CMPLY, Inc. (variously referred to herein as “CMP.LY”, “us” and “we”) takes your privacy seriously. This privacy policy applies to (i) transactions, activities and data gathered on CMP.LY (the “Site”) and (ii) the technologies and services provided by CMP.LY and accessed on the Site (collectively, the “Services”). It applies not only to persons who purchase or otherwise avail themselves of the Services (“Users”), such as Users who rely on the Services to provide form or customized disclosures (“Disclosures”) to others, but also to anyone else who accesses the Site or any Disclosures (“Visitors”).
Please review this privacy policy periodically as we may revise it without notice. This privacy policy was last revised on February 16, 2012. Each time you use the Site, or access our Services (including Disclosures) or provide us with information, you are accepting the practices described in this privacy policy at that time.
If you only access Disclosures, and do not also access the Site, you are nevertheless bound by this privacy policy, as well as the Site’s terms of service.
Privacy Policy of Users
If you are a User who publishes a website, blog or other Internet or mobile accessible content (the “User Site”), you must ensure that the User Site’s privacy policy is consistent with this privacy policy. CMP.LY is not responsible for any claims asserted against you as a result of your failure to notify persons who access the User Site that their demographic data and, if provided, personally-identifiable information may be shared with CMP.LY and, as a result, is subject to this privacy policy. Subject to our compliance with this privacy policy, you agree to indemnify, defend and hold us harmless from any claims third parties assert against us asserting that their demographic data or personally-identifiable information was made accessible to us from your User Site and was thereafter improperly used or disclosed by us.
Your IP Address
Like most websites, each time you visit the Site or access Disclosures, we automatically collect your IP address and the web page from which you came. In order to administer and optimize the Site for you and to diagnose problems with our Site, we use your IP address to help identify you and to gather broad demographic information about you. We do not combine IP addresses with any personally identifying information.
Cookies
CMP.LY collects anonymous information through cookies. A cookie is a small piece of data containing a unique identification number that is sent to your browser from a Web server, and is stored on your computer’s hard drive. The unique ID number identifies your browser to CMP.LY’s computers whenever you visit. Cookies do not enable anyone to access personally identifiable information that you have not already given us. CMP.LY primarily uses cookies to connect members with account information stored on CMP.LY’s computers. This helps CMP.LY deliver better and more personalized service. CMP.LY may also use cookies to estimate CMP.LY’s audience size for advertisers; to identify the areas of the Site you visit; to hold session information; and to track User and Visitor preferences.
Cookies are part of the technology implemented by your browser. Most browsers are initially set up to accept cookies. You can reset your browser to either notify you when you have received a cookie, or to refuse them all together.
CMP.LY relies on cookies to preserve the CMP.LY identity you have created while logged on. If you set your browser to disable cookies, you may not be able to access certain areas on the Site.
You may occasionally get cookies from our advertisers as well. CMP.LY does not control these cookies and they are not subject to our Privacy Policy. Advertisers do not have access to the Site’s cookies.
Data We Collect From You
In order to operate the Site and to provide you with information about products or services that may be of interest to you, we may collect “personal information” (i.e. information that could be used to contact you directly (without using the Site) such as full name, postal address, phone number or email address) or “demographic information” (i.e. information that you submit, or that we collect, that is not personal information; this may include, but is not limited to, zip code, hometown, gender, username, age/birth date, browsing history information, searching history information, and registration history information. Please note that nowhere on the Site do we knowingly collect, keep or maintain personal information from children under the age of 18, as we require that all Users represent to us that they are at least 18 years old, and do not ordinarily collect personal information from Visitors. If you are the parent or guardian of a minor who you believe has provided us with personal information, you may ask us to remove that information from our archives by contacting us at privacy@cmp.ly.
How We Use Personal Information
We use your email address and your other personal information to help us efficiently operate the Site and to contact you in connection with your transactions and other activities on the Site (including, but not limited to, confirmation emails, or important news that could affect your relationship with the Site). These types of communications are known as “Operational Communications.” In some cases, Operational Communications may also contain commercial messages, such as banner ads and special offers.
To operate the Site, including processing your transactions and supporting your activities on the Site, we may share your personal information with our agents, representatives, contractors and service providers so they can provide us with support services such as email origination, receipt, customer relationship management services, and order fulfillment. We require these entities not to use your personal information for any other purpose.
By purchasing, or registering or making reservations for, products or services that may from time-to-time be offered or sponsored by third parties on the Site, or electing to receive communications (such as emails or material by mail) or electing to participate in contests, sweepstakes or other programs (such as discount or rewards programs), offered or sponsored by third parties on the Site, you consent to our providing your personal information to those third parties. Those third parties may use your personal information in accordance with their own privacy policies. You will need to contact those third parties to instruct them directly regarding your preferences for the use of your personal information by them. Additionally, you agree that we may use and disclose all such information so submitted to such third parties in the same manner in which we are entitled to use and disclose any other information you submit to us.
Any third party with whom we are allowed to share your personal information is authorized to use your personal information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control, and you agree that we are not responsible or liable for any of their actions or omissions. Those who contact you will need to be instructed directly by you regarding your preferences for the use of your personal information by them.
How We Use Demographic Data
We may review all demographic data. We may use public information to enable other Users and Visitors to search your profile and to communicate with you. We may use demographic information to tailor the Site and communications to your interests. We may also share demographic information with advertisers on an anonymous and aggregated basis (i.e., without telling the advertisers your identity). One of the reasons we may do this is to increase the likelihood that our advertisers’ goods and services will appeal to you as a User or Visitor. Our sharing of demographic information with advertisers is anonymous (i.e., we do not tell advertisers which particular Users or Visitors are members of which demographic groups), subject to the rest of this privacy policy. When you respond to an advertisement, however, we ask you to remember that if that ad is targeted to a demographic group and you decide to give the advertiser your personal information, then the advertiser may be able to identify you as being a member of that demographic group.
