Complion Privacy Statement

Your privacy is important to us. This privacy statement explains the personal data Complion processes, how Complion processes it, and for what purposes.

Last Updated: 25 June 2020

Responsible Entity

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.

Privacy Shield

Complion complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield.  Complion has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Personal Data We Collect

Complion collects data from you, through our interactions with you and through our products. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our products.

The data we collect depends on the context of your interactions with Complion and the choices you make, including your privacy settings and the products and features you use. We also obtain data about you from third parties.

If you represent an organization, such as a business or school, that utilizes Enterprise products from Complion, please see the Enterprise products section of this privacy statement to learn how we process your data.

If you are an end user of a Complion enterprise product provided by your organization, please see the Enterprise Products section for more information.

How Personal Data Is Used

Complion use the data we collect to provide you with appropriate experiences with Complion. In particular, we use data to:

  • Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
  • Improve and develop our products.
  • Personalize our products.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, and doing research.

In carrying out these purposes, we combine data we collect from different contexts or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing.

Reasons We Share Personal Data

We share your personal data with your consent or to complete any transaction or provide any product you have requested or authorized. We also share data with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights and property of Complion and its customers.

Types of Parties We Transfer Data To

We share data with the following types of third parties:

  • Data processing partners, for example, services that render functionality in our product.
  • Fraud detection partners for securing client data and our compute infrastructure.
  • Error tracking parties for detecting and resolving issues that arise in our products and services.
  • Compute infrastructure partners, for example, services within which our products and services operate.

How to Access and Control Your Personal Data

You can also make choices about the collection and use of your data by Complion. You can control your personal data that Complion has obtained, and exercise your data protection rights, by contacting Complion or using tools we provide.

In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.

How you can access or control your personal data will also depend on which products you use. For example:

  • Choose whether you wish to receive promotional emails from Complion through the unsubscribe link provided in an email.
  • Inform any Complion sales representative you no longer wish to be contacted.

Cookies and Other Storage Technology

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign in, combating fraud, analyzing how our products perform, and fulfilling other legitimate purposes.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

Products Provided by Your Organization

If you use a Complion product with an account provided by an organization you are affiliated with, that organization can:

  • Control and administer your Complion product and product account, including controlling privacy-related settings of the product or product account.
  • Access and process your data, including the interaction data, diagnostic data, and the contents of your communications and files associated with your Complion product and product accounts.

If you lose access to your work or school account (in event of change of employment, for example), you may lose access to products and the content associated with those products.

Complion products are intended for use by organizations, such as schools and businesses. If your organization provides you with access to Complion products, your use of the Complion products is subject to your organization’s policies, if any.

You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator.

Complion is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.

When you use a Complion product provided by your organization, Complion’s processing of your personal data in connection with that product is governed by a contract between Complion and your organization.

Complion processes your personal data to provide the product to your organization and you, and for Complion’s legitimate business operations related to providing the product as described in the Enterprise Products section.

As mentioned above, if you have questions about Complion’s processing of your personal data in connection with providing products to your organization, please contact your organization.

Enterprise Products

Enterperise Products are Complion products are related software offered to use by organizations. Currently, this includes:

  • Complion
  • Complion Enterprise

When a customer tries, purchases, uses, or subscribes to Enterprise Products, or obtains support for or professional services with such products, Complion receives data from you and collects and generates data to provide the service (including improving, securing, and updating the service), conduct our legitimate business operations, and communicate with the customer. For example:

  • When a customer engages with a Complion sales representative, we collect the customer’s name and contact data, along with information about the customer’s organization, to support that engagement.
  • When a customer interacts with a Complion support professional, we collect usage data or error reports to diagnose and resolve problems.
  • When a customer pays for products, we collect contact and payment data to process the payment.
  • When Complion sends communications to a customer, we use data to personalize the content of the communication.
  • When a customer engages with Complion for professional services, we collect the name and contact data of the customer’s designated point of contact and use information provided by the customer to perform the services that the customer has requested.

Dispute Resolution

Complion complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield.  Complion has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/    

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Complion is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission. 

Pursuant to the Privacy Shield Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@complion.com. If requested to remove data, we will respond within a reasonable timeframe. 

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@complion.com.  

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

Complion’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Complion remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Complion proves that it is not responsible for the event giving rise to the damage. 

In compliance with the Privacy Shield Principles, Complion commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and United Kingdom individuals with Privacy Shield inquiries or complaints should first contact Complion at:

Charles Shamaly
VP, Engineering and Operations
privacy@complion.com

Complion has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/   for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

See Also