COMPLIANCE COMMAND INC.
PRIVACY POLICY
Last Updated 10-09-2024
Compliance Command Inc, together with its parents, subsidiaries and affiliates (the “Company”, “we”, “us” or “our”), is committed to protecting your (“you”, “your”, or “user”) privacy and empowering you with this privacy policy (this “Privacy Policy”). This Privacy Policy explains how we collect, use, disclose, and apply the information collected when you use our Compliance Command Platform located at www.compliancecommand.com, together with any associated services, features, functionality, or content, (collectively, the “Platform”). Our Platform Terms of Use (the “Terms”) are expressly incorporated herein, by reference, and are an integral part hereof.
This Privacy Policy sets forth our policy with respect to information that we collect from you, on or through the Platform, that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Data” or “Personal Information”). We take the privacy of your Personal Data seriously. Because of that, we have created and abide by this Privacy Policy. By using the Platform or interacting with us, you are agreeing to the application of this Privacy Policy. Please read the following carefully to understand how we collect, use, disclose, and maintain information that can be used to identify you. In addition, this Privacy Policy describes your choices for use, access, and correction of your Personal Data. If you do not agree to be bound by this Privacy Policy, please stop accessing or using the Platform.
1. Changes to this Privacy Policy. We may change this Privacy Policy, at any time and from time to time. In the event that we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy. We encourage you to review our Privacy Policy whenever you access or use the Platform to stay informed of ways that you can protect your privacy.
2. Information We Collect and Receive. When you use or interact with us through the Platform, we may collect Personal Data. More information about the categories and sources of information are provided below.
2.1 Information You Provided to Us. We collect information that you decide to share with us. At times, we may require you to provide certain information in order to use certain parts of our Platform, fulfill your requests, or provide you with certain services.
2.1.1 Account Information. When you create an account, you may provide your name, email address, phone number, physical address, and any other information you choose to upload to your account.
2.1.2 Contacting Us. You may interact with us through our Platform, including through any interactive feature, online contact form, email, or any other communication mechanism. When using these channels, you typically provide your account information and any other information you choose to provide us at your option.
2.1.3 Surveys. When you complete any forms or respond to a survey or questionnaire, we collect the Personal Data you provide.
2.2 Information We Obtain from Others. We may supplement the information we have about you with information received from other publicly available sources. Your activity on other websites and applications may be associated with your Personal Data in order to improve and customize our Platform. Additionally, employers or account holders may provide us with Personal Data about you and your permissions to use the Platform. For example, we will get contact information from company account administrators with respect to providing Platform access to authorized end users of our Services.
2.3 Information We Automatically Collect. We automatically collect certain information from you when you use the Platform, including internet or other network activity information such as your Internet Protocol (“IP”) address, unique device identifiers, browsing and search history within the Platform, and cookies and other technologies.
2.3.1 Log Information. We retain information about you when you access and use the Platform. This information can include the following: IP address, timestamps, browser information, Internet Service Provider (“ISP”), web pages visited, and URL of the webpage you visited before navigating to our Platform.
2.3.2 Device Information. We monitor user activity in connection with the Platform and may collect information about the applications and features you use and the websites you visit.
2.3.3 Crash and Error Information. If the Platform crashes or returns an error, we may collect data to determine the cause of the error using first- or Third-Party Websites. The crash or error information collected may include the following: Device IP address, device name, operating system version, application configurations(s), the time and date, and other similar statistics.
2.3.4 Cookies and Other Technologies. Cookies and similar technologies (e.g., pixels and ad tags) (collectively, “Cookies”) are small files which, when placed on your device, enable us to collect certain information, including Personal Data, from you in order to provide certain features and functionality. We and our service providers and business partners use Cookies to collect data and recognize you and your device(s) on the Platform and elsewhere across your different devices.
