This Privacy Policy (“Policy”) outlines Compassup’s (“Compassup”, “we”, or “us”)
practices in relation to the storage, use, processing, and disclosure of personal data that you have
chosen to share with us when you access the Platform (as defined in the Terms) or use the Services (as
defined in the Terms). This Policy, together with our Terms, applies to your use of the
Platform.
At Compassup, we are committed to protecting your personal data and respecting your
privacy. Please read this Policy carefully to understand our practices regarding your personal data and
how we will treat it. The Policy sets out the basis on which any personal data that we collect from you,
or that you provide to us, will be processed by us.
Unless defined in this Policy, capitalized
words shall have the same meaning ascribed to them in our Terms and Conditions. Please read this Policy
in consonance with our Terms.
By accessing the Platform, you consent to the collection, storage,
use, and disclosure of your personal data, in accordance with, and are agreeing to be bound by this
Policy. We will not collect any information from you, except where it is knowingly and explicitly
provided by you.
1. THE DATA WE COLLECT ABOUT YOU
(a)
We may collect, use, store, and transfer different kinds of personal data about you in connection with
your use of the Services, including but not limited to: (i) identity data such as username; (ii) contact
data such as personal and/or business contact information including your first name, last name, mailing
address, telephone number, fax number, e-mail address or any other personal data you provide to us for
the purposes of doing business with us; and (iii) usage data, including how you use the
Services.
(b) You do not have to provide any personal data or information to us but in doing so,
you may not be able to take advantage of all the Services we offer.
2. HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect
and process the following data about you: (a) Information you give us: This is the information you
consent to giving us about you when you use our Services or by corresponding with us (for example, by
email or chat). It includes information you provide when you register to use the Services, share data
through the Platform, through other activities commonly carried out in connection with the Services, and
when you report a problem with the Services. If you contact us, we will keep a record of the information
shared during the correspondence.
(b) Information we collect about you and your device: Each time
you visit our Platform or use one of our Services, we will automatically collect personal data including
technical and usage data. This primarily includes your theme of choice.
(c) We may also collect,
use, and share aggregated data such as statistical data for any purpose. Aggregated data could be
derived from your personal data but is not considered personal data under applicable laws. For example,
we may aggregate your usage data to calculate the percentage of users accessing a specific feature of
the Services. However, if we combine or connect aggregated data with your personal data so that it can
directly or indirectly identify you, we treat the combined data as personal data which will be used in
accordance with this Policy.
3. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSE(S)
We
respect data protection principles, and process personal data only for specified, explicit, and
legitimate purposes for which such personal data were provided. We primarily use your personal data to
enable your use of Compassup and supply the Services requested by you. We may also use your personal
data for the purposes provided in this Policy, and the purposes listed below: (a) You understand that
when you consent to providing us with your personal data, you also consent to us sharing the personal
data with third parties, including the government and regulatory entities, should the need arise under
law, in connection with or related to the provision of Services.
(b) You are aware that by using
and sharing your information on the Platform, you authorize us, our associate partners, affiliates and
related third parties to contact you via email, or the Platform. This is to ensure that you are aware of
all the features of the Platform and the Services.
(c) You are aware that any and all information
pertaining to you, whether or not you directly provide it to us (via the Platform or otherwise),
including but not limited to personal correspondence such as emails or letters, instructions from you,
etc., may be collected, compiled, and shared by us in order to render Services to you and you expressly
consent to this.
(d) In general, we will not disclose personal data except in accordance with the
following purpose or activity:(i) to register you as a user; (ii) to deliver Services; (iii) to manage
our relationship with you including notifying you of changes to any Services; (iv) to administer the
Services including troubleshooting and system testing; (v) to monitor trends so we can improve the
Services; (vi) to perform our obligations that arise out of the arrangement we are about to enter or
have entered with you; (vii) to enforce the terms of the arrangement we have with you or any third
party; (viii) to comply with a legal or regulatory obligation.
4. TRANSFER OF PERSONAL DATA
(a)
As a part of your use of and to ensure better and seamless delivery of the Services to you, the
information and personal data you provide to us may be transferred to and stored at countries other than
your home jurisdiction. These countries shall be subject to data laws of their respective countries. We
and our service providers may transfer your information to, or store or access it in, jurisdictions that
may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to
ensure that your personal data receives an adequate level of protection in the jurisdictions in which we
process it. By using such Service, you expressly consent to this transfer, and agree and acknowledge
that we will not be responsible for any additional terms and conditions, policies, and
guidelines.
(b) By submitting your information and personal data to us, you agree to the
transfer, storage and/or processing of such information, and personal data outside the country you are
based in, in the manner described above.
5. THIRD PARTY SERVICES
(a)
Our Services may, from time to time, contain services provided by or links to and from the websites of
our partner networks, advertisers, and affiliates (“Third Party Services”). Please note that the Third
Party Services that may be accessible through our Services have their own privacy policies. We do not
accept any responsibility or liability for the policies or for any personal data that may be collected
through the Third Party Services. Please check their policies before you submit any personal data to
such websites or use their services.
