Last Update: May 31, 2016
This Privacy Policy (this “Policy”) by Jacobian Engineering Inc. (the “Company” or “we”) explains the type of information we may gathered or track on our site, software, ComplyVault platform, or services (the “Service”), how such information may be used, and with what other parties the information is or may be shared. Please also carefully review our Terms of Service (the “Terms of Service”) that provides the terms, conditions, disclaimers, and limitations of liability governing the use of the Service and if you are or intend to become a subscriber to the Service, your use and access to the Service will be further conditioned upon your agreement to the Terms of Service.
Your privacy is important to us. We understand and share your concerns about the privacy of information and Client Content you may provide to store or manage through the Service. In this Privacy Policy, we attempt to explain what we do with your information and, if applicable, how we collect it. Please read this Policy carefully as it also explains how you may verify the accuracy of any personal information (“Personal Information”) we have concerning you and how you may request that we delete or update your Personal Information. By using the Service you consent to this Privacy Policy.
PRIVACY PRINCIPLES
We believe in protecting your privacy. When we collect Personal Information from you on the Service, we follow the privacy principles:- Notice. When we collect your Personal Information, we'll give you timely and appropriate notice describing what Personal Information we're collecting, how we'll use it, and the types of third parties with whom we may share it.
- Options. We'll give you choices about the ways we use and share your Personal Information, and we'll respect the choices you make.
- Relevance. We'll collect only as much Personal Information as needed for specific, identified purposes, and we won't use your Personal Information for other purposes without obtaining your consent.
- Retention. We'll keep your Personal Information only as long as we need it for the purposes for which we collected it, or as permitted by law.
- Security. We'll take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
- Accuracy. We'll take appropriate steps to make sure the Personal Information in our records is accurate.
- Access. We'll provide ways for you to access your Personal Information, as required by law, so you can correct inaccuracies.
- Sharing. Except as described in this Policy, we won't share your Personal Information with third parties without your consent.
- International Transfer. If we transfer your Personal Information to another country, we'll take appropriate measures to protect your privacy and the Personal Information we transfer.
- Enforcement. We'll regularly review how we're meeting these privacy promises, and we'll provide an independent way to resolve complaints about our privacy practices.
WHAT INFORMATION?
“Personal Information”, including, but not limited to, your name, company, address, telephone number, payment account information and e-mail address, may be collected when you order any level of Service, register with the Service, or contact us with a specific concern, information request or question. We may also collect any relevant comments provided with any question or inquiry and information, if requested, about your company, industry, number of employees and such other related information.
We may also collect non-personally identifiable information and aggregate and anonymize such information ("Aggregate Information"), for example, tracking the number of visitors to the Service, where visitors enter the Service, how long they remain, etc., in connection with the operation of the Service. Other than Personal Information you supply to us voluntarily or the Aggregate Information that may be gathered via cookies, as described in this Policy, We do not at this time collect other Personal Information in connection with your use of the Service.
If you are a subscriber or user of the Service, you provide us, through your acceptance of the Terms of Service, with Client Content (as further defined in the Terms of Service), which may contain your Personal Information or other personal or sensitive information (i.e., Protected Health Information) of your clients and other third parties.
SING YOUR INFORMATION.
We will use the information described above that you submit:
- To answer your specific inquiries;
- To aid in the administration of the Service;
- To personalize your experience with the Service;
- To improve customer service, using your information to help us more efficiently respond to service requests and support needs;
- If you opt-in, to send you additional materials relating to the Service that may be of interest to you or to send you periodic emails using the email address you provided to use the Service – such emails may provide information and updates pertaining to your services, additional services being introduced, news, and status updates, etc.;
- To process certain transactions, where your information, whether public or private will not be sold, exchanged, transferred or given to any other company ("Information Sharing") other than as provided herein, without your consent - excluding Information Sharing conducted for the express purpose of delivering the purchased Service or in the case of an acquisition, merger, sale or change in control of the Company in which case no consent by you is required; or
- As otherwise described in this Policy.
We may, from time to time, share your Personal Information with trusted third party consultants, in which case, the consultants shall use your Personal Information solely to assist us with the Service and operations, and any such consultants shall be required to comply with the terms of this Policy and obligations of confidentiality and data security. We may also release your information when we believe release is required to comply with the law, enforce the Service policies, or protect our or others' rights, property or safety.
We do not, at this time, share any Aggregate Information that we may collect with other parties for marketing, advertising or other such uses.
COOKIES AND OTHER TECHNOLOGIES.
When you visit or utilize the Service, various general information regarding your browser, operating system, IP address, domain name and the like that you use to access the Service from is automatically collected as part of the Service’s normal operations.
As part of such Aggregate Information we may collect details about your browsing behavior, such as, but not limited to, the number of times and dates you have visited or accessed the Service, and the amount of time you spend viewing or using the Service, if applicable. In addition, we may track your response to our e-mails, including, for example, learning how many users open an e-mail and compiling aggregated statistics about e-mail and other activities conducted for us. Such information is used solely for our internal purposes and in assisting us in enhancing customer experiences, support, and the usability and efficiency of the Service.
Although we do not do at this time, in addition to our own cookies for the above purposes, we reserve the right to use "transparent GIFs," on the Service to help manage any online advertising or e-mail marketing we may conduct in the future. These transparent GIF files are commonly used and provided by one or more third-party service providers, and enable service providers to recognize a unique cookie in your web browser to learn which advertisements or e-mails brought you to our website and how you use the Service. To conduct these or other activities, we or our service providers sometimes may link Personal Information you previously provided us (such as, for example, your name and e-mail address) to the information the transparent GIF files provide about how you arrive at, navigate through and leave the Service.