3. How We Use Your Information. We may use your Personal Data for our legitimate interests and the limited purpose of providing the Platform and related functionality and services, as described in the Terms and in this Privacy Policy, and as permitted by applicable law. These purposes include circumstances where it is necessary to provide or fulfill the services requested by or for you or where you have given us your express consent. We may use your Personal Data as follows:
3.1 For Our Legitimate Business Interests. We may use your Personal Data:
(i) To support our legitimate interests, including, without limitation, the provision and maintenance of the Platform, consistent with your rights and preferences;
(ii) To provide you with services that you request;
(iii) To respond to your inquiries, comments, feedback, or questions;
(iv) To send administrative information to you; for example, information regarding the Platform and changes to our Terms;
(v) To help us improve the functionality of the Platform and to better understand our users;
(vi) To customize and optimize the content or advertisements that you receive when you use the Platform, and otherwise to enhance or improve your experience and our Platform;
(vii) To develop, analyze and improve our Platform, which may include traffic, usage, and navigation patterns related to your activities on the Platform and the links we provide to Third‑Party Websites;
(viii) To send you commercial or marketing messages, including, without limitation, newsletters and e-mail communications about our offerings or services;
(ix) To protect our or any third-party’s rights or interests;
(x) For internal purposes such as auditing and data analysis;
(xi) To investigate alleged violations of our Terms; and
(xii) To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
3.2 With Your Consent. In some cases, we will ask you for consent to use your Personal Data for specific purposes. If we do, we will make sure you can revoke your consent in in accordance with the “Your Choices” section below.
3.3 Other Purposes. If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to, or at the time that, the Personal Data is collected, or we will obtain your consent subsequent to such collection but prior to such use.
3.4 Aggregated Personal Data. In an effort to understand and serve our users better, we may conduct research on our customer demographics, interests, and behaviors using aggregated and/or de-identified information collected through the Platform and from other sources so that such information can no longer be linked to you or your device (“Aggregate / De-Identified Information”).
4. How We Share and Disclose Information.
4.1 We Do Not Sell Personal Information. We do not sell or otherwise disclose Personal Data we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected. We share information to perform activities that you request.
4.2 Service Providers and Business Partners. To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with various service providers and business providers, including providers of website and/or platform hosting, website and platform-related consulting and monitoring, data analysis, information technology and related infrastructure provision, e-mail delivery, auditing, and other services related to delivering the Platform. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
4.3 Sharing Which You Control. We may ask for your consent to share your Personal Data, and if you agree, we will share your Personal Data accordingly.
4.4 Settings. We may share information consistent with your settings selections within the Platform.
4.5 Other Applications. You may, from time to time, have the ability connect your account with third-party services. By doing so, you’re enabling us and those third parties to exchange Personal Data about you so that we and those third parties can provide, improve, protect, and promote such services. Please remember that third parties’ use of your Personal Data will be governed by their own privacy policies and terms of service.
4.6 Aggregate / De-Identified Data. From time to time, we may share Aggregate / De-Identified Information about use of the Platform, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
4.7 Legal Reasons. We may also disclose your Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Data to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Platform; to enforce or apply our policies or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify our users about legal demands for their Personal Data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.
4.8 Sale, Merger, or Other Business Transfer. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), Personal Data may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, your Personal Data would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable law, we will comply with such restrictions.
5. Your Choices.
(a) If you have provided us with Personal Data, you may have the right to ask us to review, update, or delete certain Personal Data by contacting us in accordance with the “Contact Us” section below. Please note that we will need to verify that you have the authority to request that we delete your Personal Information and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.
(b) Most web browsers are set to accept Cookies by default. If you prefer, you can usually set your browser to remove or reject Cookies. Please note that if you choose to remove or reject Cookies, this could affect the availability and functionality of our Platform.
(c) You have a choice, at any time, to stop us from sending you e-mails for marketing purposes by following the “unsubscribe” link included in these messages. Please note that despite any indicated e-mail marketing preferences, we may continue to send you administrative e-mails, including, for example, notices of updates to our Terms or this Privacy Policy, if we choose to provide such notices to you in this manner.
(d) In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Platform, then you may be unable to use those features.
(e) Some browsers offer a “do not track” (“DNT”) option. Since no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make reasonable efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
6. European Residents. If you are a resident of the European Economic Area, we rely on our legitimate interest as described in this Privacy Policy to process your Personal Data. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the Personal Data we maintain about you. We offer you certain choices about what Personal Data we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below.
