Privacy Policy
Last revised on May 20, 2020
This Privacy Policy applies to the websites: compulsivo.co, www.prefinery.com and productionrails.com (the "Sites") owned and operated by Compulsivo, Inc. (referred to in this Privacy Policy as "Compulsivo" "we" or "us" or "our").
Your privacy is extremely important to us and we are committed to fair practices that protect your information. This Privacy Policy is provided to explain our information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make our policies and procedures available on every page of our Sites.
By using our Sites or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our Sites, or use our services. Continued use of our Sites, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.
Scope of this Privacy Policy
Please be aware that this Privacy Policy does not govern all the information Compulsivo may process. Our commitment to customers and service providers is governed by a separate Data Processing Amendment.
Our commitments to employees are governed by our internal employment policies.
In all instances we are committed to transparency with our customers and protecting your data privacy.
An Overview of the Sources of Personal Data
Compulsivo obtains information about individuals in these main ways:
- when you visit our Sites or contact us directly about becoming a customer or obtaining other information,
- when you become a customer of our Sites (e.g. of Prefinery),
- when you sign up for the newsletter of one of our Sites (e.g. of ProductionRails),
- when end users use goods and services provided by Customers of our Sites (e.g. partipate in a Prefinery Customer's product launch),
- when a customer uses our service to combine its data with the data residing in other applications (e.g. MailChimp),
- when you are a service provider to Compulsivo, and
- through the Compulsivo employment process.
This Privacy Policy governs how we collect and process information obtained from your visits to our Sites, when you contact us directly (or interact with us via other media outlets and social media) about becoming a customer or to obtain other information, and when you engage with us as part of the employment process.
Our Data Processing Amendment governs our processing of any information obtained as a result of the customer or service provider relationship. You can read our commitment to customers and service providers, and our fair information practices in the Data Processing Amendment.
Some definitions
"You" or "your" refers to the individual who uses this website, features, and services, or accesses available information, or engages with us directly by email or telephone.
As used in this Privacy Policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization.
Whose information does Compulsivo collect?
Compulsivo collects information from three types of individuals:
Our customers are individuals and businesses who have signed up for an account with one of our Sites. If you are a customer, we will handle information we receive from you under the terms of Compulsivo's Data Processing Amendment.
End users are individuals that use goods and services provided by Customers of our Sites. We process "End User Data" which means information about end users of Compulsivo customers, which includes but is not limited to, the first name, last name and email address of an end user.
Personnel are the people who work, and apply to work, for Compulsivo. Please refer to the Personnel section of this policy to read about the information Compulsivo collects from personnel.
What information does Compulsivo collect?
Depending on your use of our Sites, or direct interactions with us, we collect two types of information: personal information and non-personal information.
Personal Information
Personal information identifies you or may be used in combination with other pieces of personal information to identify you. Examples of personal information include your name, company name, job title, address, e-mail address, telephone number, and billing and credit card information. Personal information can also include information that does not identify you, but could be combined with other information in a way that enables you to be identified. This includes information such as age, gender, profession, zip code, IP address, and current location.
Non-Personal Information
Non-personal information is information that cannot be used or combined with other information to identify or contact you, including browser types, domain names, and statistical data involving the use of our Sites.
When does Compulsivo use end user information from third parties?
Compulsivo will collect End User Data necessary to provide our Sites' services to our customers.
End users may voluntarily provide us with information they have made available on social media websites. If you provide us with any such information, we may collect publicly available information from the social media websites you have indicated. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
When does Compulsivo use customer information from third parties?
We receive some information from third parties when you contact us. For example, when you submit your email address to us to show interest in becoming a Compulsivo customer, we receive information from a third party that provides automated fraud detection services to Compulsivo. We also occasionally collect information that is made publicly available on social media websites. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
Where and when is information collected from customers and end users?
Compulsivo will collect personal information that you submit to us. We may also receive personal information about you from third parties as described above.
Registering to Use our Sites and in the Course of Using Compulsivo services.
Customers will be required to establish an account in order to take advantage of certain features of our Sites. If you wish to establish an account you will be required to provide us with information (including personal information and non-personal information). In addition, we may obtain your personal information from you if you identify yourself to us by sending us an e-mail with questions or comments.
Cookies and Web Beacons
We also use "Web Beacons." For more information about these and a full list of the cookies we use, what they do, and how to disable the non-necessary ones, please refer to the Prefinery Cookie Policy. We do not use cookies or web beacons on the compulsivo.co or productionrails.com domains.
Personnel
If you are a Compulsivo worker or applicant, we collect information you voluntarily provide to us. We use the information collected for Human Resources purposes in order to administer benefits to workers and screen applicants.
You may contact us in order to (1) update or correct your information, (2) change your preferences with respect to communications and other information you receive from us, or (3) receive a record of the information we have relating to you. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.
Does Compulsivo collect information from children under 16 years of age?
We are committed to protecting the privacy of children. Our Sites are not designed for or directed to children under the age of 16. We do not collect personal information from any person we actually know is under the age of 16.
What does Compulsivo do with the information it collects from customers?
