Complion takes our commitment to privacy seriously and believes that the right to privacy is critical. This privacy statement applies to Complion, any reference to “Complion,” “we,” “us” or the “Company” is a reference to RegBinder Inc DBA/Complion, Inc and the relevant affiliate involved in the processing activity.

Responsible Entity

Complion is the controller of your Personal Data as described in this Privacy Statement, unless expressly specified otherwise.

This Privacy Statement does not apply to the extent to which we process Personal Data in the role of processor on behalf of our customers, including where we offer to customers our cloud product and services through which our customers and/or their affiliates:

  1. send electronic communications to individuals, or
  2. otherwise collect, use, share or process Personal Data via our cloud product and services.

Non-Complion Responsible Entities

For detailed privacy information related to where a Complion customer and/or a customer affiliate who uses the Complion cloud product and services is the controller, please reach out to the respective customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Privacy Statement. 

Processing Activities

This Privacy Statement applies to the processing of Personal Data collected by us when you:

  • Visit our websites that display or link to this Privacy Statement;
  • Visit our branded social media pages;
  • Visit our office;
  • Receive communications from us, including emails, phone calls, texts or facsimile;
  • Use our cloud product and services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data;
  • Register for, attend and/or otherwise take part in our events, webinars or contests; or
  • Participate in any Complion community.

A Note on Our Website Links and Privacy

Our websites and services may contain links to other websites, applications, and services maintained by third parties. 

The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements: you should review these to better understand the privacy practices enacted by those third parties.

Personal Data We Collect

Personal Data we directly collect may include the following:

  • An expression of interest in obtaining additional information about our services, request customer support (including accessing our Help portal), use our “Contact” or similar features, register to use our websites, sign up for an event, webinar or contest, or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
  • Use and interact with our websites or emails: we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons, or similar technologies, such as internet protocol (IP) addresses or other identifiers, which may qualify as Personal Data;
  • Use and interact with our services: we automatically collect information about your device and your usage of our services, through log files and other technologies, some of which may qualify as Personal Data; and
  • Voluntarily submitting certain information to our services: such as filling out a survey about your user experience, we collect the information you have provided as part of that request.

Purposes of Personal Data Collection

Complion collects Personal Data for a variety of reasons:

  • Providing our website, product, and services: We process your Personal Data to perform our contract with you: the use of our websites and services and to fulfill our obligations under applicable terms of use or terms of service. If we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our website and to provide you with content you access and request (for example, downloading collateral from us);
  • Providing necessary functionality: We process your Personal Data to perform our contract with you for the use of our websites and services; if we have not entered into a contract with you, Complion bases the processing of your Personal Data on our legitimate interest to provide you with the required functionality needed during your use of our website, product, and/or services;
  • Managing user accounts and registration: If you have registered for an account with Complion, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
  • Handling contact and user support requests: If you fill out a chat web form, contact web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
  • Managing event registrations and attendance: We process your Personal Data to plan and host events or webinars that you have registered or that you attend, including sending communications related  to the event or webinar to you, to perform of our contract with you;
  • Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
  • Assessing and improving user experience: We process device and usage data which in some cases may be associated with your Personal Data, in order to analyze trends in order to assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering, or where we seek your valid consent;
  • Reviewing compliance with applicable usage terms: We process your Personal Data to review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
  • Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our services the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our service offering;
  • Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences;
  • Sending marketing communications: We will process your Personal Data to send you marketing information, product recommendations, and other non-transactional communications (for example, marketing newsletters or telemarketing calls) about us and our affiliates and partners, including information about our product or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent; and
  • Compliance with the law: Complion process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

With Whom Does Complion Share Your Data?

Complion may share your Personal Data. This sharing may include:

  • Contracted service providers, for example, entities that may provide information system services, payment processing, marketing, research, customer success and support, and/or data enrichment purposes;
  • Social media networks for the purposes of targeted advertising;
  • A third party involved in the event Complion is involved with a merger, dissolution, acquisition, or some other corporate structure where said third party is the controlling entity.

Any Personal Data or other information you choose to submit in blogs on our websites may be read, collected, and used by others who visit these forums.

Transfer of Data Internationally

Where Data May Go

Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates and third-parties disclosed in “With Whom Does Complion Share Your Data?”

Processing Considerations: Jurisdictions

Ergo, your Personal Data may be processed outside of the scope of your jurisdiction. These jurisdictions may not be subject to an adequacy decision by the European Commission, your local legislator, or regulator. These jurisdictions may not provide the same level of data protection as your jurisdiction.

Processing Considerations: Protections

Complion ensures the recipient of your Personal Data offers an adequate level of protection: by entering into the appropriate back-to-back agreements or standard contractual clauses for the transfer of data as approved by the European Commission which is outlined in Article 46 of the GDPR or Complion will request your prior consent to such international data transfers.

Duration of Personal Data at Complion

Stance and Methodology

Complion may retain your Personal Data for the period of time that is reasonable with the purpose of the collection of your personal data.  Complion may determine an appropriate retention period based on the amount, sensitivity, and nature of your Personal Data processed, and the relative and potential risk of harm from unauthorized use or disclosure of your Personal Data.

Post Expiry

After expiry of any applicable retention period(s), your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, Complion will put in place appropriate and reasonable measures to prevent any further use of such data.

Your Rights to Your Personal Data

Subject to local data protection laws, you have certain rights to your Personal Data; these may include:

  • Access to Personal Data held by us;
  • Correct inaccurate Personal Data;
  • To the extent permitted by law: to erase/delete your Personal Data;
  • Restrict processing of your Personal Data;
  • Transfer your Personal Data to another controller;
  • Object to the processing of your Personal Data for the reasons of legitimate business interests; and,
  • Withdraw consent of use of your Personal Data.

How to Exercise the Rights to Your Personal Data

You may exercise your rights to your Personal Data in several ways:

  • Contact Complion via the “Contact” section of our corporate web site; 
  • Call us directly via the number listed on our corporate web site; 
  • Contact us through the support channels of phone, chat, or email; or,
  • Contact your Customer Success Manager.

Customer Data and Your Rights

Our Role

As described above, we may also process Personal Data submitted by or for a customer to our cloud product and services. 

If not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data in the role of a mere processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Personal Data concerned: see the “Responsible Entity” section. 

Our Control

We are not responsible for and have no control over the privacy and data security practices of our customers: these may differ from those set forth in this Privacy Statement. 

If your Personal Data has been submitted to us by or on behalf of a Complion customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. 

Our Commitment 

We may only access a customer’s data upon instruction from that customer; if you choose to make your request directly to us, we will require the name of the customer who submitted your data to Complion. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

Security and Your Personal Data

Complion takes the utmost caution and care with your Personal Data in the form of technical, administrative, and physical controls to protect against the mishandling, unauthorized disclosure,  and misuse of your Personal Data.

These controls are part of the generally accepted standards to protect your Personal Data. However, it is important to note that no form of protection or series of protections for data processing, transmission, or storage are completely secure.

You are responsible for maintaining the security of any credentials required to access any accounts you may have with Complion. Additionally, signing out of services and limiting access to any device on which you access our product or services is your responsibility.

Changes to Our Privacy Statement

Changes to this Privacy Statement may happen over time to accommodate environmental deltas as the landscape in which Complion operates changes: these factors may include legal, technological, sociological, or intra-Complion process changes.

See Also