At Commure, Inc., we recognize that privacy is important! This Privacy Notice along with our Cookie Notice (collectively, the “Commure Privacy Statements”) apply to www.commure.com and its associated sub-domains, and all websites and services or applications that link to the Commure Privacy Statements (the “Site”) and users of the services covered by the Terms of Use and Developer User Agreement (the “Services”). The Commure Privacy Statements describe our policies and practices regarding the online collection, storage, sharing and use of your personal information with respect to the Site and Services.

The Commure Privacy Statements do not apply to any other services or products operated by us, nor do they apply to any third-party websites, products, or services. When using our website, you may encounter embedded content, such as YouTube videos, or you may be directed to other websites. Our provision of a link to any other website or third-party services is for your convenience and does not signify our endorsement of such website or any services, contents, or business practices associated therewith. When you click on such a link, you will leave our Site and go to another site. During this process, a third party may collect information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content and the collection and processing of your information by those websites and third parties fall outside the scope of the Commure Privacy Statements. We encourage you to carefully review the privacy statement of those websites and any website you visit.

IF YOU DO NOT AGREE WITH THE COMMURE PRIVACY STATEMENTS, PLEASE DO NOT USE THE SITE OR SERVICES

What Categories of Personal Information We Collect

1. Registration Information. When you register to receive information regarding our products or services or to create an account with us via the Site or Services, you may provide us with your personal information, such as your name, email address, phone number, address, job title, and/or employer’s name.
2. Correspondence Information. When you correspond with us (whether by email, feedback tools, online forms, or any other form of communication), you may provide us with personal information, such as your name, email address, phone number, address, and other information that you may choose to provide or communicate to us.
3. Job Candidate Information. If you submit a job application or reach out to us with regards to an employment opportunity, you may provide us with your name, email address, phone number, address, and details regarding your employment and academic history. We may also collect the information described above via recruiting agencies acting on either our or your behalf or via other third-party service providers that we leverage to search for and evaluate potential candidates (e.g., LinkedIn).
4. User & Use Information. When you visit our Site and use our Services, we may collect or generate certain device attributes and other online identifiers from you and information regarding your interactions with our Site and Services. Such device and other online identifiers may include your IP address, unique identifiers (UIDs), and device fingerprints, which are typically generated using combinations of IP addresses, UIDs, and/or device attributes such as device type, operating system, device ID, browser type, user agent, etc. Such information regarding your interactions with our Site and Services may include which pages you visit, which links you click on, and which images and objects you interact with. We may also collect such information via our partners and service providers during the course of your interactions with our websites, products, and/or services.

Cookies and Similar Technologies

We use various cookies and similar technologies, including web beacons and local storage, on our Site. For information regarding the cookies and similar technologies we may use, please see our Cookie Notice.

How We Use Your Information

We only use your personal information for the legitimate business purposes set forth below:

1. Products and Services. We may use your personal information to operate and provide the Site and the Services (including to troubleshoot and resolve any bugs or other issues with the Site and Services), personalize and enhance the Site and Services, and develop new websites, products. services, features and functionalities.
2. Customer Support and Correspondences. We may use your personal information to provide technical and account support and to engage with you for the purposes of obtaining your views and feedback on or your use of, and our operation of, our websites, products and services. We may also use your personal information to communicate with you regarding our website, products, services, features, functionalities and other information which may be of interest to you, including news and information regarding our websites, products and services (e.g., announcements about features, functionalities, terms of use, privacy policies or other aspects of our websites, products and services).
3. Sales and Marketing. We may also use your information to otherwise contact you to inform you about or otherwise promote our products and services and to assist you in purchasing our products and services. We do not share your personal information with third parties for their direct marketing purposes.
4. Employment Opportunities. We may use your information when recruiting, evaluating, and processing you as a candidate for open employment opportunities.
5. Security, Investigatory, and Legal Matters. We may use your personal information to: (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist or respond to government enforcement or regulatory agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against third-party claims or allegations; (4) protect the security and integrity of our websites, products, and services; (5) exercise or protect the rights and safety of us, our customers or others; or (6) comply with our legal obligations, including our obligations to comply with subpoenas, court orders, or any regulatory or other legal process.
6. Analysis. We may use your information for analyzing usage trends and patterns and measuring the effectiveness of content, programs, features and functionality of the Site and Services.
7. Permission and Other Purposes. We may use your personal information when we otherwise have your permission or for any other purpose described in the Commure Privacy Statements. And finally, we may use anonymized information derived from your personal information for legitimate business purposes other than those specified in this Policy.

With Whom We Share Your Information

1. Service Providers. We may share your personal information with individuals or entities that provide services to or on our behalf. For example, we may share your IP address and device fingerprint information with our service providers in order to help ensure the security and integrity of our website, products, and/or services. We may also share your account registration information with our service providers who manage the account login portals for our websites, products, and services. Or we may share your name, contact information, and employment history with recruiters to assist us in finding and evaluating candidates for available employment opportunities.
2. Affiliates. We may share your information with our affiliates to operate, provide, develop, enhance, and personalize our websites, products or services and to otherwise assist us in processing your information for the purposes described in How We Use Your Information. For example, we may also share your information with our affiliates in connection with our evaluation of you as a potential job candidate for a position offered by us or one of our affiliates.
3. Third Parties in Connection with Security, Investigatory, and Legal Matters. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to: (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against third-party claims or allegations; (4) protect the security or integrity of our website, products, or services; (5) exercise or protect the rights and safety of us, our customers, or others; or (6) comply with our legal obligations.
4. Third Parties in Connection with Change of Control or Sale. We may also share your personal information to third-parties (e.g., purchasers and their financial and legal representatives) in connection with a sale, merger, or change in control of us or our assets, including in preparation for any such event. Any entity which buys us or any part of our business will have the right to continue to use your personal information, but only in the manner described in this Privacy Notice or as you may otherwise agree.

