Privacy Policy

Your privacy is important to us

When you use VComply services, you believe us with your data. This Privacy Policy is intended to enable you to comprehend what information we collect, why we collect it, and what we do with it. This is vital; we wish you will take time out from your routineto carefully read the policy.

We at VComply are committed to protecting your privacy. This privacy policy applies to our website (www.v-comply.com), our blog (v-comply.com/blog) and our signup services on both the website and the blog and the platform we provide you after you sign up with us or become our client including our associated mobile applications (mobile apps) owned and controlled by VComply.

This privacy policy document administers and directs our data collection, processing, and usage practices. It governs your decisions regarding the choice of use, access, and correction of your personal information. By using the websites or platform or the subscription service, you consent to the data practices described in this privacy policy. If you do not agree with the data practices described in this privacy policy, you should not use the websites or the sign up service for the platform or the blog. We encourage you to review this privacy policy periodically.

Registration and use

To access the services of VComply, you are required to register on the platform by providing an email address and creating a password, and providing us with other information (if any). You are in agreement to provide us with accurate, complete, and current registration information about yourself. The security and confidentiality of your password is your responsibility. By registering, you agree that you are fully responsible for all activities conducted under your username and password. We may assume that any communications we receive under your account have been made by you.

Unauthorized account access

You understand and agree that in order to confirm your identity and help ensure the security of your account, we may require you to provide information to verify your identity. VComply has no liability to any loss, damages, liability, expenses or attorneys’ fees that you may incur due to another person utilizing your password or account, either with or without your knowledge and/or authorization and regardless of whether you have or have not educated us regarding such unauthorized use. The liability for any loses, damages, liability, expenses and attorneys’ fees incurred by VComply or a third party due to someone else using your account is on you.

Information we collect

When you interact with the website, we may collect personal data and other information from you, as further described below:

Personal data that you provide through the site: we collect personal data from you when you voluntarily provide such information, such as when you contact us with inquiries, register an account with us or submit an application to us. By voluntarily providing us with personal data, you are consenting to our use of it in accordance with this privacy policy. If you provide personal data to us, you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of VComply and the authorized third parties referred to herein located in the United States.

The kinds of data we gather will rely on the services you utilize, how you utilize them, and what you give. The kinds of information we gather specifically from you may include: – name, address, phone number and email address – discretionary data, for example, a photo, that you choose to connect with your record (your “profile data”) – login details and password, on making your VComply account – any email requests or inquiries you submit to us – demographic data, for example, your gender – user-produced content you post in public online VComply discussions. We use our own sign up service to build our webpage and blog that people can visit to learn more about our product. We collect and manage information using the sign up service for our own marketing use and it solely belongs to us and is used, disclosed and protected according to this privacy policy. In utilizing the services, you may transfer or input different kinds of content, including yet not constrained to: responsibilities, attachments, names of entities, department, and division, group names, and discussions. In the event that you are utilizing the services in connection with an account made by a VComply client (e.g., manager, association, or an individual), we gather and process the information you submit in the interest of the client. However, our clients, and not VComply, decide their own strategies with respect to storage, access, alteration, deletion, sharing, and maintenance of content which may apply to your utilization of the service. For instance, a client may give or revoke access to the service, enable or disable third party integrations, oversee permissions, maintenance and export settings, or share responsibilities. For more clarity with respect to the content that you provide when using the services, please check with the association about the policies and settings that they have instituted within the organization. If you happen to pay for our paid premium services, we will utilize a third party credit card payment processing organization to collect payment information, including your credit card number, billing address and phone number. Your payment information is stored by the third party service provider on our behalf, and VComply does not store any of this information. If you happen to utilize our invitation service to on-board a colleague or your team to the service, you would be required to feed in individual’s contact data, which may include their email address or their contact number, and automatically send an invitation. VComply stores the data you give to send the invite, to on-board your colleague if your invite is accepted, and to analyze the success of our invitation service. The websites and sign up services and the platform are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us.