(b) Your relationship with these third parties and their
services and tools is independent of your relationship with us. These third parties may allow you to
permit/restrict the information that is collected. It may be in your interest to individually restrict
or enable such data collections.
(c) The place of processing information depends on each
third-party service provider and you should check the privacy policy of each of the service providers to
identify the data shared and its purpose. You will be subject to a third party’s privacy policy if you
opt in to receive communications from third parties. We will not be responsible for the privacy
standards and practices of third parties.
6. COOKIES
(a) We use cookies to distinguish you from
other users of the Platform and remember your preferences. This helps us to provide you with a seamless
user experience when you use our Services and also allows us to improve the Platform.
(b) We
collect data by way of ‘cookies’. Cookies are small data files which are sent to your browser from the
Platform and are stored on your computer or device (hard drive). The cookies shall not provide access to
data in your computer or device such as email addresses or any other data that can be traced to you
personally. The data collected by way of cookies will allow us to administer the Platform and provide
you with a tailored and user-friendly service. The cookies shall enable you to access certain features
of the Services. Most web browsers and devices can be set to notify when you receive a cookie or prevent
cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that
we can provide when you visit the Platform. At present, the only cookies which are collected are theme
preferences.
(c) Additionally, you may encounter cookies or other similar devices on certain
pages of the Platform that are placed by third parties. We do not control the use of cookies by third
parties. If you send us personal correspondence, such as emails or letters, or if other users or third
parties send us correspondence about your activities or postings on the Platform, we may collect such
information into a file specific to you.
7. DATA SECURITY
(a) We implement certain reasonable
security measures to protect your personal information from unauthorized access and such security
measures are in compliance with the security practices and procedures as prescribed under the applicable
laws. However, you agree and acknowledge that the above-mentioned measures do not guarantee absolute
protection to the personal information and by accessing the Services, you agree to assume all risks
associated with disclosure of personal information arising due to breach of firewalls and secure server
software.
(b) Where you have chosen a password that enables you access to our Services, you are
responsible for keeping this password confidential. We ask you not to share the password with
anyone.
(c) We will comply with the requirements of applicable laws in the event of a data or
security risk.
8. DATA RETENTION
You are aware
that your personal data will continue to be stored and retained by us for a reasonable period after your
use of the Services.
9. BUSINESS TRANSITIONS
You
are aware that in the event we go through a business transition, such as a merger, acquisition by
another organization, or sale of all or a portion of our assets, your personal data might be among the
assets transferred.
10 .CHANGE IN PRIVACY POLICY
(a)
We keep our Policy under regular review and may amend this Policy from time to time, at our sole
discretion.
(b) The terms of this Policy may change and if they do, the changes will be posted on
this page and, where appropriate, notified to you by email. The new Policy may be displayed on-screen
and you may be required to read and accept the changes to continue your use of the
Services.
11. YOUR LEGAL RIGHTS – YOU HAVE THE RIGHT TO:
(a)
Access Your Personal Information. You will receive a copy of the personal information we hold about you.
Please note that we may request specific information from you to enable us to confirm your identity and
right to access. If we cannot provide you with access to your personal information, we will inform you
of the reasons why, subject to any legal or regulatory restrictions. If you would like to make such a
request, please contact us at:
[email protected] and include “Access Personal Information” in the
subject line.
(b) Update Your Personal Information. We aim to ensure that personal information in
our possession is accurate, current and complete. If you believe that the personal information about you
is incorrect, incomplete or outdated, you may request the revision or correction of that information. We
will use reasonable efforts to revise it and, if necessary, to use reasonable efforts to inform agents,
service providers or other third parties, which were provided with inaccurate information, so records in
their possession may also be corrected or updated. If you would like to make such a request, please
contact us at: info
[email protected] and include “Update Personal Information” in the subject
line.
(c) Object to Processing You may have the right to object to us processing your information
in certain circumstances. This right applies when we are processing your personal information based on a
legitimate interest (or those of a third party), which you may challenge if you feel it impacts your
fundamental rights and freedoms. You also have the right to object where we are processing your personal
information for direct marketing purposes. However, in some cases, we may demonstrate that we have
compelling legitimate grounds to process your information or legal obligations which override your
rights and freedoms. If you would like to make such a request, please contact us at:
[email protected] with “Object to Processing” in the subject line.
(d) Erasure of Your
Personal Information. You may ask us to delete or remove personal information where there is no legal
reason for us to continue using it. You also have the right to ask us to delete or remove your personal
information where you successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to erase your personal
information to comply with law. Please note that we may not always be able to comply with your request
of erasure for specific legal reasons which we will notify you, if applicable, at the time of your
request. If you would like to make such a request, please contact us at:
[email protected] with
“Erasure of Personal Information” in the subject line.
If you wish to exercise any of the rights
set above, please send a request to
[email protected]. We will need you to provide specific
information to help us confirm your identity. This is a security measure to help ensure that your
personal information is not disclosed to someone that does not have the right to receive it.