Complion Privacy Policy

Last Updated: June 1, 2022

Introduction

Complion, Inc. (“Company,”Us” or “We”) respect(s) your privacy and are committed to protecting it through our compliance with this policy.  

This privacy policy ( the “Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.complion.com, or our any other of our proprietary services, websites or platform controlled by us on the several variants of our websites and/or API services (collectively and interchangibly, the “Sites” or the “Services”) practices for collecting, using, maintaining, protecting, and disclosing that information.  We also may receive your personal information (including Protected Health Information) from our customers and/or agents.

This policy applies to the information we collect: (1) On any of our Sites or through our Services; (2) In electronic communications, including electronic mail, text, and other electronic messages between you and Us through any of our Sites; or (3) When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

The policy does not apply to information collected by: (1) Us offline or through any other means, including on any other website not operated by Us or otherwise by any third party; or (2) Any third party, including through any application or content (including advertising) that may link to or be accessible from or on any of the Sites or through the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using our Sites or Services, you agree to this Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Site, including information:

  • By which you may be personally identified, such as name, e-mail address, or any other identifier by which you may be contacted online or offline (“Collected Information”);
  • That is about you but individually does not identify you; 
  • About your internet connection, the equipment you use to access our Site, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and web beacons.
  • From third parties, for example, our business partners.

Information You Provide to Us.

The information we collect on or through our Site may include:

  • Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Site.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Details of transactions you carry out through our Site and your use of the Site.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Site, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Site.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include Collected Information, but we may maintain it or associate it with Collected Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

  • Estimate usage patterns and the size of our user base.
  • Store information about your preferences, allowing us to customize our Site according to your individual usage patterns.
  • Speed up system operations on the Site.
  • Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
  • Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not gather Collected Information automatically, but we may tie this information to Personal Information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Collected Information or they may gather information, including Collected Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Collected Information:

  • To present our Site and its contents to you.
  • To provide you with information or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you, your organization, and Us, including for billing and collection.
  • To notify you about changes to our Site or any services we offer or provide though it.
  • To allow you to participate in interactive features on our Site.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Collected Information that we gather or you provide as described in this Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Collected Information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Complion, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Collected Information held by Complion, Inc. about our Site users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your Collected Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Complion, Inc., our customers, or others. 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Collected Information you provide to us. We have created mechanisms to provide you with the following control over your information: 

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your email address or contact information used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to privacy@complion.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional Personal Information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit the CCPA privacy notice for California Residents.

California’s “shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@complion.com or write us at: 1500 W 3rd St Suite 501, Cleveland, Ohio 44114.

First, California consumers can opt out of the sale of their Personal Information. However, this option is not applicable as Complion, Inc. does not sell your Personal Information.

Second, California consumers can request to know:

  • What specific pieces of information a business has collected about the consumer;
  • Categories of Personal Information it has collected about the consumer;
  • Categories of sources from which the Personal Information is collected;
  • Categories of Personal Information that the business sold or disclosed for a business purpose about the consumer;
  • Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
  • The business or commercial purpose for collecting or selling Collected Information.

Third, California consumers can request that a business delete Collected Information about the consumer that a business has collected from the consumer.

This Policy provides the required notices to California consumers. The categories of Collected Information we collect and disclose for business purposes in the preceding 12 months are described above. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the CCPA.

To make a “Request to Know” or “Request to Delete” your Collected Information, please submit to us a Data Subject Access Request (DSAR) Form by either:

  • Emailing a completed and signed DSAR Form to privacy@complion.com.
  • Please put either “Request to Know” or “Request to Delete” in the subject line of your email.

Note: Authorized agents may also complete and submit the Interactive Request Form on behalf of a California Consumer.

We will confirm receipt of your request within 10 business days. We must provide the requested information or delete your Collected Information within 45 days of receipt of your request, but we can use up to an additional 45 days if we let you know that additional time is needed.

Before responding, we must verify that the person making the request is the person about whom we have collected their Collected Information. We may ask you to provide certain, limited Collected Information, such as your name and email address to verify and match your identity with our records and systems. If you have an account with us, we may ask that you verify your identity through our account authentication process. This is also to protect against fraud. We will not retain this Collected Information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months. There may be cases where we do not have any Collected Information about you or we are not able to verify your identity for matching purposes. Deleting your Collected Information may result in the closing of your account and inability to access the Sites and Services. However, you can always re-register at any time.