Information automatically collected

When you utilize our services that connect with the Internet, including, not restricted to, when you use the services by means of our sites, your cell phones, and VComply software/applications, we consequently gather certain data as depicted in this section. As examined further below, we and our third party service providers who work on behalf to provide and improve our services, utilize an assortment of technologies, including cookies and similar tools, to help with gathering this data.

Log Files

When you utilize the services, our servers automatically record certain data in server logs. These server logs may incorporate data, for example, your web requests, Internet Protocol (“IP”) address, browser type and settings, referring/exit pages and URLs, number of sessions, time spent on the website, number of clicks and interaction with the website, metadata related with uploaded content, domain names, landing pages, pages visited, mobile carrier, date and time stamp and other such data.

Device Identifiers

When you use any of your mobile devices to access our services, we gather particular device information, including your MAC address and other unique device identifiers. We, additionally, may gather data on the kind of device you use to access our service, its operating system, and network information, which may incorporate your cell phone number. We may connect this device identifier with your account and will utilize information related to your device identifier to improve our services on your device and to analyze any device related issues.

Location Information

We gather and process general data about the location of the device from which you are accessing the service (e.g., approximate geographic location construed from an IP address).

Data we collect from third-party integrations

In the event that you utilize third-party integrations (e.g., OneDrive, Google Drive, Slack) through the services or are required to do as such by your organization, such providers may enable us and our service providers to access and store data about your interaction with those platforms as it is identified with utilization of the services. However, if you do not wish to share this information, you are advised to not initiate these connections.

Other information

Non-Identifiable Data

When you interact with VComply through the Site, we receive and store certain personally non-identifiable information. Such information cannot presently be used to specifically identify you. VComply may store such information itself or such information may be included in databases owned and maintained by VComply affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the characteristics of businesses that apply to or are accepted by VComply, and we may publish or otherwise disclose such aggregated information.

Aggregated Personal Data

In an ongoing effort to better understand and serve the users of the Site, VComply may conduct research on the characteristics of such users, including but not limited to user demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and VComply may publish or otherwise disclose such aggregated information. This aggregate information does not identify you personally.

Analytics and Tracking Technologies

We may, allow third party service providers to, use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Cookies help us to analyze how users use the Site and enhance your

experience when you use the Site. Third parties or affiliates may administer VComply banner advertising programs and other online marketing on non-VComply websites and services. To do so, these parties may set and access first-party cookies delivered from a VComply domain, or they may use third-party cookies or other tracking mechanisms.

On most web browsers, you will find a “help” section. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.

Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Our use of your personal data and other information

VComply uses the personal data you provide in a manner that is consistent with this privacy policy. If you provide personal data for a certain reason, we may use the personal data in connection with the reason for which it was provided or for other VComply related purposes. For instance (but without limitation):

• To make the site easier for you to use by entering your personal information only once.
• To provide information to allow VComply to create and publish content most relevant to its customers.
• To alert its customers to product upgrades, special offers, updated information and other new products and services.
• If you provide personal data in order to create a username and profile, we will use your personal data to provide you with access to such those components of the site that require a username (including the VComply application), to administer your access to the site (e.g., sending a replacement password to the email address you provided to us) and to monitor your use of the site.
• If you provide personal data to attend an event, we will use your personal data to give you access to that event and track the attendees of the event.
• If you provide VComply with your telephone number through any medium, you may receive telephone contact from us with information regarding new products and services or upcoming events.

VComply may also use your personal data and other personally non-identifiable information collected through the site to help us manage and administer the site, improve the site, better understand our users and improve the VComply application.Please note that when we refer to your username in this privacy policy, such username may be a username that you are permitted to create in connection with the site, depending on the circumstances.

