Thank you for trusting AuditComply (we, us or AuditComply) to be responsible for your personal data, which we want you to know that we take seriously. We respect your privacy and are committed to protecting your personal data.
It applies to all processing of personal data undertaken by AuditComply (other than processing of personal information in the context of recruitment and employment, which is dealt with under separate internal policies) including when you interact with us as one of our customers or suppliers (or as an employee or representative of same), visit our premises, or visit or use our websites (regardless of where you visit them from) (our websites), or our browser based automated audit and inspection compliance software application, AuditComply®, which provides Authorised Users access to the AuditComply® portal and templates (Cloud Software), and mobile based audit compliance software application, AuditComply®, which provides Authorised Users access only (the App) (each or both, as applicable, of the Cloud Software and the App together the Software), and the services available through them the Services.
It also informs you how we will look after your personal data, about your privacy rights and how the law protects you. It does not cover any third party website you have used to access our websites or Services or any third party websites that you access from them.
It is important that you read this policy so that you are fully aware of how and why we are using your data. This policy also includes our cookies and similar technologies policy, at Schedule 1 below, and a specific and more detailed privacy notice for California residents whose personal data we may process, at Schedule 2 below. This schedule is not relevant to you if you reside elsewhere.
Before using the Services through a company licence, as an individual, you will be required to accept this policy and agree to the terms of our separate end-user licence agreement (EULA), a copy of which will be provided to you before you access the AuditComply® portal for the first time and a copy can be obtained by contacting us directly.
1. WHO WE ARE
1.1 Contact Details
Our full details are:
Full name of legal entity: AuditComply Ltd, a company incorporated in Northern Ireland under registered company number NI623693
Email address: firstname.lastname@example.org
Postal address: Suite 8, Alexander House, 17 Ormeau Avenue, Belfast, Northern Ireland, BT2 8HD
ICO Registration Number: ZA450833 (this is the number under which we are registered with the UK Information Commissioner’s Office as a fee paying data controller).
1.2 Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, we act as both a data controller (i.e. where we make decisions) in relation to your personal data that we collect, as well as a data processor (i.e. process data broadly in accordance with your instructions.
When we act as a Processor: When as a customer or user you use our Services to process personal data, we act as a data processor. Under these circumstances, the customer (i.e. the organisation which has purchased a licence which permits you with access to the Services) or user may act as a data controller or data processor itself, and we will act as either a processor or a sub-processor.
When we act as a Controller: By contrast, when we collect personal data and determine the purposes and means of processing that personal data – for example, when we store account information for account registration, administration, services access, or contact information as explained below – we act as a controller.
1.3 Third-Party Links
Our websites and Services may include links to third-party websites, widgets, plug-ins and applications (including various social media platforms). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
2. WHAT KIND OF PERSONAL DATA DO AUDITCOMPLY PROCESS?
INFORMATION YOU SUPPLY TO US
2.1 General Personal Data: This is personal information about you that you share with us by online forms on our website, through email, through the post, on the telephone, when you register to use the Services, when you complete customer surveys, engage with our customer services team, or by any other means.
Typically, when you contact us you may provide information about yourself, including your full name, job title, billing address, business name, personal and/or business email address, telephone and/or mobile phone number and other contact details.
When you sign up to use our Services, or when using the Services, you will be required to provide your name and email address, online identifiers, username and password, company details, job title, department name, team, gender, qualification level and manager details alongside other non-personal details.
You may also provide personal data you provide when you report any technical or service issues in relation to our websites or Services, including relevant notes about any issues and how we responded to resolve these, as well as details of any payments you have made through our websites.
2.2 Customer Data: When you use our Services, you may upload personal data relating to third party individuals (other than account data). Any personal data you provide when using our Services, other than account data, is known as Customer Data in this policy.
2.3 Financial Details: Where you pay for the Services (either on your own or on your organisation’s behalf), or provide us with your or your company’s financial details in order to facilitate payments by us to you, we may collect financial details.
Financial details of our customers include credit card numbers, sort codes and account numbers and billing information, which we collect and process using third party PCI-compliant service providers (currently Stripe Inc, GoCardless and Revolut). Such service providers are not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Where you have separately provided us with your bank account details in order to facilitate payments by us to you these will be kept securely.