You may choose not to accept any such cookies and the Service will still work if you choose to do so, by adjusting the privacy and cookie settings available in your web browser. You should refer to your browser's help file and other directions to learn how to do this. Note, that under certain circumstances blocking all cookies may restrict the sites you can visits and may affect your use of the Service.
DISCLOSING PERSONAL INFORMATION.
Subject to applicable law, we and our various Service Providers (defined below) may disclose and share your Personal Information:
- Within the Company;
- To unaffiliated third parties under contract to perform services for or on our behalf ("Service Providers"), who are required to uphold and maintain privacy and security policies with respect to privacy and the treatment of your Personal Information;
- To a third party in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or division of the Company; and
- To other such persons or agencies as permitted or required by applicable law or regulations.
For debit, credit card and ACH payments, we employ third parties to process payments on our behalf. These third-party processing parties will only have access to the information you provide required to fulfill your payment. They are required under agreements with us to process this information securely and in accordance with the relevant privacy or data protection laws, standards, regulations and best practices.
PROTECTING AND STORING YOUR INFORMATION.
We take the security of the information we collect through the Service seriously and in response implements a variety of security measures designed to reduce the risk of unauthorized disclosures and accidental destruction or loss of your Content and to maintain the safety of your personal information using methods appropriate to the nature of the data and information provided to us by you.
Personal Information collected via the Service is stored on servers located in the United States, and these servers are subject to our IT security policies and procedures. To discuss the security programs, procedures and policies that we utilize to reasonably secure your Personal Information and Content, please contact your Company representative or contact us through the Service. We are happy to discuss our security program with you.
ANALYTICS INFORMATION
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, and other information that assists us in improving the Service. We may collect and use this analytics information together with your Personally Identifiable Information and stitch together session data from unauthenticated User visits with authenticated User visits to build a broader profile of our individual Users so that we can serve you better.
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). You can find out more information about how Google collects and processes the data here: http://www.google.com/policies/privacy/partners/.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT.
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. As part of the California Online Privacy Protection Act, subscribers to the Service who have submitted Personal Information may make any changes to their information at any time by logging into their account. In addition, given that there are no current defined widely accepted standards, as of the date of this Privacy Policy, regarding responding to and handling "Do Not Track" mechanisms we do not recognize any web browser “Do Not Track” settings. If this changes in the future we will modify this Policy and provide an applicable notice.
CHILDREN'S ONLINE PRIVACY PROTECTION ACT ("COPPA").
We are is concerned about the safety of children when they use the internet, and will never knowingly collect Personal Information from minors (children under 13 years of age, or any other age defined under applicable law) without prior verifiable parental consent that complies with those recommended practices and applicable rules put forth by the Federal Trade Commission. The Service is expressly directed to people who are at least 13 years old or older. If we become aware that a minor is attempting to or has submitted Personal Information, we will not accept such Personal Information and will then take prompt steps to remove any such Personal Information from our records and the Service.
LINKS / THIRD-PARTY WEBSITES.
This Policy applies only to the Service. Occasionally, at our discretion, we may include or offer links to Affiliate or third party products or services. These third party sites have separate and independent privacy policies and we therefore have no responsibility or liability for the content and activities of these linked sites. You should read and understand the applicable Terms of Use and Privacy Policy that such third party sites may offer and require you to conform with. We welcome any feedback about these sites.
OPTING OUT / REQUESTING CHANGES.
Under laws that may apply to you, you are entitled to request that we:
- Provide you with a copy of your Personal Information that we hold;
- Cease processing your Personal Information, in whole or in part, as you direct us, for the purposes of direct marketing;
- Correct any errors in that Personal Information; and
- Update Personal Information as required.
If you would like to receive a copy of your Personal Information as submitted to us via the Service, or if you wish to opt-out of receiving marketing related communications from us, please send a request to us at privacy@complyvault.com. If your Personal Information is incorrect or incomplete, and you wish us to correct or delete it, please contact us. We will then make reasonable efforts to timely correct or update your Personal Information (unless we require further information from you to complete your request).
You may also ask us to remove your name and other Personal Information from our databases. For each such request, we will make all reasonable efforts to do so promptly, subject to legal requirements and other considerations, which may require that we maintain your information for a specified length of time. Removing such information may also limit the functionality of some features.
CHANGES TO THIS POLICY.
We may, in our sole discretion, update this Policy from time to time by posting a new or amended policy on the Service. If we make material changes to this Policy affecting handling of your Personal Information we will provide you an opportunity to opt-in under the terms of the revised policy through an email notice, or conspicuous notice on the Service. Any notices to be provided to you under this Policy shall be sent by email to the last email address that we had on file for you, and you hereby consent to receiving any such notice by electronic mail.
After any such changes take effect, any newly collected Personal Information will be subject to the terms of the revised policy and all previously collected Personal Information will be handled in accordance with your response to our opt-in notice.
If no material changes are made to this Policy affecting treatment of your Personal Information, the amended policy shall be effective upon posting and your access to or use of the Service following an update shall be deemed consent to the revised policy.
We recommend you visit this page regularly and in particular before supplying any Personal Information to us via the Service.
This Policy may not be otherwise amended by you without our written consent.
CONTACT US.
If you have questions concerning this Policy, please contact us at: (415) 688 - 4305 or privacy@complyvault.com.