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MSHAWISE Privacy Policy

 

Effective date: January 1st, 2024

This Privacy Policy describes how Compli-Wise LLC (“MSHAWISE”) collects, uses and discloses information, and what choices you have with respect to the information.

‍1) Scope of this Privacy Policy

This Privacy Policy applies to MSHAWISE’s products and services, including applicable mobile and desktop applications (collectively, the “Services”), MSHAWISE.com and other MSHAWISE websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with MSHAWISE. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of MSHAWISE’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the MSHAWISE platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “MSA”), including the processing of any data submitted through the Services (“Service Data”). The organization (e.g., your employer or another entity or person) that agreed to the MSA (“Customer”) controls its instance of the Services and any associated Service Data (the “Customer Instance”).

‍2)‍ Information MSHAWISE Collects and Receives

MSHAWISE may collect, generate, and receive Service Data and other information and data (“Other Information”; Service Data and Other Information collectively “Information”)) in a variety of ways:

  • Service data. Customers and individuals granted access to a Customer Instance by a Customer (“Authorized Users”) may submit Service Data to MSHAWISE when using the Services.
  • Usage information.
  • Account information. To create or update a MSHAWISE account, you or a Customer (e.g., your employer) supply MSHAWISE with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide MSHAWISE (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
  • Usage information.
  • Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users interact with the Services. For example, MSHAWISE logs what Third Party Services are connected with the Services (if any).
  • Log data. As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  • Device information. MSHAWISE collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether MSHAWISE collects some or all of this information often depends on the type of device used and its settings.
  • Location information. MSHAWISE receives information from you, your Customer and other third parties that may help MSHAWISE approximate your location. MSHAWISE may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. MSHAWISE may also collect location information from devices in accordance with the consent process provided by your device.
  • Cookie information. MSHAWISE uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. 
  • Third-Party Services. A Customer can connect Third-Party Services to its Customer Instance. Typically, Third-Party Services are software services that integrate with MSHAWISE Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Customer Instance. MSHAWISE may also develop and offer MSHAWISE applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with MSHAWISE. For example, if a single sign-on service is connected with MSHAWISE, MSHAWISE may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to MSHAWISE to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to MSHAWISE. When a Third-Party Service is enabled, MSHAWISE is authorized to connect and access Other Information made available to MSHAWISE in accordance with any permission(s) granted by Customer (including, by its Authorized User(s)). MSHAWISE does not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
  • Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.
  • Third-party data. MSHAWISE may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners, or others that MSHAWISE engages with to make MSHAWISE’s own information better or more useful. This data may be combined with Other Information MSHAWISE collects and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
  • Additional information provided to MSHAWISE. MSHAWISE receives Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in an educational program hosted by MSHAWISE or a vendor, request support, interact with our social media accounts or otherwise communicate with MSHAWISE.
  • Information transferred via the Google API. MSHAWISE’s use and transfer of information received from Google API’s to any other app will adhere to Google API Services User Data Policy, including Limited Use requirements.
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3) How MSHAWISE Uses Information

Service Data will be used by MSHAWISE in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law. MSHAWISE is a processor of Service Data and Customer is the controller.

In addition, MSHAWISE uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, MSHAWISE uses Information:

  • To provide, update, maintain and protect our Services, Websites, and business. This includes use of Service Data and Other Information to support delivery of the Services under an MSA, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
  • As required by applicable law, legal process, or regulation.
  • To communicate with you by responding to your requests, comments, and questions. If you contact us, MSHAWISE may use Information to respond.
  • To develop and provide additional features. MSHAWISE tries to make the Services as useful as possible for Customers and Authorized Users, and MSHAWISE may use aggregated and anonymized Services Data and Other Information to develop new Services or improve existing Services.
  • To send emails and other communications. MSHAWISE may send you service, technical and other administrative emails, messages, and other types of communications. MSHAWISE may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, MSHAWISE sometimes sends emails about new product features, promotional communications, or other news about MSHAWISE. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from MSHAWISE please reach out through the contact mechanisms described below.
  • For billing, account management, and other administrative matters. MSHAWISE may need to contact you for invoicing, account management, and similar reasons and MSHAWISE uses account data to administer accounts and keep track of billing and payments.
  • To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, MSHAWISE may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

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‍4) Data Retention

MSHAWISE will retain Service Data in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law.