2.4 Verbal Information: If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.
2.5 Marketing Information: You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).
2.6 Third Party Data: Where you are sharing personal data that does not directly relate to you (e.g. your representatives that legally act on your behalf), you must ensure you have the consent to do so and have shared this policy with that person/those people, including where you are acting to register other individuals on their behalf.
IF YOU FAIL TO PROVIDE PERSONAL DATA
2.7 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products). In this case, we may not be able to fulfil any order you place with us, but we will notify you if this is the case at the time.
PERSONAL DATA WE COLLECT
2.8 CCTV Footage: We may use CCTV cameras on our premises and may record footage of you where you attend our premises in person, and use such footage as required in our legitimate interests, including to ensure the safety and well-being of our staff.
2.9 Technical Data from our Websites: We use certain technical services to gather technical data online whenever you use our websites (as a visitor) including information about your device and your visits to our websites such as your IP address, geographical location, browser type, referral source, internet service provider (ISP), clickstream data, browser type and language, timezone, length of visit and pages viewed, date or time stamps weblogs and other communication data. Please see our cookies and similar technologies policy in Schedule 1 below for further details.
You are not personally identifiable from any of the technical data we collect using such services.
2.10 Technical Data from our Services: We also use certain technical services to gather certain technical and all usage data whenever you use our Services, including device, content and usage data, as well as the data mentioned in Section 2.10 above. We may also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time. We collect this data using cookies and other similar technologies. Please see our third party vendor policy in Schedule 2 below for further details.
You will be personally identifiable from any of the data we collect using our Services, as it will be tied to your specific user account.
PERSONAL DATA WE RECEIVE FROM THIRD-PARTIES
2.11 Device Data: analytics providers such as Apple and Google based outside the EU; advertising networks such as Google based outside the EU; and search information providers such as Google based outside the EU.
2.12 Contact, Financial and Transaction Data: from providers of technical, payment and delivery services such as Stripe based outside the EU, GoCardless based outside the EU and Revolut based outside the EU.
2.13 Social Media: publicly available information through social media sites, such as Facebook, LinkedIn, Twitter, Instagram and Google, including where you have responded to a promotional item or offer from us through social media facilities.
2.14 Publicly Available Information: we may collect personal information about you from other publicly available sources. This can include your name, address and other publicly available information. As far as passible, we ensure that where any third-parties are involved in suppling such information, that they are compliant to do so. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register.
2.15 Customer Data: Through our Services, our other customers or users may collect, store and process personal data about you – such data is also known as Customer Data under this policy.
We require all of our customers to agree to adhere to these terms at all times, but do not actively monitor content uploaded or processed using our Services and are not responsible for enforcing those terms.
If you are reviewing this policy because you believe your or your organisation’s data has been used in violation of those terms, please contact us.
KEEPING YOUR PERSONAL DATA UP TO DATE
2.16 It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. WHAT INFORMATION IS NOT COLLECTED?
3.1 We do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers).
3.2 Nor do we collect any information about criminal convictions and offences. As noted above, our Terms of Service include restrictions on any of our customers using our Services to collect such data (or financial information) but as noted we do not proactively monitor this, and cannot be held responsible where our customers breach these restrictions.
3.3 If you’re a child under the age of 16 (or are otherwise younger than the legal age limit required in the country in which you reside), you may not have an account on AuditComply. AuditComply does not knowingly collect information from or direct any of our content specifically to children under relevant ages. If we learn or have reason to suspect that you are a user who meets these criteria, we will unfortunately have to close your account. Please see our Terms of Service for information about account termination.
If you are a child aged between 16 and 18 using our Services or websites from the UK or European Union, you must have informed your parents or guardians of this, of the terms of this policy, and have their consent to do so.
4. HOW IS INFORMATION USED?
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.1.3 Where we need to comply with a legal or regulatory obligation.
4.2 Generally, we do not rely on consent as a legal basis for processing your personal data other as set out below in relation to marketing and testimonials. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
4.3 Our Standard Business Operations:
4.3.1 To provide the services that we contract to provide to you, or to the relevant customer to whom we sell access to the Services and who has authorized you to access same on their behalf;
4.3.2 To provide you with information that you request from us;
4.3.3 To confirm your identity as a natural living person; and
4.3.4 As part of our billing, payments and recovery processes.
We may also use contact information to notify you of any issues which might impact the provision of our Services to you.
