SANCTIONS COMPLIANCE · ANTI-MONEY LAUNDERING (AML) · KNOW YOUR CUSTOMER (KYC) VIEW COMPLIANCE POLICIES
PromoVEN
SANCTIONS COMPLIANCE · ANTI-MONEY LAUNDERING (AML) · KNOW YOUR CUSTOMER (KYC) VIEW COMPLIANCE POLICIES
PromoVEN
PromoVEN LLC · Legal Policies

Terms of Service, Privacy Policy & Refund/Cancellation Disclosures

B2B terms of service, privacy policy, and refund and cancellation disclosures.

01. GLOBAL PLATFORM TERMS, OPERATIONAL BOUNDARIES, & LEGAL ELIGIBILITY

1.1 Scope of Operations & Statutory Limitation of Liability

PromoVEN LLC (the “Company”) operates a digital marketplace for corporate information and a verified business directory. The Company provides information and helps businesses verify corporate profiles. It is not a clearinghouse, financial intermediary, transaction broker, commercial agent, payment processor, or escrow agent. Participating companies negotiate and complete all trade agreements, commercial contracts, purchase orders, joint ventures, letters of credit, and physical or digital payments resulting from data searches, networking, or profile matching outside the platform. The Company does not monitor, supervise, or endorse those transactions and is not responsible for their performance, delivery, quality, or legality.

1.2 Eligible Digital Services & Classification of Non-Physical Assets

No tangible goods or physical consumer products are sold, stored, or distributed by the Company or through the platform. Fees, purchases, and other transactions on the platform relate to non-physical commercial digital services, including:

  • Corporate Membership Dues: Fees allocated for multi-layered corporate background underwriting, onboarding, and platform registration.
  • Data Visualization Access Rights: Tiered operational subscription keys permitting the viewing of verified corporate data rooms and company matrices.
  • Corporate Advertisements & Promotional Placements: Managed B2B marketing banners, targeted corporate profiles, and verified directory highlight placements.
  • Event Sponsorships, Delegations, & Tickets: Corporate admissions, branding footprints, and corporate table allocations for specified trade summits and institutional networking forums.

These items are considered “Digital Services” and are governed by the Company’s B2B terms.

1.3 User Content, Intellectual Property, & Directory Data Integrity Protection

Applicants and approved companies must provide complete corporate information. Members confirm that uploaded documents, beneficial ownership records, tax filings, and operational information are legitimate, current, and accurate. The Company may delete, hide, or suspend a corporate profile or operational data field that contains misleading, incomplete, or unverified information. The collection of verified profiles, financial indices, and business data on the platform is the Company’s intellectual property. Users may not use or create automated scripts, scraping bots, deep-learning models, indexers, data-mining crawlers, or browser extensions to collect, extract, copy, or redistribute profile data. Violations may lead to immediate profile termination and loss of platform access. The Company may also seek statutory damages under applicable U.S. and international intellectual property laws.

1.4 Mutual Indemnification & Hold Harmless Agreements

By applying for membership or maintaining an active directory listing, the member company, its subsidiaries, directors, and authorized legal representatives agree to indemnify, defend, and hold harmless PromoVEN LLC, its parent organizations, executives, compliance officers, and technology providers against civil claims, administrative fines, financial losses, regulatory penalties, legal fees, or operational damages arising from:

  • The member's submission of falsified, fraudulent, or expired corporate documentation.
  • Any transaction or operational agreement entered into off-platform with another member discovered through the Company's directory.
  • Any breach of international trade laws, local tax evasions, or sanctions violations committed by the member corporation or its ultimate beneficial owners.

02. GLOBAL PRIVACY POLICY, DATA CONTEXT, & JURISDICTIONAL COMPLIANCE

2.1 The Principle of Strict Data Minimization

The Company follows the principle of data minimization. We collect corporate registration documents, ultimate beneficial ownership records, operational information, and executive biometric data only to protect the platform, prevent corporate identity theft, and meet required cross-border Know Your Business (KYB) and Anti-Money Laundering (AML) checks. We do not sell, lease, trade, barter, monetize, or distribute user data, corporate usage data, or screening information to marketing firms, analytics vendors, advertising brokers, or public data networks. We process and store this information in our corporate systems.

2.2 Jurisdictional Alignments & International Data Protection Standards

Because the Company serves users in the United States, Venezuela, Colombia, and other parts of Latin America, we take applicable data-protection requirements into account in each jurisdiction:

  • United States Frameworks: Data collection aligns with the Federal Trade Commission (FTC) privacy mandates, the Corporate Transparency Act (CTA) data protections, and NY SHIELD Act security protocols for private data encryption and breach containment.
  • Colombian Frameworks: Our system respects the spirit and strict architectural data tracking boundaries established by Ley 1581 de 2012 (Régimen General de Protección de Datos Personales). We implement technical measures to ensure that the processing of corporate executive and shareholder information complies with principles of legality, transparency, and restricted circulation.
  • Venezuelan Frameworks: Data handling aligns with constitutional mandates regarding Habeas Data and corporate confidentiality as governed by regional commercial codes, ensuring that corporate data profiles are used strictly for their intended vetting and authorization scope.