6.1 Right of Access. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
6.2 Right to Rectification. If your Personal Data is inaccurate or incomplete, you may be entitled to ask that we correct or complete it.
6.3 Right to Erasure. You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable) and where there is no other legal basis for processing.
6.4 Right to Restrict Processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as if you contest its accuracy or object to us processing it.
6.5 Right to Data Portability. You may have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
6.6 Right to Object. You may ask us at any time to stop processing your Personal Data, and we will do so: (a) if we are relying on a legitimate interest to process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your Personal Data for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
6.7 Right to Withdraw Consent. If we rely on your consent to process your Personal Data, you may have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
6.8 Right to lodge a Complaint. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
7. Additional Information for Residents of Certain US States.
7.1 Additional information for California Residents (Effective January 1, 2023).
7.1.1 If you are a resident of the State of California, you may have certain rights afforded to you under the California Consumer Privacy Act or the “CCPA”, as amended by the California Privacy Rights Act.
7.1.2 We collect Personal Data for the business and commercial purposes described in the section above titled “How We Use Your Information”, and we share Personal Data with the categories of third parties described in the section above titled “How We Share and Disclose Information”. We do not ‘sell’ (as such term is defined in the CCPA) the Personal Data we collect (and will not sell it without providing you a right to opt-out). Please note that we do use third-party Cookies for our advertising purposes as further described in the section above titled “Information We Automatically Collect”.
7.1.3 California law, if applicable to us, provides some California residents with the rights listed below:
(i) You may have the right to request that we disclose to you the Personal Data we collect, use, or disclose, and information about our data practices.
(ii) You may have the right to request that we delete your Personal Data that we have collected from you.
(iii) You may have the right to request that we correct inaccurate Personal Data.
(iv) You may have the right to exercise control over our collection and processing of certain sensitive Personal Data.
(v) You have the right not to receive retaliatory or discriminatory treatment for exercising these rights.
7.1.4 To request access to or deletion of your Personal Information, or to exercise any other privacy rights under California law, please contact us at [email protected] or via any other method which may be specified in the “Contact Us” section below. In order to verify your request to know or delete certain Personal Data, we may require you to provide us with certain information to be used solely for the purpose of verifying your identity.
7.1.5 Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
7.2 Additional information for Colorado Residents (Effective July 1, 2023).
7.2.1 The Colorado Privacy Act, if applicable to us, provides some Colorado residents with the rights listed below:
(i) You may have the right to know and see what Personal Data we have collected about you in a portable format.
(ii) You may have the right to request that we correct inaccurate Personal Data.
(iii) You may have the right to request that we delete the Personal Data we have collected about you.
(iv) You may have the right to opt out of targeted advertising (as defined under Colorado law).
7.2.2 To request access to or deletion of your Personal Data, or to exercise any other privacy rights under Colorado law, please contact us at [email protected] or via any other method which may be specified in the “Contact Us” section below.
7.2.3 Please note that to respond to some rights we may need to verify your request either by asking you to log in and authenticate your account or otherwise verify your identity by providing information about yourself or your account. Authorized agents can make a request on your behalf if you have given them legal power of attorney or we are provided proof of signed permission, verification of your identity, and, in some cases, confirmation.
7.3 Additional information for Connecticut Residents (Effective July 1, 2023).
7.3.1 The Connecticut Data Privacy Act, if applicable to us, provides some Connecticut residents with the rights listed below:
(i) You may have the right to know and see what Personal Data we have collected about you in a portable format.
(ii) You may have the right to request that we correct inaccurate Personal Data.
(iii) You may have the right to request that we delete the Personal Data we have collected about you.
(iv) You may have the right to opt out of targeted advertising (as defined under Connecticut law).
7.3.2 To request access to or deletion of your Personal Data, or to exercise any other privacy rights under Connecticut law, please contact us at [email protected], or via any other method which may be specified in the “Contact Us” section below.
