Comprise Technologies, Inc (“Comprise”, “we”, “us” or “our”) is committed to respecting and protecting the accuracy, confidentiality and security of your personal information, and wants you to feel secure when visiting our website (the “Website”), downloading our mobile device applications (the “Mobile Apps”), and using our services (the “Services”). This Privacy Policy sets out our policies concerning the collection, use, disclosure and protection of personal information we receive from individuals using the Website, the Mobile Apps or the Services.

“Personal information” means all information about an identifiable individual.

Unless otherwise agreed to in writing by Comprise Technologies, Inc., by using the Website, the Mobile Apps or the Services, you will be deemed to have consented to the terms and conditions set forth in this Privacy Policy, including (without limitation), the collection, use and disclosure of your personal information by Comprise Technologies.

IF YOU ARE NOT IN AGREEMENT WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, DO NOT SUBMIT ANY OF YOUR PERSONAL INFORMATION, USE THE WEBSITE, OR DOWNLOAD THE MOBILE APPS.

Scope of Privacy Policy

Comprise Technologies may update this Privacy Policy from time to time. We will notify you about material changes by placing a prominent notice on the Website and the Mobile Apps. It is your responsibility to review the most current version. If this Privacy Policy is updated, your continued use of this Website, the Mobile Apps or the Services and any subsequent submission of personal information by you will be deemed your conclusive acceptance of the most recent version of this Privacy Policy.

Accountability

Comprise Technologies is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.

In order to oversee overall compliance with this Privacy Policy and with applicable personal information protection laws, Comprise Technologies has designated a Privacy Officer. Contact information for Comprise Technologies Privacy Officer can be found at the end of this Privacy Policy.

Please note that if you are a corporate customer or any other type of organization, you are responsible for the legal collection and use of personal information of individuals within your organization, in accordance with the principles set out in your privacy policy and the applicable laws in the countries in which you operate. Comprise Technologies is not responsible for your privacy practices and policies.

Purposes for Collecting Personal Information

Through the Services, the Website and the Mobile Apps, Comprise Technologies collects, uses and discloses to certain third parties personal information for the following primary purposes:

The paragraphs below provide further information about what types of personal information we collect and how we use and disclose it for each of the Services, the Website and the Mobile Apps.

The Mobile Apps

For Comprise Technologies' consumer customers (i.e., individuals who download our products for their own personal use), our Mobile Apps may collect personal information such as your name, email address, documents name, documents printed, library card number and PIN (Personal Identification Number). In addition, Comprise Technologies will also collect geolocation data from your device which can be done through IP, wifi or GPS.

Comprise Technologies will use this personal information for product registration and installation purposes, as well as for customer verification. Some of this personal information may also be used by Comprise Technologies in the event that you file a report for assistance.

Comprise Technologies will try to collect personal information directly from the individual concerned unless authorized by that individual to collect it from a third party such as your ILS vendor, or as otherwise permitted by law.

If personal information is collected for any other purposes than described above (unless the purpose for collecting personal information is obvious and you provide your personal information for that purposes, or unless otherwise permitted or required by laws), Comprise Technologies will communicate the purpose of collecting the personal information to you at the time of collection, either orally or in writing, as well as its use and how it may be disclosed.

If personal information is gathered in writing, the purpose of its collection will be communicated through printed materials, the Website or email. If personal information is gathered orally, Comprise Technologies will provide an oral explanation of the purpose for the collection and use.

Consent

As indicated at the top of this Privacy Policy, unless otherwise agreed to in writing by Comprise Technologies, by using the Website, the Mobile Apps or the services, you will be deemed to have consented to the terms and conditions set forth in this Privacy Policy, including (without limitation), the collection, use and disclosure of your personal information by Comprise Technologies.

IF YOU ARE NOT IN AGREEMENT WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, DO NOT SUBMIT ANY OF YOUR PERSONAL INFORMATION, USE THE WEBSITE OR DOWNLOAD THE MOBILE APPS.

As a general principle, Comprise Technologies will obtain your consent before collecting, using or disclosing your personal information for any purpose other than as identified in this Privacy Policy. Comprise Technologies will make an exception only where legal, medical or security reasons make it impossible or impractical to obtain consent, as discussed further below. We will make reasonable efforts to ensure you understand how your personal information may be used or disclosed. If Comprise Technologies plans to use previously-collected personal information for a new use that is incompatible with the original purpose, you will be informed of the new purpose, and we will obtain consent from you prior to this new use.

The form of consent can vary, depending on the sensitivity of the information and the circumstances. Consent may be express or implied depending on the nature of the personal information or the use. At times, consent for one use can fairly be implied to include consent for other included or related uses. When determining the appropriate form of consent, Comprise Technologies will be guided by what a reasonable person would consider fair and appropriate in the circumstances.

Your consent may be provided to Comprise Technologies orally, in writing or electronically, either personally or through an authorized individual. Consent can be implied when you are informed that information will be used for certain purposes and you submit the information with this knowledge, or consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.

