Last Revised and Effective as of: February 6, 2020
The Commure Privacy Statements do not apply to any other services or products operated by us, nor do they apply to any third-party websites, products, or services. When using our website, you may encounter embedded content, such as YouTube videos, or you may be directed to other websites. Our provision of a link to any other website or third-party services is for your convenience and does not signify our endorsement of such website or any services, contents, or business practices associated therewith. When you click on such a link, you will leave our Site and go to another site. During this process, a third party may collect information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content and the collection and processing of your information by those websites and third parties fall outside the scope of the Commure Privacy Statements. We encourage you to carefully review the privacy statement of those websites and any website you visit.
What Categories of Personal Information We Collect
Registration Information. When you register to receive information regarding our products or services or to create an account with us via the Site, you may provide us with your personal information, such as your name, email address, phone number, address, job title, and/or employer’s name.
Correspondence Information. When you correspond with us (whether by email, feedback tools, online forms, or any other form of communication), you may provide us with personal information, such as your name, email address, phone number, address, and other information that you may choose to provide or communicate to us.
Job Candidate Information. If you submit a job application or reach out to us with regards to an employment opportunity, you may provide us with your name, email address, phone number, address, and details regarding your employment and academic history. We may also collect the information described above via recruiting agencies acting on either our or your behalf or via other third-party service providers that we leverage to search for and evaluate potential candidates (e.g., LinkedIn).
User & Use Information. When you visit our Site and use our Services, we may collect or generate certain device attributes and other online identifiers from you and information regarding your interactions with our Site and Services. Such device and other online identifiers may include your IP address, unique identifiers (UIDs), and device fingerprints, which are typically generated using combinations of IP addresses, UIDs, and/or device attributes such as device type, operating system, device ID, browser type, user agent, etc.. Such information regarding your interactions with our Site and Services may include which pages you visit, which links you click on, and which images and objects you interact with. We may also collect such information via our partners and service providers during the course of your interactions with our websites, products, and/or services.
Cookies and Similar Technologies
We use various cookies and similar technologies, including web beacons and local storage, on our Site. For information regarding the cookies and similar technologies we may use, please see our Cookie Notice.
How We Use Your Information
We only use your personal information for the legitimate business purposes set forth below:
Products and Services. We may use your personal information to operate and provide the Site and the Services (including to troubleshoot and resolve any bugs or other issues with the Site and Services), personalize and enhance the Site and Services, and develop new websites, products. services, features and functionalities.
Sales, Advertising and Marketing. We may, either directly or through our partners and service providers, use your personal information to develop, support, analyze the effectiveness of, enhance, and personalize our marketing and advertising campaigns and to provide you with ads and marketing materials. We may also use your information to otherwise contact you to sell or otherwise promote our products and services and to assist you in purchasing our products or services.
Employment Opportunities. We may use your information in with our recruiting, evaluating, and processing you as a candidate for open employment opportunities.
Security, Investigatory, and Legal Matters. We may use your personal information to: (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist or respond to government enforcement or regulatory agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against third-party claims or allegations; (4) protect the security and integrity of our websites, products, and services; (5) exercise or protect the rights and safety of us, our customers or others; or (6) comply with our legal obligations, including our obligations to comply with subpoenas, court orders, or any regulatory or other legal process.
Analysis. We may use your information for analyzing usage trends and patterns and measuring the effectiveness of content, programs, features and functionality of the Site and Services.
Permission and Other Purposes. We may use your personal information when we otherwise have your permission or for any other purpose described in the Commure Privacy Statements. And finally, we may use anonymized information derived from your personal information for legitimate business purposes other than those specified in this Policy.
With Whom We Share Your Information
Service Providers. We may share your personal information with individuals or entities that provide services to or on our behalf. For example, we may share your IP address and device fingerprint information with our service providers in order to help ensure the security and integrity of our website, products, and/or services. We may also share your account registration information with our service providers who manage the account login portals for our websites, products, and services. Or we may share your name, contact information, and employment history with recruiters to assist us in finding and evaluating candidates for available employment opportunities.
Affiliates. We may share your information with our affiliates to operate, provide, develop, enhance, and personalize our websites, products or services and to otherwise assist us in processing your information for the purposes described in How We Use Your Information. For example, we may also share your information with our affiliates in connection with our evaluation of you as a potential job candidate for a position offered by us or one of our affiliates.