7.4 Addition Information for Nevada Residents (Effective October 1, 2019).
7.4.1 If you are a Nevada resident, under Privacy and Security of Personal Information Chapter of the Nevada Revised Statutes Section 603A (“603A”), we are required to provide you with the following:
(i) We may collect certain covered information (as defined under Nevada Law) when you use or visit our Platform, including, but not limited to first and last name, home or other physical address, electronic email address, and telephone number.
(ii) We may share your covered information to third parties as described in the section above titled “How We Share and Disclose Information”.
(iii) Third parties may collect covered information about your online activities over time and across different internet websites when you use our Platform.
7.4.2 Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has provided “personally identifiable information” to us via the Platform, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at [email protected], or via any other method which may be specified in the “Contact Us” section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
7.5 Additional information for Utah Residents (Effective December 1, 2023).
7.5.1 If you are a Utah resident, pursuant to the Utah Consumer Privacy Act, we must share with you that:
(i) We collect Personal Data for the business and commercial purposes described in the section above titled “How We Use Your Information”;
(ii) We may share your Personal Data to third parties as described in the section above titled “How We Share and Disclose Information”; and
(iii) We collect the categories of Personal Data described in the section above titled “Information We Collect and Receive”.
7.5.2 Utah law, if applicable to us, provides some Utah residents with the rights listed below:
(i) You may have the right to know and see what Personal Data we have collected about you in a portable format.
(ii) You may have the right to request that we delete the Personal Data we have collected about you.
(iii) You may have the right to opt out of targeted advertising (as defined under Utah law).
7.5.3 To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Utah law, please contact us at [email protected], or via any other method which may be specified in “the Contact Us” section below.
7.6 Additional information for Virginia Residents (Effective January 1, 2023).
7.6.1 If you are a Virginia resident, pursuant to the Virginia Consumer Privacy Act, we must share with you that:
(i) We collect Personal Data for the business and commercial purposes described in the section above titled “How We Use Your Information”;
(ii) We may share your Personal Data to third parties as described in the section above titled “How We Share and Disclose Information”; and
(iii) We collect the categories of Personal Data described in the section above titled “Information We Collect and Receive”.
7.6.2 Virginia law, if applicable to us, provides some Virginia residents with the rights listed below:
(i) You may have the right to know and see what Personal Data we have collected about you.
(ii) You may have the right to request that we correct inaccurate Personal Data.
(iii) You may have the right to request that we delete the Personal Data we have collected about you.
(iv) You may have the right to opt out of targeted advertising (as defined under Virginia law).
7.6.3 To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Virginia law, please contact us at [email protected], or via any other method which may be specified in the “Contact Us” section below.
8. Security. We take reasonable precautions intended to help protect your Personal Data that we collect. Unfortunately, no system or online transmission of data is completely secure, and we cannot guarantee the security of data transmitted across the Internet. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
9. Information Retention. We will retain Personal Data required to comply with privacy requests, as required by law, and in order to resolve disputes. We may also retain copies of your Personal Data for disaster recovery purposes, to prevent fraud or future abuse, or for legitimate business purposes.
10. Data Processing and Data Transfers. In connection with your use of the Platform, we may store, process, and transmit data in the United States and locations around the World—including those outside your country of residence. Your Personal Data, therefore, may be subject to privacy laws that are different from those in your country of residence. In such instances, we shall ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that industry appropriate contractual, technical, and organizational measures are in place.
11. Links to Third-Party Websites. The Platform may contain links to other websites not operated or controlled by us, including social media websites (“Third-Party Websites”). The information that you share with Third Party Websites will be governed by the specific privacy policies and terms of service of the Third-Party Websites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these websites. Please contact the Third-Party Websites directly for information on their privacy practices and policies.
12. Children’s Information. The Platform is directed to individuals at the age of 18 and over. We do not knowingly collect Personal Data from individuals under the age of 18. If we become aware of individuals who have provided us with Personal Data and are under the age of 18, we will take steps to deactivate the account and delete the Personal Data. If you become aware of information from individuals under the age of 18 which has been provided to us, please contact us in accordance with the “Contact Us” section below.
13. Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us via email at [email protected].
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