We maintain multiple contact lists (with email addresses and other information) to allow us to communicate with individuals who do business with us or who have expressed an interest in the Services.
We may contact you to confirm your purchases or respond to requests that you make, notify you of changes to your account or the Services, for marketing purposes, to inform you of any updates or news in relation to us or our products, or to otherwise inform you of information related to our business or your account with us.
We strive to provide you with choices regarding personal data uses for marketing and advertising and currently use to manage our email correspondence. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions.
We will never sell your personal data to any third party (as noted below).
We may post customer testimonials and comments on our websites or other platforms, which may contain personal data. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
4.6 Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4.7 Legal Requirements
We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.
4.8 Customer Data
Whilst we do have access to personal data stored in your data packages stored on AuditComply, i.e. what we call Customer Data in these terms, we do not process such data otherwise than in accordance with your instructions, or with your consent as set out herein. It belongs to you, and you are responsible for it, as well as for making sure that your content complies with our Terms of Service.
We do not access any information (including personal data contained in same) you have stored using your account unless required to for security or maintenance, or for support reasons, or with the consent of the account owner, or process it other than to store the data securely as described herein, and then delete it as applicable, or as strictly required by law.
4.9 Enhancing our Services
We may use personal data (other than that comprised in private Customer Data) for the purposes of providing, enhancing, or improving our IP geolocation, fraud detection, demographic targeting, and other Services and products.
4.10 Website Administration and Customisation
We may use the information we collect about you for a variety of website administration and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our websites, deliver our websites content to you, measure Website traffic, measure user interests and traffic patterns, and improve our websites and the services and features offered via our websites.
4.11 Aggregated or Non-Identifying Information
Non-identifying information includes information collected from or about you that does not personally identify you – including aggregated information. AuditComply treats IP addresses, log file information, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise. AuditComply may use non-identifying information for any purpose.
We may also combine your non-identifying information with third party data sources (including data obtained from offline sources and data obtained from our customers using the Services) in our effort to improve our Services. We may share such non-identifying information with customers, affiliates, and other third parties for any purpose.
Certain jurisdictions, including the European Union, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Information as described in this policy should be assumed to include IP address and Unique ID data.
5. WHAT INFORMATION IS SHARED?
5.1 We do not disclose personal data outside AuditComply, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in in above or otherwise below:
5.1.1 any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006;
5.1.2 with your employer, a person or entity authorised by your employer or the other person or entity by whom you have been authorised to use the Services, who can access all information you input, store or process using the Services;
5.1.3 with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances (excluding private Customer Data – unless we are subject to a Compelled Disclosure);
5.1.4 with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our website or by email before any transfer of your personal data. Any purchaser would be bound by the terms of this policy and our Terms of Service;
5.1.5 with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above (excluding Customer Data);
5.1.6 with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.) (excluding Customer Data unless for the limited purposes described above);
5.1.7 with specific selected third parties, determined by us, if you breach any agreement with us including any relevant EULA, or the person authorising you to use our Services breaches the corporate licence between them and us, and any other relevant agreements, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable) (excluding private Customer Data); and
5.1.8 with service providers acting as processors based in the European Union or United Kingdom or US who provide IT and system administration services, including for the performance of our contract with you, as set out below:
When we transfer your data to our service providers, we remain responsible for it.
5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar to our own policy.
5.3 We do not share, sell, rent, or trade personal data with third parties for their commercial purposes.
5.4 We may also share personal data with your permission, so we can perform services you have requested.
6. IS SHARED INFORMATION TREATED DIFFERENTLY?
6.1 Our Services may allow you to share the Customer Data you process using our Services with other users who may access that content and use it in compliance with our Terms of Service, where, for example, you access the Servers via a multi-user account.
6.2 Any personal data associated with Customer Data may be gathered by third parties with whom you have chosen to share your account. If you do not want your Personal Information to be utilised by third parties, please do not make your Customer Data available to them.
