promptly if you believe your account has been compromised.
If Something Goes Wrong
If a security incident affects your personal information, we will investigate promptly and take steps to contain it. Where the law requires it, we will notify the relevant supervisory authority within the applicable deadline, which is 72 hours of becoming aware of a qualifying breach under the UK and EU GDPR, and we will notify affected individuals without undue delay where the incident is likely to result in a high risk to their rights, or where state breach notification laws require it. We will tell you what happened, what information was involved, and what you can do.
Your Privacy Rights
Wherever you live, you can ask us to give you a copy of the personal information we hold about you, correct it if it is wrong, delete it, or stop using it for marketing. Contact us at info@centurica.com and we will respond within the time the law allows. We may need to verify your identity before we act, and we may decline a request where the law permits, for example where we must retain records for tax or professional reasons. We will not treat you differently for exercising your rights.
Additional Rights in the EU and UK
If you are in the European Economic Area or the United Kingdom, the GDPR gives you the right to be informed about how we use your information, to access it, to have inaccurate information rectified, to have your information erased in certain circumstances, to restrict how we process it, to receive your information in a portable machine-readable format, to object to processing carried out on the basis of our legitimate interests, and to object to direct marketing at any time.
Where we rely on your consent, you can withdraw it at any time. Withdrawing consent does not affect processing carried out before you withdrew it.
You also have the right to complain to your local data protection authority. In the United Kingdom this is the Information Commissioner’s Office. In the European Economic Area it is the supervisory authority for your country. We would ask you to raise the matter with us first so we have the chance to put it right.
Additional Rights in California
If you are a California resident, you have the right to know what categories of personal information we have collected about you, the sources it came from, why we collected it and who we disclosed it to; to request a copy of that information; to request deletion; to request correction; and to limit our use of sensitive personal information.
In the twelve months before the date of this policy we collected the categories of information described in the section above titled “Information We Collect”, from you directly, from your use of our website and dashboard, and from accounts and records you give us access to during an engagement. We disclosed personal information for business purposes to the categories of recipient listed under “Who We Share Information With”.
We have not sold personal information, and we have not shared it for cross-context behavioural advertising, in the preceding twelve months. We do not knowingly sell or share the personal information of consumers under sixteen.
California law also allows residents to ask once a year about personal information disclosed to third parties for their own direct marketing purposes. We do not make those disclosures.
To make a request, email info@centurica.com. You may use an authorised agent, in which case we will ask for proof of their authority.
Children
Our website and services are intended for businesses and for adults. We do not knowingly collect personal information from children under sixteen, and our services are not directed at them. If you believe a child has provided us with personal information, contact us and we will delete it, except where we are required to retain it. Limited copies may remain in backups until those backups are cycled out.
Links to Other Sites
Our website and dashboard contain links to sites we do not control, including marketplaces, platforms and the sites of partners. We are not responsible for their content or their privacy practices, and this policy does not apply to them. Check their own privacy policies before giving them your information.
Changes to This Policy
We may update this policy from time to time. When we do, we will change the effective date at the top of this page. If the changes are significant, we will take reasonable steps to tell you, which may include emailing you or placing a notice on our website. Continuing to use our website or services after a change takes effect means the updated policy applies to you.
How to Contact Us
For any question about this policy, about how we handle your information, or to exercise your rights, contact us at:
Centurica Ventures LLC
1910 Thomes Avenue
Cheyenne, WY 82001
United States
Email: info@centurica.com
Telephone: +1 (406) 215-1022