MSHAWISE may retain Other Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Other Information for the period of time needed for MSHAWISE to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

  • We retain customer data and credentials up to 365 days following account termination unless deletion is requested earlier.
  • We retain applicant data for up to three (3) years unless deletion is requested earlier.
  • We retain website visitor information in accordance with retention periods stated in the Cookie Policy.

 5) How MSHAWISE Shares and Discloses Information

This section describes how MSHAWISE may share and disclose Information.  MSHAWISE does not intend to collect personal information of individual consumers, and does not sell or share personal information of individuals with other businesses or organizations. The extent to which MSHAWISE collects or processes personal information is limited to business contact information for a limited number of employees of the Customers. This business contact information is necessary for MSHAWISE to perform the services requested by the Customers. Other, case-by-case instances where MSHAWISE might share business contact information of Customers’ designated employees are described below. ‍

  • Displaying and operating the Services. Because of the nature and functionality of the Services, Information will be displayed as part of the Services to Authorized Users in a Customer Instance. For example, information about which of Customer’s employees have accepted an invite to use the Services may be displayed as part of the Services.
  • Third-party service providers and partners. MSHAWISE may engage third parties as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services. To the extent necessary and applicable, these third-party service providers and partners will be bound by appropriate and commercially reasonable confidentiality obligations. 
  • Third-Party Services. Customer may enable or permit Authorized Users to enable Third- Party Services. MSHAWISE requires each Third-Party Service to disclose all permissions for information access in the Services, but MSHAWISE does not guarantee that they do so. When enabled and as requested by Customer, MSHAWISE may share Information with Third-Party Services. Third-Party Services are not owned or controlled by MSHAWISE and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the service provider for any questions.
  • Corporate affiliates. MSHAWISE may share Information with its corporate affiliates, parents, and/or subsidiaries.
  • During a change to MSHAWISE’s business. If MSHAWISE engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of MSHAWISE’s assets or stock, financing, public offering of securities, acquisition of all or a portion of MSHAWISE’s business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to appropriate and commercially reasonable confidentiality arrangements.
  • Aggregated or de-identified data. MSHAWISE may disclose or use aggregated or de-identified Information for any purpose. For example, MSHAWISE may share aggregated or de-identified Information with prospects or partners for business or research purposes.
  • To Comply with Laws. If a law enforcement or government agency sends MSHAWISE a demand for Information about a Customer, MSHAWISE shall attempt to redirect the agency to request that data directly from the Customer. As part of this effort, MSHAWISE may provide the Customer’s basic contact information to the law enforcement or government agency. If compelled to disclose Information to a law enforcement or government agency, then MSHAWISE will give the Customer reasonable notice of the demand and cooperation to allow the Customer to seek a protective order or other appropriate remedy unless MSHAWISE is legally prohibited from doing so. MSHAWISE will not voluntarily disclose Information related to a Customer to any law enforcement or government agency, unless required by public authorities, including to meet national security or law enforcement requirements.
  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of MSHAWISE or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
  • With consent. MSHAWISE may share Information with third parties when MSHAWISE has consent to do so.

‍6) Security

MSHAWISE takes the security of its services and the data associated with those services very seriously. MSHAWISE uses industry-standard technical and organizational measures to protect Information from loss, misuse, and unauthorized access or disclosure. All Information is encrypted at rest and in transit. While no security measures can guarantee perfect security, these steps take into account the sensitivity of the Information MSHAWISE collects, processes, and stores, and the current state of technology. Given the nature of communications and information processing technology, MSHAWISE cannot guarantee that Information in our care will be absolutely safe from intrusion by others during transmission through the Internet or while stored on our systems or otherwise. When you click a link to a third-party site, you will be leaving our site and MSHAWISE doesn’t control or endorse what is on third-party sites.