6.3 Whilst AuditComply accepts no responsibility for how other users may use information stored on your account you choose to share with them, we do require our users to agree that if they would like to use other users’ data, they may only use it for the purposes authorised by the relevant account holder. For example, where an AuditComply user has made an email address available for the purpose of identification and attribution, do not use that email address for advertising. We expect you to reasonably secure any Customer Data you have gathered from other users, and to respond promptly to complaints, removal requests, and “do not contact” requests from AuditComply or AuditComply users.
7. HOW IS MY INFORMATION SECURED?
7.1 AuditComply takes all measures reasonably necessary to protect personal data from unauthorised access, alteration, or destruction, maintain data accuracy and help ensure the appropriate use of personal data. We follow generally accepted industry standards to protect the personal data we hold, both during transmission and once we receive it.
7.2 In addition, we limit access to any Customer Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to duties of confidentiality. Our third party hosting provider will not have direct access to Customer Data. Direct access to Customer Data shall be locked down to an internal internet protocol accessible only from within the network of our third party hosting provider.
7.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7.4 No method of transmission, or method of electronic storage, is 100% secure. Although we will do our best to protect your personal data, we cannot guarantee its absolute security. Any transmission is at your own risk.
8. HOW IS INFORMATION COLLECTED AND STORED GLOBALLY?
8.1 Information that we collect will be stored and processed in [the United Kingdom, the European Union and US in accordance with this policy. However, we understand that we have users from different countries and regions with different privacy expectations and local legal requirements, and we try to meet those needs and requirements.
8.2 We provide the same standard of privacy protection to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business. Additionally, we require that if our vendors or affiliates have access to personal data, they must comply with applicable data privacy laws, including signing data transfer agreements such as EU standard contractual clause agreements, where required by law.
8.3 In particular:
8.3.1 we provide clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data and if applicable. Where consent is not the applicable ground for processing, we will ensure that it has an appropriate ground for processing any personal data (including but not limited to contractual obligation or legitimate interest);
8.3.2 we collect only the minimum amount of personal data necessary, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing;
8.3.3 we offer you simple methods of accessing, correcting, or deleting the data we have collected; and
8.3.4 we provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.
9. WHAT HAPPENS IF I HAVE A COMPLAINT?
9.1 If you have concerns about the way AuditComply is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at email@example.com with the subject line “Data Privacy”. We will respond within 30 days at the latest, unless required to respond earlier under relevant law.
9.2 If you are a data subject based in the UK or European Union, you may have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), or other competent supervisory authority of an EU member state if the Services are accessed outside the UK. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you please contact us in the first instance.
10. HOW DO YOU RESPOND TO COMPELLED DISCLOSURE REQUIREMENTS?
10.1 AuditComply may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.
10.2 In complying with court orders and similar legal processes, AuditComply strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
11. HOW CAN I ACCESS MY OWN PERSONAL INFORMATION?
If you’re already a user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting us.
Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. DATA RETENTION AND DELETION
Personal Data Generally
12.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
12.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Personal data which AuditComply considers to be of less relevance to the performance of a contract, such as miscellaneous correspondence or telephone records, may be deleted earlier.
12.3 We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.
12.4 By law we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the six year limitation period thereafter in case you raise any claims in relation to any products or services you or your employer or other person by whom you have been authorised to use our Services have purchased from us. This section does not apply to Customer Data.
12.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12.6 If you would like to cancel your account and initiate deletion of your personal data, you may do so in your user profile. As above, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, maintain security, and enforce our agreements, but barring legal requirements, the timeframe above will be observed for deletion.
12.7 We will endeavour to delete any Customer Data in our next quarterly data deletion cycle, after your account being terminated, or you deleting such Customer Data using your account. This is to synchronise deletion of such Customer Data with our quarterly data deletion cycles, and to facilitate the potential provision of a service to you (as our customer) that may permit the restoration of your account, or of accidentally deleted Customer Data, upon request and for payment of a fee. You should not that this is not guaranteed, and that Customer Data may be, irrevocably, deleted more quickly.
13. HOW DO YOU COMMUNICATE WITH USERS?
13.1 We will use your email address to communicate with you, if you’ve given us the OK, and only for the reasons you’ve permitted. Emails by default are not disclosed with other users, even if you belong to the same organization. This will not change how we contact you, as we always utilise your primary email address.