How to Edit Your Information
CMP.LY believes strongly in giving you the ability to access and edit your personal information. So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. For example, since children under 18 are not allowed to register as CMP.LY members, we need to take reasonable measures to preserve the accuracy of our members’ ages. Please contact us at support@cmp.ly to find out how to change information you cannot access through your Profile. You may notify us of any changes in your personal information, or request that such information no longer be used by us or our Users or Visitors by sending an e-mail to remove@cmp.ly; however, you acknowledge that we maintain data archives from which information you have provided to us in the past cannot be removed without extraordinary measures, and we do not have any obligation to remove such information so long as we cease using it or making it available to others upon your request. Please be aware, however, that if you ask us to cease using your personally identifiable information, you may no longer be able to receive certain updated information from us, or participate in various functions of the Service. We may share your personal information with our employees or agents to the extent necessary for them to carry out their job duties.
Information Retention
To preserve the integrity of our databases, standard procedure calls for us to retain information submitted by members for an indefinite length of time. CMP.LY understands your submissions as consent to store all your information in one place for this indefinite length of time, if we so wish. If required by law, as is the case to comply with the Children’s Online Privacy Protection Act (COPPA), we will nullify member information by erasing it from our database. We will also respond to written member requests to nullify account information. If you wish to make such a request, which requires that we verify your identity, or if you have any questions regarding this policy, contact CMP.LY at privacy@cmp.ly. Also, by using this Site, you do hereby represent and warrant that you understand and agree that all information submitted by you to CMP.LY becomes the property of CMP.LY and may be used in the sole discretion of CMP.LY in accordance with this Privacy Policy and the Terms of Service.
Choice/Opt-Out
Our Site provides Users and Visitors the opportunity to affirmatively opt-out of receiving communications from us and our partners at the point where we request information about the User or Visitor. This Site gives Users and Visitors the option to end our use of their information, and to cease receiving or otherwise having access to future communications or Services.
Your California Privacy Rights
A California privacy law that went into effect on January 1, 2005, the “Shine the Light” law, allows California residents to obtain a list of third parties to whom a business has disclosed personal information if it shares such information with third parties for their direct marketing purposes. However, if a business adopts and discloses in its privacy policy a policy of not disclosing customers’ personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and by providing a cost-free means to exercise that right.
As stated earlier in this Privacy Policy, personal information submitted at the time of registration or submission may be used for marketing and promotional purposes only with the particular User or Visitor’s permission. Whenever a User or Visitor agrees to allow us to collect personal information, we provide that person with an option to prevent such information from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time by clicking on the link below:
Click here to opt-out
Because the Service has a comprehensive privacy policy and provides you with details on how you may opt-in or opt-out of the use of your personal information by third parties for direct marketing purposes, we are not required to provide you with the third party list.
Special Cases in which we Share Personal Information
Your personal information may be passed on to a third party in the event of a transfer of ownership or assets, or a bankruptcy. We may also disclose personal information when we determine that such disclosure is necessary to comply with applicable law, to cooperate with law enforcement or to protect the interests or safety of the Site or other Users or Visitors. We also may disclose your personal information to our subsidiary and parent companies and businesses, and other affiliated legal entities and businesses with whom we are under common corporate control. Whenever personal information is disclosed under this paragraph, we may also disclose your demographic information along with it, on a non-anonymous basis. All of our parent, subsidiary and affiliated legal entities and businesses that receive your personal information or non-anonymous demographic information from us (except in the case of bankruptcy), will comply with the terms of this privacy policy with respect to their use and disclosure of such information.
Our Security Precautions
Your CMP.LY Profile is password-protected so that only you and authorized CMP.LY employees have access to your account information. In order to maintain this protection, do not give your password to anyone. If someone who represents to you they are CMP.LY staff asks for any personal account information, including password, check their URL. If it doesn’t say they are support@cmp.ly, they’re not. Also, if you share a computer, you should sign out of your CMP.LY account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties.
CMP.LY makes every effort to ensure that your information is secure on its system. CMP.LY has staff dedicated to maintaining this Privacy Policy and other privacy initiatives, periodically reviewing Web security and making sure that every CMP.LY employee is aware of our security practices. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, CMP.LY cannot guarantee the security of any information you transmit to us, and you do so at your own risk. If you have any further questions on this issue, refer to the Site’s Terms of Use. CMP.LY expressly disclaims any liability that may arise should any other individuals obtain the information you submit to this Site.
The Site has security measures in place to protect against the loss, misuse and alteration of the information under our control. Your information may be transferred to and maintained on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which you reside, and the country or jurisdiction in which these computer networks are located may not have privacy laws as protective as the laws in your country or jurisdiction.
CMP.LY may contain links to other websites. We are of course not responsible for the privacy practices of other websites. We encourage our Users and Visitors to be aware when they leave our Site to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by CMP.LY.
Changes to This Privacy Policy
We reserve the right to modify the terms of this Privacy Policy at any time and your continued use of the Service will constitute your acceptance of those changes. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.
Contact Information
Questions or comments regarding this Privacy Policy should be sent by e-mail to privacy@cmp.ly or by U.S. mail to CMPLY, Inc., 419 Park Avenue South, 2nd Floor, New York, NY, 10016, United States of America.