‍7) Age Limitations

To the extent prohibited by applicable law, MSHAWISE does not expect, intend or market the use of its Services and Websites to be accessed by anyone younger than 18 years old. If MSHAWISE learns that anyone younger than 18 has unlawfully provided Personal Data, MSHAWISE will take steps to delete such information.

‍8) Changes to This Privacy Policy

MSHAWISE may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or MSHAWISE may make changes to our services or business. MSHAWISE will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If MSHAWISE makes changes that materially alter your privacy rights, MSHAWISE will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should cease interacting with the Services. Contact the applicable Customer if you wish to request the removal of Personal Data under their control.

‍9) Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Service Data. In general, MSHAWISE is the processor of Service Data and the controller of Other Information.‍

‍10) Your Rights

Individuals located in certain US States such as California and Virginia have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information (in a portable form or otherwise), as well as to seek to update, delete or correct this Information. Where possible and as outlined in this Privacy Policy, you can request to limit your use and disclosure of this Information. You can exercise your privacy rights by sending a request to via email at: privacy@MSHAWISE.com or in writing to:
‍

MSHAWISE

Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204 

‍To the extent that MSHAWISE’s processing of your Personal Data is subject to applicable laws covering the processing of Personal Data, MSHAWISE relies on its legitimate interests, described above, to process your data. MSHAWISE may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to MSHAWISE’s use of your Personal Data for this purpose at any time.‍

‍11) Your California Privacy Rights

This section provides additional details about the personal information MSHAWISE collects about California consumers and the rights afforded to them under the California Consumer Privacy  Act, as amended by the California Privacy Rights Act or “CCPA.”‍

For more details about the personal information MSHAWISE has collected over the last 12 months, including the categories of sources, please see the Information MSHAWISE Collects and Receives section above. MSHAWISE collects this information for the business and commercial purposes described in the How MSHAWISE Uses Information section above. MSHAWISE shares this information with the categories of third parties described in the How MSHAWISE Shares and Disclose Information section above. Subject to certain limitations, the CCPA also provides California consumers the right to request to know more details about the categories or specific pieces of personal information MSHAWISE collects (including how MSHAWISE uses and disclose this information), to delete their personal information, correct their personal information that may be occurring, and to not be discriminated against for exercising these rights. Please also note that MSHAWISE does not collect sensitive personal information as defined under the CCPA.

 

California consumers may make all other requests to access, correct, or delete pursuant to their rights under the CCPA by contacting us at privacy@MSHAWISE.com, or by mailing us at:
‍

MSHAWISE

‍Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204 
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MSHAWISE will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

‍12) Your Virginia Privacy Rights

Subject to certain limitations, the Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers the right to request to access personal information we collect about you, correct inaccuracies in you personal data, to request a portable copy of your personal information, and to delete your personal information. You also have the right opt-out from the processing your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, which MSHAWISE does not do. You also have the right to opt out of targeted advertising and selling (as such terms are defined under the VCDPA), however, MSHAWISE does not participate in selling of your personal information. 

 

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

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MSHAWISE will honor the exercise rights or appeals of decisions of Virginia residents requested via email at privacy@MSHAWISE.com or in writing to:

‍

MSHAWISE

‍Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204 

13) Contacting MSHAWISE

Please also feel free to contact MSHAWISE if you have any questions about this Privacy Policy or MSHAWISE’s practices, or if you are seeking to exercise any of your statutory rights. MSHAWISE will respond within a timeframe that is compliant with all applicable regulations 

You may contact us at privacy@MSHAWISE.com or at our mailing address below:

MSHAWISE

‍Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204