In general, we use the information collected to provide you with a great overall experience interacting with us and when using our Sites and to help us understand who uses our offerings, for internal operations such as operating and improving our Sites and our services, to contact you for customer service and billing purposes and to facilitate the delivery of Compulsivo advertising in some cases, including using your email to send information to you about our services.
We use your information to send you a welcome e-mail after you create an account, when you are invited to our Sites, or when you sign up for a demo, webinar or to receive our newsletter. We also use your information to send other e-mail communication related to our Sites. We always give you the option to unsubscribe in any email we send you.
If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personal information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. We also use the information collected to send announcements and updates regarding changes to our Terms of Service, Privacy Policy or when making pricing changes. You will not be able to unsubscribe from these announcements and updates as they contain important information relevant to your use of our Sites and our services.
We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve our Sites and services. We may link some of this information to personal information for internal purposes or to improve your experience with our Sites and our services, in these cases we will obtain your consent.
What does Compulsivo do with the information it collects from end users?
We use End User Data to identify you and to provide you with customer service on behalf of a Compulsivo customer. We will disclose End User Data to the relevant Compulsivo customer so that they are better able to assist you. If you are interested in how we process the data on behalf of Compulsivo customers, please read our Data Processing Amendment.
Third Parties Generally
Third parties may be able to independently directly collect personal and non-personal information without permission from Compulsivo, and may include potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers and other similar parties. To opt out, see Do Not Track.
Outside Contractors and Third-Party Processors
We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to our Sites and our services, such as hosting, credit card processing and fraud screening, and mailing list hosting. In the course of providing products or services to us, these Outside Contractors may have access to information collected through our Sites or our services, including your personal information. We require that these Outside Contractors agree to (1) protect the privacy of your personal information consistent with this Privacy Policy, or the Data Protection Amendment and (2) not use or disclose your personal information for any purpose other than providing us with the products or services for which we contracted or as required by law.
Laws and Legal Rights
We may disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personal information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Sites' Terms of Service, to detect fraud, or to protect the safety and/or security of our users, our Sites, or the general public. Compulsivo is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-U.S. or Swiss-U.S. Privacy Shield, Compulsivo is potentially liable.
Sale of Business
We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Compulsivo or any of its Corporate Affiliates (as defined herein), or that portion of Compulsivo or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.
Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Compulsivo, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.
Does this Privacy Policy apply when I link to other websites or services?
Our Sites or our services may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than those provided by Compulsivo. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us.
When does Compulsivo disclose information to other third parties?
Except as set forth in this Privacy Policy, the Compulsivo Data Processing Amendment or the Prefinery Cookie Policy or as specifically authorized by a Compulsivo customer, we will not disclose any information to third parties.
Could my information be transferred to other countries?
Compulsivo is incorporated in the U.S. Information collected via our Sites, through direct interactions with you, or from use of our services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.
Is the information collected through our Sites and Services secure?
We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.
For more information about how Compulsivo stores and secures customer and company data, please see the Prefinery Security Policy.
Is Compulsivo Privacy Shield compliant?
EU-U.S. and Swiss-U.S. Privacy Shield Framework
Compulsivo complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union and Switzerland to the United States, respectively. Compulsivo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Compulsivo commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Compulsivo.
Compulsivo has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.
Compulsivo also commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
What rights are are offered to California residents?
The California Consumer Privacy Act ("CCPA") provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to our Customers, Compulsivo acts as a "service provider" under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Customers in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Compulsivo Customer with whom you have a direct relationship.
What choices do I have regarding the collection, disclosure and distribution of personal information?
Except as otherwise described in this Privacy Policy or in the Data Processing Amendment, as applicable, we will only use personal information for the purposes described above or as otherwise disclosed at the time we request such information from you. You must "opt in" and give us permission to use your personal information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by clicking the unsubscribe link included on the bottom of all such communications, or by contacting us via email.
Do Not Track
The term "Do Not Track" ("DNT") refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. Compulsivo observes your right not to be tracked and respects your DNT preference. Please see the Prefinery Do Not Track Policy for more details.
Can I update or correct my information?
The rights you have to request updates or corrections to the information Compulsivo collects depend on your relationship with Compulsivo. Personnel may update or correct their information as detailed in our internal company employment policies.
Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact_us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.
If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization of which you are a customer.
How will I know if there are any changes to this Privacy Policy?
We may revise this Privacy Policy from time to time without notice. Having said that, we will not make changes that result in significant additional uses or disclosures of your personal information without notifying you of such changes via e-mail. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal information, for which an e-mail is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using our Sites and any services we provide. Your continued use of our Sites and our services following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.
Whom do I contact if I have any privacy questions?
If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact our Privacy Agent in any of the following ways:
- By email at support@compulsivo.co
- By postal mail or courier:
Attn: Privacy Agent
Compulsivo, Inc.
1108 Lavaca St Ste 110-318
Austin, TX 78701
Applicable Law
This Privacy Policy is governed by the laws of Texas, USA without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US framework.
By using our Sites or our services or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our Sites, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.