Comprise Technologies may collect, use or disclose personal information without your knowledge or consent in the following limited circumstances:

Subject to certain exceptions (e.g. where the personal information is necessary to provide Services, or the withdrawal of consent would frustrate the performance of a legal obligation), you may withdraw or refuse to provide your consent to Comprise Technologies, or request that your personal information be removed from our databases and records, by giving reasonable notice. All communications with respect to the withdrawal of consent should be made in writing and addressed to Comprise Technologies'Privacy Officer.

If you refuse or withdraw consent, or request that your personal information be removed from our databases and records, Comprise Technologies will make you aware of the likely consequences of this action. In some cases, it may prevent Comprise Technologies from providing you with the Services.

Limited Collection

Comprise Technologies will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified. Comprise Technologies will not collect excessive personal information, and will limit the purposes of collection to what a reasonable person would consider fair and appropriate in the circumstances.

Comprise Technologies will collect personal information only by fair and lawful means, will be transparent, up front and open with you, and will communicate in a manner that is clear and reasonably understood.

Limited Use, Disclosure and Retention

Comprise Technologies will use and disclose personal information only as described in this Privacy Policy, or for the purposes for which it was collected, or as agreed by you, or without your consent for the limited circumstances listed above in the section titled “Consent”. We will not use or disclose personal information for any additional purpose that is incompatible with the original purpose unless we obtain consent to do so. We will not sell your personal information to other parties.

Comprise Technologies may share personal information with our employees, contractors, consultants, service providers, business partners and other parties who require such information to assist us with providing you with the Services. By providing personal information to Comprise Technologies, you will be deemed to have consented to the disclosure of your personal information to such parties.

The use, collection and disclosure of personal information may involve Comprise Technologies transferring personal information across borders. If this occurs, we will comply with all applicable trans-border data flow privacy laws.

Comprise Technologies will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required for legal or business purposes. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous. If you have an account with Comprise Technologies, any personal information will be destroyed, deleted or made anonymous once your account has been inactive for two years.

Accuracy

Comprise Technologies will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. Comprise Technologies does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. Comprise Technologies therefore relies on you to keep your personal information accurate and current.

You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Comprise Technologies'Privacy Officer and must provide sufficient detail to identify the personal information and the correction being sought.

If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.

Safeguarding Personal Information

Comprise Technologies will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Comprise Technologies as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the personal information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically). Comprise Technologies'security safeguards include locked filing cabinets, physically secured offices where personal information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.

Comprise Technologies will use appropriate security measures when disposing of and destroying personal information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.

Comprise Technologies trains all staff who handle personal information on the importance of and procedure for maintaining confidentiality. All employees, contractors, consultants and service providers of Comprise Technologies who are provided access to personal information on behalf of Comprise Technologies are required to be familiar with and comply with the provisions of this Privacy Policy and applicable laws.

Comprise Technologies will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Comprise Technologies will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Comprise Technologies and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a Privacy Commissioner or similar regulatory body in any relevant jurisdiction.

Comprise Technologies will also continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Openness

This Privacy Policy is available to the public on our Website, so that information about our policies and practices relating to the management of information is readily available to everyone.

Requests for Access

You have the right to access your personal information, subject to limited exceptions under applicable laws such as solicitor-client privilege, disclosure that would reveal personal information about another person, legal obligations and proprietary rights. Comprise Technologies'Privacy Officer will assist you with your request. This includes:

All requests should be made in writing (by mail, fax or email), provide sufficient detail to identify the information being sought, and be directed to Comprise Technologies'Privacy Officer. Comprise Technologies'Privacy Officer may require further information defining the request more succinctly.

We will respond to written requests within thirty (30) days of receiving such request. We will either make the requested information available within that time period, or provide written notice of an extension where additional time is required to fulfill the request. If Comprise Technologies cannot fulfill your request in full or in part, you will be provided with a response in writing that documents the reason for refusal and the recourse available to you.

A minimal fee may be charged for providing access to personal information, where permitted under applicable law. Where a fee applies, we will inform you of the cost and request further directions from you on whether or not we should proceed with your request.

Complaint Procedure

Complaints, concerns or inquiries about Comprise Technologies' privacy policies and practices, including compliance with this Privacy Policy, should be made in writing to:

Privacy Officer
Comprise Technologies, Inc.
1041 Route 36, Building B
Navesink, NJ 07752
USA
Tel: 732-291-3600
Fax: 732-291-3699
Email: techsupport@CompriseTechnologies.com

Specific details about the inquiry or complaint must be provided. All complaints will be investigated and will be responded to in accordance with the section above as well as applicable laws. If the Comprise Technologies Privacy Officer is unable to address your concerns, the issue may be escalated to the office of the CEO or to the relevant Privacy Commissioner or similar regulatory authority.