2.3 Comprehensive Data Mapping & Categories of Collected Information

The Company identifies and classifies the following data:

  • Corporate Operational Metadata: Official company names, commercial registry filings (Actas Constitutivas, Certificados de Existencia), national tax identifications (RIF, RUT, NIT, EIN), physical site addresses, operational licenses, utility records, and verifiable ongoing transactional histories.
  • Shareholder & Control Person Telemetry: Complete capitalization tables (Libros de Accionistas), organizational charts, trust instruments, corporate resolutions, and valid powers of attorney (Poderes Notariados/Registrados).
  • Individual Personal Identifiers: Biometric passport scans, national identity cards (Cédulas de Identidad, Driver's Licenses), full legal names, dates of birth, residential addresses, and source-of-wealth validation records.
  • Technical System Telemetry: Internet Protocol (IP) addresses, cryptographic session tokens, user access logs, browser configurations, and internal security audit trails.

2.4 Data Hosting, Server Architecture, & International Jurisdictional Disclosures

PromoVEN LLC is organized and operates in the United States. Its corporate infrastructure is managed from New York using Odoo.sh cloud hosting. When you upload corporate records, company bylaws, shareholder registers, or executives’ personal credentials, you consent to the transfer and storage of those data on servers in the United States. The Company uses the Advanced Encryption Standard (AES-256) for stored data and Transport Layer Security (TLS 1.3) for data in transit to help protect against unauthorized access, interception, or exposure.

03. SYSTEMIC DATA RETENTION, MODIFICATION, & AUDITING PROTOCOLS

3.1 Statutory Data Retention Lifecycles

To comply with Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and international banking transparency requirements, the Company retains historical records, corporate verification documents, identity indices, and screening logs for seven (7) years in encrypted form.

3.2 Commencement of Retention Timeline

The seven-year statutory archiving window does not begin at the initial collection stage. The timeline begins on the exact date that the business relationship is formally terminated, the user profile is deactivated, or corporate access keys are permanently revoked.

3.3 Explicit Right to Rectification & Administrative Restrictions

Corporate members possess a continuous right to request the update, correction, or rectification of historical data fields to ensure their public and private directory matrices reflect their real-world corporate status.

  • Submission Mechanism: To trigger an administrative data modification review, an authorized legal representative must submit a corporate attestation outlining the requested updates via our secure dashboard.
  • Compliance Locks: Data fields directly linked to active compliance investigations, corporate look-through background checks, or global sanctions matches cannot be altered, masked, or hidden by the user while an inspection or regulatory review is pending.

04. COOKIE POLICY, SYSTEM WEB TELEMETRY, & ANALYTICS

4.1 Use of Cookies and Local Storage Technologies

The Company uses browser cookies, pixel tags, and local storage to maintain sessions, help protect user accounts against cross-site scripting, and support marketplace performance. Cookies on this platform fall into three categories:

  • Essential & Security Cookies: Cryptographic session tokens, user authentication markers, and load-balancing parameters that are strictly necessary to maintain portal access and secure encryption lanes. Deactivating these cookies will cause immediate platform functional failure.
  • Functional Cookies: Non-identifying localized variables that recall user interface settings, such as navigation preferences, sidebar adjustments, and layout state configurations.
  • System Telemetry Cookies: Internal diagnostic mechanisms that log platform error reports, loading latencies, and component rendering metrics.

4.2 Prohibited Third-Party Tracking & Pixel Exploits

The platform blocks third-party behavioral advertising scripts, consumer-profiling cookies, and marketing pixels, including social media retargeting tools. Tracking is handled internally or through analytics systems that do not share company tracking data with advertising brokers.

4.3 Automated Corporate Web Analytics

To improve the layout, interface performance, and server capacity, the Company collects web usage data that does not identify individuals. This includes page navigation, component clicks, session duration, device operating systems, and browser types. The Company aggregates and anonymizes this data, then processes it in its cloud infrastructure to review overall usage without exposing corporate identities or individual communication logs.

05. STRICT RECURRING SUBSCRIPTION & CANCELLATION LIFECYCLES

5.1 Automated Billing Configurations

Some premium Digital Services, including corporate data visualization, ongoing access to the business directory, and managed advertising, are sold through recurring subscriptions. When a company activates a subscription, it authorizes recurring charges to its registered business payment method at the end of each billing period (monthly, quarterly, or annually).

5.2 Mandatory Subscription Cancellation Procedures

Corporate members may cancel recurring subscriptions at any time through their account management portal.