13.2 Depending on your email settings, AuditComply may occasionally send notification emails about new features, requests for feedback, important policy changes, or offer customer support. We also send marketing emails, including ones featuring new services and products offered by our commercial partners, but only with your consent. There’s an unsubscribe link located at the bottom of each of the emails we send you.
13.3 Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails.
Unless legally necessary (in which case you will be notified by email), any changes we may make to this privacy notice in the future will be posted on this page without further recourse or notice to you. If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information.
We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments.
Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page and, where appropriate, may be notified to you when you next log on to use the Services. Otherwise, any changes shall be applicable without further notice.
This version two of this policy was last updated in July 2022 and historic versions can be obtained by contacting us.
15. HOW CAN I CONTACT AUDITCOMPLY?
This policy shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy.
SCHEDULE 1 – COOKIES AND OTHER TECHNOLOGIES POLICY
1. WHAT SPECIFIC TECHNICAL DATA DO AUDITCOMPLY COLLECT?
1.1 AuditComply collects and analyses traffic by keeping track of the IP addresses of our visitors and by collecting log file information. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet service provider (ISP) or by another organisation. An IP address, by itself, cannot identify you personally (unless you are logged in whilst using our sites). However, when combined with other information, your IP address can be used to identify the computer you are using. In addition, AuditComply may use your IP address to estimate your geographic location.
1.3 AuditComply may also use web beacons, small graphic images or other web programming code (also known as “1×1 GIFs” or “clear GIFs”), which may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our websites, to monitor how users navigate our websites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
1.4 AuditComply may also use embedded scripts on our websites and in connection with the provision of its Services. “Embedded scripts” are programming code designed to collect information about your interactions with a website, such as the links you click on, and may assist our customers in providing us with information used to provide the Services. The code is temporarily downloaded onto your device from our web server, our customer’s web server, or a third party service provider, is active only while you are connected to our websites containing the embedded script, and is deactivated or deleted thereafter.
1.5 Your web browser automatically sends information to every website you visit, including ours. For example, our server logs may receive and record information such as the pages you access on our websites, referring URLs, your browser type, your operating system, the date and time of your visit, and the duration of your visit to each page.
1.6 Log file information may also include a user agent string, a series of characters automatically sent with your Internet requests that provide information necessary for smooth Internet communications such as the operating system and browser you used. Similar to an IP address, a user agent string, by itself, does not identify you personally. However, when combined with other information, a user agent string might be used to identify the computer originating a message.
1.7 AuditComply may also request access to or otherwise receive information about your device location when you access our websites. Your location data may be based on your IP address. We use location data in connection with providing the Services and to help improve the Services.
1.8 AuditComply may assign your computer or mobile device a unique identification number (Unique ID) based on log file information when you access our websites AuditComply may set a cookie on your device containing, amongst other things, the device’s Unique ID. AuditComply uses information generated from the Unique ID for purposes of improving our Services, primarily our ability to detect fraud. AuditComply does not share the Unique ID or any associated data with unaffiliated third parties.
2. WHAT COOKIES / TRACKING CODE ARE USED BY AUDITCOMPLY?
2.1.2 A cookie is a small piece of text that our web server stores on your computer or mobile device, which your browser sends to us when you return to our site. Cookies do not necessarily identify you if you are merely visiting AuditComply; however, a cookie may store a unique identifier for each logged in user. The cookies AuditComply sets are essential for the operation of our websites, or are used for performance or functionality, and are set out in more detail below. By using our website, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept cookies, you will not be able to log in or use AuditComply’s services.
2.2 Google Analytics
2.2.1 We use Google Analytics as a third party tracking service, but we don’t use it to track you individually or collect your personal data. We use Google Analytics to collect information about how our website performs and how our users, in general, navigate through and use AuditComply. This helps us evaluate our users’ use of AuditComply; compile statistical reports on activity; and improve our content and website performance.
2.2.2 Google Analytics gathers certain simple, non-personally identifying information over time, such as your IP address, browser type, internet service provider, referring and exit pages, time stamp, and similar data about your use of AuditComply. We do not link this information to any of your personal information such as your user name.
2.2.3 AuditComply will not, nor will we allow any third party to, use the Google Analytics tool to track our users individually; collect any personal data other than IP address; or correlate your IP address with your identity. Google provides further information about its own privacy practices and offers a browser add-on to opt out of Google Analytics tracking.