• VComply registration: When you register on to VComply, please carefully read our privacy policy and terms of use. In the event of any conflict between the applications privacy policy and any other portion of this privacy policy or our terms of use, the applications privacy policy will control.
• You can practice certain control on how your content is utilized by/shared with others by means of your settings on the services. VComply may view and offer your content just as essential (I) to keep up, give and enhance the service; (ii)avert or address specialized or security issues and resolve support demands; (iii) If we believe or have received a grievance asserting, that such content is infringing upon our Acceptable Use Guidelines; (iv) as sensibly important to enable VComply to consent to or maintain a strategic distance from the infringement of appropriate law or direction; (v) to follow a substantial lawful subpoena, requests, or other legitimate process that meets the necessities of our Law Enforcement Guidelines; and (vi) as put forward in our Subscription Agreement with the customer or as explicitly allowed in writing by the customer. We may likewise examine your User Content in total and on an anonymized premise, so as to better comprehend the way in which our Service is being utilized.
• Under no circumstances will any information provided to VComply be sold or rented to a third party without your prior consent. However, VComply may use your contact information to send you company and product information that you requested, and for marketing analytics of VComply website traffic.
• To make the site easier for you to use by entering your personal information only once.

 

Our disclosure of your personal data and other information

In addition to the disclosures described above, there are certain circumstances in which we may share your personal data with certain third parties without further notice to you, as set forth below:

Business Transfers

In the event of a sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.

Related companies

VComply is comprised of a variety of entities, and we may share your personal data with those various entities for purposes consistent with this privacy policy. Agents, contractors, and other third parties

VComply, like many businesses, sometimes hires others to perform certain functions. Examples of such functions include mailing information and maintaining databases. When we employ or engage others to perform a function of this nature, we only provide them with the information that they need to perform their specific function under appropriate confidentiality obligations.

The service enables you to transfer and share comments or feedback freely on VComply forums and blogs. Any data that you submit to open sites isn’t classified, and VComply may utilize it for any reason (incorporating as testimonials or other VComply marketing materials). Any data you post straightforwardly in these ways will be accessible to general society everywhere and possibly available through third-party search engines. Such data can be perused, gathered as well as utilized by different users, and it could be utilized to send you messages. Appropriately, please take care when utilizing these features of service.

Legal compliance

We, VComply, reserve the right to access and disclose your information in good faith when such disclosure is necessary to: (a) enforce legal rights and comply with the law; (b) comply with an order from a government entity or other competent authority, (c) prevent or address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage; (d) protect our rights, prevent fraud and/or comply with judicial proceeding, court order, or legal process served on VComply.

Law enforcement

In specific situations, we might be required to unveil your data to government or law enforcement authorities in light of a lawful demand by a public authority or on the off chance that we need to do as such to conform to a lawful commitment, including to meet national security or law authorization necessities. We can likewise disclose your data in order to apply or enforce our terms and conditions or to respond to any cases, to secure our rights or the rights of a third party, to ensure the wellbeing of any individual or to avoid or keep away any unlawful movement (including for the purposes of fraud protection and credit risk reduction).

We work hard to protect our users from unauthorized access or data breaches.

• We use highly secured SSL encryption to secure the data on the web.
• We constantly review our data collection, storage and processing practices to guard against unauthorized access to systems.
• We restrict access to personal information to VComply employees, contractors and agents who process it for us, and are subject to strict confidentiality obligations and in case of violations, they will be terminated from the services.

 

Your profile

When you create a username for the site, please also note that your username, how long ago you created your account and any information included in the “about” field in your profile will be viewable by only you or whom you give access to. Please note that we have no obligation to delete any of your data or activity or otherwise remove their association with your profile or username.

Your choices

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain components of the Site.

