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Privacy Notice.

At Compliance Counsel we strongly believe that privacy matters and we're committed to protecting your personal data. This Privacy Notice will inform you about our privacy practices and your rights as it relates to the personal data we may have access to when your visit our website or use our services. 

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Last updated: February 6, 2024

Version: 1.0

Overview.

The purpose of this Privacy Notice is to provide you with information about our privacy practices at Compliance Counsel, LLC ("Company," "us," or "we"). More specifically, it defines how we collect, use, process, and share personal data. "Personal Data" is any information that relates to an identified or identifiable individual and it deserves to be protected properly. Personal Data doesn’t include data that is no longer identifiable, where an individual’s identity has been removed such as anonymous or pseudonymised data.

 

This Privacy Notice applies to your interactions with us through our website or our services, including any data you provide to us when you send us a message, participate in an event, purchase a product or service, communicate with us, or interact with us in another expected way. 

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This Privacy Notice applies to individuals globally, however certain individuals may be entitled to additional privacy rights based on applicable laws in their respective geographic region. 

Our role.

As a service provider, our Company is considered both: 

  • a “Controller” of Personal Data that we receive from you directly through your interaction with us; and 

  • a “Processor” of Personal Data that we process on behalf of our clients to provide our services. 

 

If you have questions about our privacy practices - you can contact us at:

Our privacy practices.

1. Third-party links. 

This Privacy Notice doesn’t apply to any client or third-party services, applications, software, or websites, even if they interact with, link, or integrate with our website or services (collectively, “Third-Party Services”). These Third-Party Services are each responsible for their own privacy practices and it’s your sole responsibility to review their respective privacy notices. As an example, if you choose to interact with a link to one of our social media accounts, we’re not responsible for how those Third-Party Services collect and share data about you. 

 

We would love to encourage you to review their respective privacy notices since one of our core beliefs at Compliance Counsel is that privacy matters and we all need to work together to protect our data privacy rights.

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2. What Personal Data we collect.

We collect and process various types of Personal Data, which you provide directly to us or which we may receive through our clients and Third-Party Services. Our data collection includes the following types of Personal Data: 

 

  • Identifiers: Such as your name, email address, telephone number, and IP address.

  • Customer records: such as your signature, identification number, financial information and account records. 

  • Protected characteristics: details such as your age, citizenship, sex, and military status (collected only where necessary and lawful). 

  • Financial data: billing and account details for transaction processing.

  • Internet and network activity: such as your browsing history and application usage to enhance your experience and improve our website and services. 

  • Location information: such as data derived from your IP address or device settings for service optimization. 

  • Professional data: such as your business affiliation, job title, and work contact information, relevant to B2B interactions. 

  • Other identifiable information: any other data that can reasonably be linked to you. 

 

We may also collect, use, and share de-identified or aggregated data, which is not considered Personal Data, such as statistical or demographic data for any purpose.

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3. How we use your Personal Data.

We’re committing to using your Personal Data responsibly, within the spirit of data minimization, and solely for the purposes for which it was collected. Here are the primary ways we may use your Personal Data:

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4. How we share your Personal Data

We may share your Personal Data with third parties to fulfill our legal obligations. Here are some examples of when we may share your Personal Data:

  • On behalf of our Clients. To fulfill our contractual obligations, we may share your Personal Data under the instructions of our clients, who act as ‘data controllers’, in compliance with applicable laws and regulations. 

  • Third-Party Services. Your Personal Data may be shared with Third-Party Service providers who support our website and/or service (for example, cloud hosting providers, software applications, payment processors, etc.) These Third-Party Service providers are considered ‘sub-processors’ under applicable data protection laws. Please visit our Third-Party Services page for additional information and a list of our Third-Party Services. We encourage you to review this documentation regularly for updates.

  • Business changes. In events such as a merger, acquisition, or sale of our assets or business, your Personal Data may be transferred or shared in compliance with confidentiality agreements to applicable parties. Any new owners will be bound to the obligations set forth in this Privacy Notice in regards to handling  your Personal Data. 

  • For legal reasons. We may disclose your Personal Data to:

    • Address legal claims or comply with legal proceedings (including subpoenas);

    • Protect our rights, property, safety, and those of others;

    • Comply with applicable laws and regulations;

    • Respond to lawful public authority requests, including national security or law enforcement matters; and

    • To prevent or take action against possible violations of our terms and conditions.

  • At your direction. With your consent or upon your direction, we may share your Personal Data with third parties for other purposes. We provide mechanisms for you to express your preferences regarding how and with whom your data is shared. 

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We have not and do not plan on selling your Personal Data.

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5. Data security.

We care about security and have put appropriate technical and administrative safeguards, i.e. security measures, in place to protect your Personal Data. Our Company follows the principle of least privilege and has controls in place to limit employee, agent, contractor, and other third party access to your Personal Data. Their access is limited on a need-to-know basis and is further protected by confidentiality agreements. They will only process your Personal Data based on our instructions, subject to their confidentiality, and contractual obligations.

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6. Data retention. 