Third Parties in Connection with Security, Investigatory, and Legal Matters. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to: (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against third-party claims or allegations; (4) protect the security or integrity of our website, products, or services; (5) exercise or protect the rights and safety of us, our customers, or others; or (6) comply with our legal obligations.
Third Parties in Connection with Change of Control or Sale. We may also share your personal information to third-parties (e.g., purchasers and their financial and legal representatives) in connection with a sale, merger, or change in control of us or our assets, including in preparation for any such event. Any entity which buys us or any part of our business will have the right to continue to use your personal information, but only in the manner described in this Privacy Notice or as you may otherwise agree.
We Do Not Sell Your Information
We do not sell your personal information to third parties. It’s that simple.
Security of Your Information
In furtherance of our commitment to respecting your privacy rights, we maintain physical, technical and administrative safeguards that are designed to help protect the security of your personal information, and we review, test, and update such measures on an ongoing basis. It is important to remember, however, that no system or method of transmission is 100% secure. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our Site or Services.
Data Storage and Retention
We retain your personal information for a period that we believe to be reasonably necessary for the purposes for which we process such information or as otherwise required by law.
Transfer of Personal Data to the United States
We maintain our headquarters and the vast majority of our processing operations within the United States. As such, your personal data may be transferred to the United States, a country with privacy laws that may not be deemed to provide the same level of protection as the jurisdiction in which you reside. For example, the United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Although we will implement and maintain safeguards to mitigate the risk associated with the transfer of personal data to countries whose privacy laws may not afford you the same degree of protection as the laws of the country in which you are located, we cannot guarantee that such measures will fully mitigate such risks.
Your Privacy Rights
Depending upon where you’re located, the laws to which we are subject, and other factors, you may have certain rights regarding your personal information. Such rights may include:
- Right to Access: Learn more about the categories of your personal information we process, the purposes for which we process it and the categories of recipients with whom we share it, and to access such personal information;
- Right to Rectification: Rectify any inaccurate personal information of yours and ensure it is complete for the purposes for which we process it;
- Right to Erasure (Right to be Forgotten): Delete your personal information in certain circumstances;
- Right to Restrict: Restrict our processing of your personal information in certain circumstances;
- Right to Object: Object to our processing of your personal information;
- Right to Object Against Automated Decision-Making: Not be subject to a decision based solely on automated processing, including profiling, which produces legal or other similar effects ("Automated Decision-Making") (Note: Automated Decision-Making currently does not take place on our websites or in our services);
- Right to Data Portability: Right to receive a copy of your personal information and to transfer your personal information to another controller;
- Right to Withdraw your Consent: Withdraw your consent to process your personal information at any time (to the extent we base processing on consent); and
- Right Against Discrimination: Not be discriminated against for exercising your rights described above.
Please note that your rights may vary depending upon your location, and certain personal information may be exempt from such requests under applicable law.
For individuals located in the European Union, you can find more information regarding your privacy rights here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en
If you wish to exercise your privacy rights, please contact us via email at email@example.com. You may authorize an agent to submit such requests on your behalf. We may require you to verify your identity or require your authorized agent to verify their identity, your identity, and their authority to act on your behalf before fulfilling a request to exercise your rights.
Changes to the Commure Privacy Statements.
We may update the Commure Privacy Statements from time to time to reflect changes in our practices or business, the Site or Services, or other factors. If we do, we will post the updated Commure Privacy Statement(s) as well as the effective date of such updates.
Because the Commure Privacy Statements can change at any time, we encourage you to periodically review them to stay informed about our collection, processing, and sharing of your personal information.
Our Site and Services are not directed toward children. Children under the age of eighteen years old are not eligible to use our Services, and we therefore ask that children do not submit any personal information to us, or use our Services provided on, through or via our Site. If you are a parent or guardian of a child and believe that your child provided us with their personal information, please contact us at firstname.lastname@example.org.
Questions, Concerns, or Complaints
If you have any questions, concerns, or complaints regarding the Commure Privacy Statements or our practices regarding your personal information, please contact us at:
Mail: Commure, Inc.Attn: Privacy Department 376 Brannan Street San Francisco, CA 94107