Data Security

We have implemented measures designed to secure your Collected Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Collected Information, we cannot guarantee the security of your Collected Information transmitted to our Site. Any transmission of Collected Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
The security of your Collected Information is very important to us. While we strive to put in place
HIPAA. As described above, we have taken steps to ensure compliance with HIPAA requirements for PHI, including the Security Rule with respect to electronic PHI.
We will retain your Collected Information for the period necessary to fulfill the purposes described in this Policy unless a longer retention period is required by law. When there is no longer a legitimate need to retain your information, we will securely delete or anonymize it, or if this is not possible, securely store it until deletion is possible.

Children and Study Participant Personal Data

The Sites and Services are generally intended to be accessed and used by adults. If we become aware that we have collected the information of minors who have accessed our Sites, we will take steps to delete it from our systems and records as appropriate.

In some circumstances, we may be provided Collected Information (including Protected Health Information) of children and/or study participants by our customers via our Services. As this information is part of their research activities, we are not in a position to delete or revise it.

Questions (including technical difficulties, support requests, and data subject requests, etc.) from children and/or study participants should be directed to the research team (e.g., clinical site and/or sponsor) and not to Complion. We will obtain appropriate consent or rely on other legitimate basis as may be required to collect and retain children’s and/or a study participant’s Collected Information for purposes of a study. 

Study Participants as Complion Services Users

Our Services include proprietary software and tools (as applicable and made available to the end-user). Study participants who access Our Services will have minimal Collected Information collected on them to enable our customer-driven workflows and contractual obligations. This Collected Information will not be used for any other purpose nor disclosed to any third parties that would use such information for their own purposes.

European Users

Note that EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain Collected Information relating to you in the United States. Upon request, we will provide you with access to the Collected 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, 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 Collected Information, please submit a written request to privacy@complion.com.

EEA Privacy Rights

The Legal Basis for Using EEA Collected Information

For residents of the European Economic Area (EEA), we advise that your Collected Information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”). Our legal basis for collecting and using your Collected Information is to do so with your consent; where we need the Collected Information for performance of a contract or requested Service, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Collected Information in question. If we collected your Collected Information with your consent, you may withdraw your consent at any time.

Our retention of your Collected Information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.

To the extent that we transfer Collected Information from the EEA to a jurisdiction outside the EEA that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such Collected Information is safeguarded through appropriate contractual terms, such as the Standard Contractual Clauses, or other approved mechanisms.

Where legally required, We may request to execute its separate Data Processing Agreement (DPA) with you. 

Additional Rights for EEA Residents

In addition, if you are a resident of the EEA, you have the right to:

  • Find out if we use your Collected Information, to access your Collected Information, and receive copies of your Collected Information.
  • Withdraw any express consent that you have provided to the processing of your Collected Information at any time without penalty.
  • Access your Collected Information and have it corrected or amended if it is inaccurate or incomplete. Note: where Collected Information is processed solely for clinical research, access may be restricted and/or denied. Whenever possible, Complion will honor your right to access by redacting information if your request would otherwise be restricted and/or denied.
  • Obtain a transferable copy of some of your Collected Information which can be transferred to another provider when the Collected Information was processed based on your consent.
  • If you believe your Collected Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Collected Information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
  • Request your Collected Information be deleted or restricted under certain circumstances. For example, if We are using your Collected Information on the basis of your consent and have no other legal basis to use such, you may request your Collected Information be deleted when you withdraw your consent.

Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Collected Information conducted in reliance on lawful processing grounds other than consent.

If we ask you to provide Collected Information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Collected Information is required and if not, the consequences of not sharing your Collected Information with us.

Similarly, if we collect and use your Collected Information in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.

We endeavor to apply suitable safeguards to protect the privacy and security of your Collected Information and to use it only consistent with your relationship with us and the practices described in this Policy.

To withdraw consent or exercise these rights, please contact us via email at privacy@complion.com.

If you are not satisfied with our response, or believe we are processing your Collected Information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your jurisdiction. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en 

Third Party Links and Services

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third party operating any site or service to which the Site(s) link. The inclusion of a link on the Sites does not imply our endorsement of the linked site or service. Please note that we are not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of other organizations.

Changes to Our Policy

It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us.  To register a complaint or concern, please email privacy@complion.com.

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