We will retain your Personal Data only as long as reasonably necessary to fulfill the purposes we collected it for, and to comply with our legal, regulatory, tax, accounting, and other business obligations. This includes retention for longer periods in the event of a complaint or potential litigation. The retention period is determined based on the nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, and our operational requirements. You have the right to request deletion of your data under certain conditions. In some instances, we may anonymize your data for research or statistical purposes, in which case it may be used indefinitely without further notice.

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7. What are your data privacy rights?

Under applicable data privacy laws, you may have rights related to your Personal Data. These include the ability to:

  • Access your Personal Data. You have the right to request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

  • Correct your Personal Data.  If you believe that any Personal Data we hold about you is incorrect or incomplete, you have the right to request that we correct or complete it. 

  • Erase your Personal Data. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is also known as the ‘right to be forgotten.’

  • Object to processing. You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

  • Restrict processing. You have the right to request the temporary suspension of the processing of your Personal Data in certain scenarios, such as if you want us to establish its accuracy or the reason for processing it.

  • Transfer your data. You have the right to request the transfer of your Personal Data to another party in certain circumstances.

  • Withdraw consent. You have the right to revoke your consent to the processing of your Personal Data at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

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8. Responding to your requests.

We aim to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

 

To exercise your rights under this Privacy Notice, please reach out to us via mail or send an email to privacy@compliancecounsel.com.

 

To make it easier to prioritize your privacy request, please use the following subject line in your email: “Request related to your privacy practices.” 

 

Once we receive your request, we’ll ask you for some additional information to ensure that we can verify your identity and then we will respond to your request within a reasonable amount of time. We aim to respond to verifiable privacy requests within forty-five (45) days of receipt. If we need more time (no more than 90 days), we’ll inform you of the extension via email. If you have an account with us, we’ll reply back to the email address associated with your account. If you don’t have an account with us, we’ll respond to the email address that we received from you when you sent in your request.

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9. No use by minors.

Our website and services are not intended for individuals under the age of sixteen (16). We do not knowingly collect, use, or disclose Personal Data from children or minors. If we become aware that we have collected Personal Data from a child or minor, without a parent’s consent, we will take steps to remove that information from our systems. If you believe that we may have information about or from a child or minor, please contact us immediately so that we can take appropriate action.

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10. Do not track disclosure. 

At this time, our website does not support “Do Not Track” (DNT) signals, however users can opt to use private web browsers to visit our website and we provide options for you to manage your data privacy, including opting out of certain tracking technologies. Please refer to our cookie policy for additional details. We will continue to monitor developments in the DNT space and may adjust our practices accordingly. 

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11. International transfers.

We offer our services globally, which means we may transfer your Personal Data into or outside of the United States in order to deliver our services and to operate our website. We are committed to protecting your Personal Data and comply with applicable data protection regulations, including data residency and international transfer requirements. In the case of international transfers, we have the following measures in place to protect your Personal Data: 

 

  • Adequacy decisions. We may transfer Personal Data to countries that have been recognized by relevant authorities as providing an adequate level of data protection. 

  • Data Protection Agreements. When transferring data to countries without adequacy decisions, we use data protection agreements with standard contractual clauses approved by relevant authorities or other legal mechanisms to protect your Personal Data.

 

Our international data transfer practices are designed to comply with applicable data protection laws, including the GDPR for European data subjects, and reflect our commitment to maintaining the privacy and security of your personal data, regardless of where it is processed.

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Please note, the legal landscape for data protection and international data transfers is subject to change, and we continuously review and update our practices in response to legal developments. For more information about how we protect your data during international transfers, please contact us directly.

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12. Complaints.

If you have any concerns or complaints about our use of your Personal Data, we encourage you to reach out to us so that we can try our best to resolve your concerns.

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13. Applicable law.

This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of Texas, applicable to contracts deemed to be made within such State, without regard to choice of law or conflict of law provisions thereof.

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14. Changes to this notice.

We’re committed to improving our website and our services and may need to make changes to this Privacy Notice from time to time and we’re entitled to do so at our sole discretion at any time. 

 

If we make any material changes, we’ll notify you by adding a statement to our website, providing you with an in-app notification, and/or sending you an email when we’re required to do so by applicable law. 

 

You can see when our Privacy Notice was last updated by checking the date at the top of the Notice. 

 

By continuing to interact with us and using our services after an updated Privacy Notice has been posted, you agree to be bound by the terms of the updated Privacy Notice. You’re responsible for periodically reviewing this Privacy Notice to ensure that you stay informed about our privacy practices. Should you have an objection to or a question about a change in this Privacy Notice, please contact us.

 

It’s important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

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15. Contact us.

We’re here to help you navigate your privacy needs and if you have questions about our privacy practices, you can contact us via email or mail at: 

  • Via email: privacy@compliancecounsel.com

  • Via mail at: ATTN: Privacy Team

    • Compliance Counsel, LLC 

    • 5900 Balcones Drive, STE 10

    • Austin, TX 78731 U.S.

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16. Thank you.

Thank you for taking the time to review our privacy practices. We do really care about your privacy and believe that the right to privacy does matter. So if you've made it this far, we appreciate you taking the time to read our Privacy Notice.

We believe that your privacy rights are important and we will try our best to protect your privacy.

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