  • Processing Deadlines: Cancellation requests must be executed through the platform interface at least five (5) business days prior to the next scheduled automated billing date. Failure to cancel within this window will result in the automated execution of the charge for the subsequent billing cycle.
  • Access Continuation: Following the successful submission of a cancellation request, the corporate profile will retain baseline directory visualization rights until the exact expiration date of their current pre-paid billing cycle.

5.3 Non-Issuance of Pro-Rated Credits or Adjustments

The Company does not issue prorated or partial credits, cash adjustments, or credit extensions for unused membership days, unviewed corporate data rooms, or marketing banners removed before the end of a billing cycle.

06. UNYIELDING B2B REFUND DISCLOSURES & VETTING PROTOCOLS

6.1 Strict "All Sales Are Final" Corporate Policy

Except where U.S. federal law requires otherwise, payments to PromoVEN LLC for Digital Services are nonrefundable. These payments include initial application fees, corporate review fees, annual or monthly membership dues, business directory access tokens, featured advertising placements, and trade event sponsorships.

6.2 Global Economic Sanctions Enforcement & Asset Control Protocol

Every corporate applicant, directory member, executive officer, and natural Ultimate Beneficial Owner (UBO) who owns more than 10% directly or indirectly, or exercises control, is screened in real time against global sanctions lists. If an applicant, member company, or related UBO appears on an active international sanctions list, including the U.S. OFAC Specially Designated Nationals (SDN) List, the European Union Consolidated Financial Sanctions Targets, or the United Nations Security Council Consolidated List, the following steps apply:

  • Immediate Denial & Permanent Revocation: The company's membership application will be immediately denied, all active marketplace profiles will be permanently unlinked, and data access keys will be revoked without prior notice.
  • Absolute OFAC Asset Compliance Control: The Company handles all incoming and held funds in absolute compliance with United States federal asset control laws [31 C.F.R. Chapter V]. If U.S. federal law dictates that the funds received from or linked to a sanctioned party must be formally blocked, frozen, or redirected into a restricted escrow account rather than returned to the sender, the Company will freeze the assets immediately. The Company will report the blocked transaction to the appropriate federal authorities within the mandatory 10-day reporting window.
  • The Prohibited Return Threshold: Under no circumstances will the Company process an unauthorized refund to a sanctioned entity, as returning capital to a designated SDN constitutes a direct violation of federal law and carries severe criminal penalties.
  • Conditional Safe-Return Rule: A monetary return of funds will only be initiated if, and exclusively when, U.S. federal asset control laws explicitly permit a return of funds instead of a mandatory block (e.g., if an applicant shares a similar name but is conclusively proven through Enhanced Due Diligence to be a false positive match). In such highly specific permitted scenarios, the capital will be returned exclusively to the exact original form of payment to prevent illicit cross-border capital diversion, layering, or structural smurfing.

6.3 Account Termination & Asset Forfeiture For Compliance Infractions

The Company may immediately terminate the account of any corporate member that violates the platform’s security rules. Examples include submitting altered or expired legal documents, such as an expired Venezuelan RIF or invalid Colombian RUT; misrepresenting Ultimate Beneficial Owners; bypassing directory access controls; or being subject to an active cross-border regulatory or criminal investigation. If an account is terminated for a policy or compliance violation, paid membership dues, unused advertising credits, and event sponsorship amounts are forfeited to the Company. No partial, prorated, or calculated refunds will be issued.

07. CORE REGULATORY COMPLIANCE AND INDEPENDENT POLICY INTEGRATION

7.1 Separation and Subordination of Documents

This document covers use of the website, privacy, and billing. It does not replace the Company’s Compliance, Sanctions, and Anti-Money Laundering Policy. For information about business verification and required documents, see the Compliance Policy. All platform participants must follow that policy.

7.2 Independent Global Compliance Policy Integration

For details about business verification requirements, screening procedures, and identity documents, read the Compliance Policy.

08. SYSTEMIC COMPLIANCE CONTACT, NOTIFICATIONS, & LEGAL ASSISTANCE

8.1 Centralized Portal Communication Mandate

The Company processes legal notices, data-change requests, and formal corporate inquiries through its Contact Us page. We may not process requests sent through unverified email or telephone channels.

8.2 Guidance for Corporate Inquiries & Dispute Notifications

Corporate applicants, members, foreign investors, and regulators may use our Contact Us page to ask questions about platform rules, report errors, request data corrections, or submit formal notices.

09. AMENDMENTS, COMPLIANCE VALIDATION, & LEGAL EFFECT

9.1 Right to Corporate Amendment

The Company may update these Terms of Service, Privacy Policy, and Refund and Cancellation Disclosures to reflect changes in trade laws, technology, or regulatory requirements. Updates take effect when the revised text is published on this website.

9.2 Complete Compliance Validation

By using the web application, applying for membership, completing the corporate onboarding questionnaire, uploading corporate data, or maintaining a verified profile on the PromoVEN network, the applicant company, its directors, officers, and authorized regional legal representatives agree to follow the rules, data policies, billing terms, and verification requirements in this document.