Third party links and services

The services contain links to third party sites, for example, online networking sites, and integrations. If you choose to use these sites or integrations, you may reveal your data to third party websites, as well as to their users and people in general. Since these third party sites and organizations are not controlled by VComply, VComply isn’t in charge of the content or practices of those sites or organizations. The accumulation, utilization, and divulgence of your own and other data will be liable to the protection arrangements of the third party sites or services, and not this Policy. We ask you to peruse the protection and security arrangements of these third parties.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by VComply other than Personal Data collected through the Site. In addition, this Privacy Policy shall not apply to any information that we do not directly solicit from you or that you provide to VComply through the site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site (such as comments or information posted in discussion forums), information provided to VComply or any VComply personnel or members by email or through the Contact page on the Site, information provided to VComply or any VComply personnel or members by email or through the Contact page on the Site, information provided through social media platforms, information that you otherwise provide in connection with the Site outside of our application process or user profile creation process, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and VComply shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Security

VComply takes reasonable steps to protect the personal data provided via the site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the site may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal data to VComply via the internet.

Information processing and GDPR

• We restrict access to personal information to VComply employees, contractors and agents who process it for us, and are subject to strict confidentiality obligations and in case of violations, they will be terminated from the services.
• VComply provides GRC systems data to its customers. As a service provider, VComply application may collect personal data (name, email address, contact info, company name) to track the data entered into the system to ensure authentic and authorized usage.
• VComply has put in place appropriate technical and organizational measures to help ensure that its processing activities meet the requirements of GDPR, some of which we have described in this statement.
• VComply has implemented various security measures including controls, application and network level security audits by third-parties as well as robust standard operating procedures to manage any security incident in collaboration with the customer.
• VComply is committed to ensuring that it has data transfer and data management mechanisms in place as required by the GDPR.
• VComply is working with its customers to enable them with specific capabilities within its applications to assist them in meeting their GDPR requirements.
• VComply is designed to assist customers with their record keeping and accountability obligations by providing audit trails for information changes within the system which captures the data flow and user navigation from login to logout.
• VComply is designed to provide capabilities to its clients to assist responding to requests by end users exercising their rights under GDPR.
• VComply software is designed to provide customers with administrative access to manage user information along with user roles and responsibilities across the system.
• VComply will work in collaboration with clients to implement robust GDPR compliant standard operating procedures for security breach related incidents.
• VComply will actively work with clients to implement and confirm appropriate data processing agreements are in practice.

 

Data Retention Policy

VComply retains data for up to 7 years for active accounts and up to 30 days for accounts that are not active/subscribed. VComply may be allowed to retain specific data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for the defense of legal claims, for the performance of a legal obligation, or upon order of a government or judicial authority.

Data Deletion Policy

We shall delete all customer data submitted to the Services/System per the terms. Personal Data shall be processed and stored for only as long as required by the purpose they have been collected for. Personal Data collected for purposes related to the performance of a contract between VComply, and the User shall be retained until such contract has been fully performed. Data collected for the purposes of VComply’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by us by contacting us. If you want to delete your data from our systems, you can send an e-mail to help@v-comply.com requesting the deletion of the data. Upon request, we delete the data within 30 days of request.

Compliance and Cooperation With Regulatory Authorities

We regularly review our compliance with our Privacy Policy. We also adhere to several internal regulatory frameworks, along with the EU-US and Swiss-US Privacy Shield Frameworks. As and when we receive formal written complaints, we follow-up the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Other terms and conditions

Your access to and use of the site is subject to the terms of use at https://www.v-comply.com/termsofservice In addition, certain components of the site (e.g., applications to VComply)may have additional sub-policies that apply to such components of the site, and we will provide such sub-policies within the user interface for such components.

Changes to VComply’s privacy policy

The site and our operations may change from time to time. As a result, at times it may be necessary for VComply to make changes to this privacy policy. VComply reserves the right to update or modify this privacy policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any personal data. This privacy policy was last updated on the date indicated above. Your continued use of the site after any changes or revisions to this privacy policy shall indicate your agreement with the terms of such revised privacy policy.

Access to information: Contacting VComply

If you have any questions about this privacy policy or our treatment of the information you provide us, please contact us. To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal data in our possession that you have previously submitted via the site. Please also feel free to contact us if you have any questions about VComply’s privacy policy or the information practices of the site. You may contact us at: help@v-comply.com.