2.2.4 Certain pages on our site may set other third party cookies. For example, we may embed content, such as videos, from another site that sets a cookie. While we try to minimise these third party cookies, we can’t always control what cookies this third party content sets.
2.3.1 “Do Not Track” is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of information about your online activity from third party tracking services. We do not track your online browsing activity on other online services over time and we do not permit third-party services to track your activity on our site beyond our basic Google Analytics tracking, which you may opt out of. Because we do not share this kind of data with third party services or permit this kind of third party data collection on AuditComply for any of our users, and we do not track our users on third-party websites ourselves, we do not need to respond differently to an individual browser’s Do Not Track setting.
2.3.2 If you are interested in turning on your browser’s privacy and Do Not Track settings, the Do Not Track website has browser-specific instructions.
2.3.3 Please see our section on email communication to learn about our use of pixel tags in marketing emails.
SCHEDULE 2 – CPPA PRIVACY NOTICE
CATEGORIES OF PII COLLECTED
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of PII categories that we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This definition does not mean that all instances of that category of PII were collected by us but reflects our good-faith belief to the best of our knowledge that some of that information from the relevant category may be and may have been collected. For example, specific PII types would only be collected if you provided such PII directly to us.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name, driver’s license number, passport number, or other similar identifiers.
Collected: Yes – real name, e-mail address, account name and alias.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some PII included in this category may overlap with different categories.
Collected: Yes – telephone number and signature.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Category E: Biometric information.
Examples: Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or different physical patterns, and sleep, health, or exercise data.
Category F: Internet or other similar network activity.
Examples: Interaction with our services or advertisement.
Category G: Geolocation data.
Examples: Approximate physical location.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 USC Section 1232g, 34 CFR Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalfs, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
Under CCPA, personal information does not include:
SOURCES OF PERSONAL INFORMATION
We obtain the categories of personal information listed above from the following types of sources:
USE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES OR COMMERCIAL PURPOSES
We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), as further set out in the “How Is Your Information Used” in the main section of our Policy above.
If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Policy.
DISCLOSURE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES OR COMMERCIAL PURPOSES
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Please note that the categories listed above are those defined in the CCPA; this does not mean that all examples of that category of PII were disclosed but reflects our good-faith belief to the best of our knowledge that some of that information from the relevant category may be and may have been disclosed.
When we disclose PII for a business purpose or a commercial purpose (other than to a regulatory or government body, or to other users with whom any user’s account is affiliated), we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
SALE OF PERSONAL INFORMATION
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. We do not sell personally-identifying information.
SHARING OF PERSONAL INFORMATION
We may share your PII identified in the above categories with the categories of third parties identified in the “What Information is Shared?” section above.
YOUR RIGHTS UNDER THE CCPA
The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
EXERCISING YOUR CCPA DATA PROTECTION RIGHTS
To exercise any of your rights under the CCPA, and if you are a California resident, you can contact us using the contact methods specified above.
Only you, or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable request related to your personal information.
Your request to us must:
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is complicated or there are several of them. In this case, we will notify you and keep you updated.
Any disclosures we provide will only cover the 12 months preceding the verifiable request’s receipt. For data portability requests, we will select a format to provide your personal information that is readily usable and allow you to transmit the information from one entity to another without hindrance.
DO NOT SELL MY PERSONAL INFORMATION
For example, our services providers (for example, our analytics or advertising partners) may use technology on our services that sell personal information as defined by the CCPA. Suppose you wish to opt-out of the use of your data for interest-based advertising purposes and these potential sales as defined under the CCPA. In that case, you may do so by following the instructions below.
Please note that any opt-out is specific to the browser you use. You may need to opt-out of every browser that you use.
Your mobile device may give you the ability to opt-out of the use of information about the apps you use to serve you ads that are targeted to your interests:
Our services do not respond to Do Not Track signals. However, some third party websites do keep track of your browsing activities. If you visit such websites, you can set your web browser preferences to inform websites to disabling such tracking. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
YOUR CALIFORNIA PRIVACY RIGHTS (CALIFORNIA’S SHINE THE LIGHT LAW)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Data with third parties for the third parties direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
CALIFORNIA PRIVACY RIGHTS FOR MINOR USERS (CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 22581)
California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain the removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the e-mail address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.