We Do Not Sell Your Information

We do not sell your personal information to third parties. It’s that simple.

Security of Your Information

In furtherance of our commitment to respecting your privacy rights, we maintain physical, technical and administrative safeguards that are designed to help protect the security of your personal information, and we review, test, and update such measures on an ongoing basis. It is important to remember, however, that no system or method of transmission is 100% secure. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our Site or Services. Use of the Site or Services constitutes an acknowledgement and acceptance of this statement.

Data Storage and Retention

We retain your personal information for a period that we believe to be reasonably necessary for the purposes for which we process such information or as otherwise required by law.

Transfer of Personal Data to the United States

We maintain our headquarters and the vast majority of our processing operations within the United States. As such, your personal data may be transferred to the United States, a country with privacy laws that may not be deemed to provide the same level of protection as the jurisdiction in which you reside. For example, the United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Although we will implement and maintain safeguards to mitigate the risk associated with the transfer of personal data to countries whose privacy laws may not afford you the same degree of protection as the laws of the jurisdiction in which you are located, we cannot guarantee that such measures will fully mitigate such risks. Use of the Site or Services constitute acknowledgement and acceptance of this statement.

Your Privacy Rights Generally

Depending upon where in the world you’re located, the laws to which we are subject, and other factors, you may have certain rights regarding your personal information. Such rights may include:

• Right to Access: Learn more about the categories of your personal information we process, the purposes for which we process it and the categories of recipients with whom we share it, and to access such personal information;
• Right to Rectification: Rectify any inaccurate personal information of yours and ensure it is complete for the purposes for which we process it;
• Right to Erasure (Right to be Forgotten): Delete your personal information in certain circumstances;
• Right to Restrict: Restrict our processing of your personal information in certain circumstances;
• Right to Object: Object to our processing of your personal information;
• Right to Object Against Automated Decision-Making: Not be subject to a decision based solely on automated processing, including profiling, which produces legal or other similar effects (“Automated Decision-Making”) (Note: Automated Decision-Making currently does not take place on our websites or in our services);
• Right to Data Portability: Right to receive a copy of your personal information and to transfer your personal information to another controller;
• Right to Withdraw your Consent: Withdraw your consent to process your personal information at any time (to the extent we base processing on consent); and
• Right Against Discrimination: Not be discriminated against for exercising your rights described above.

Please note that your rights may vary depending upon your location, and certain personal information may be exempt from such requests under applicable law.

For individuals located in the European Union, you can find more information regarding your privacy rights here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

Privacy Rights of California Residents

California residents have the right, under certain circumstances, to request information regarding the sharing of certain categories of “personal information” (as defined by applicable California law) during the prior year to third parties for their direct marketing purposes. As noted above, we do not share your personal information with third parties for their direct marketing purposes. For any questions regarding this, please contact us as described below.

Under the California Consumer Privacy Act (CCPA) California residents have other rights with respect to certain categories of their personal information. This includes the:

• Right to Know:
  • You can request information about, and access to, personal information that we have collected, disclosed, or sold in the past 12 months, including the categories of information collected; sources from which the personal information is collected; personal information that we have sold or disclosed about you for a business purpose; third parties with whom we share personal information; the business or commercial purpose for collecting the information; and the specific pieces of personal information that we have collected about you.
• Right to Deletion:
  • You can request that we delete your personal information (subject to certain exemptions).
• Right to Opt-Out of the Sale of Personal Information:
  • We do not and will not sell your personal information (as defined by the CCPA).
• Right to Non-Discrimination for Exercising your Rights.
  • We do not discriminate against or otherwise take any action adverse to individuals who choose to exercise their rights under the CCPA.

Additionally, we are required to inform California residents of the following:

• Sale of Personal Information: As noted above, we do not and will not sell your personal information.
• Financial Incentives: We do not offer financial incentives for providing personal information.
• Categories of Personal Information Collected: The following categories of information cover the personal information that we intend to collect from our users in the future, in addition to covering what we have previously collected, with our user’s consent, in the past 12 months:
• Identifiers
• Protected Classifications
• Electronic network activity
• Geolocation data;
• Employment-related information; and
• Education information.
• Information Shared for a Business Purpose: We may share any of the above categories of information with our service providers for business purposes in order to provide the Services to you. We do not disclose your personal information to other Third Parties (as defined in the CCPA) without your consent.
• Categories of Sources: The information that we collect comes from individuals using the Site or Services and their devices. This includes information that has been submitted directly by individuals.
• Business Purpose: We collect information from you in order to provide and improve the Services, conduct research and analytics, identify and correct technical errors, secure the services, prevent fraud, and to comply with applicable law.

Any inquiries or requests in relation to these rights can be made using the contact information listed below.

Privacy Rights of Nevada Residents

Commure’s collection and use of personal data is as described above. Commure does not sell personal information. Any inquiries or requests to exercise any rights under Nevada law can be made using the contact information below.

Privacy Rights of Colorado Residents

Commure’s collection and use of personal data is as described above. Any inquiries or requests to exercise rights under Colorado law can be made using the contact information below.

Privacy of Virginia Residents

Commure’s collection and use of personal data is as described above. Any inquiries or requests to exercise rights under Virginia law can be made using the contact information below

Connecticut Privacy Policy Notice

If collected, we will take reasonable measures to protect the confidentiality of Social Security numbers and limit access to those with a need for such information. We prohibit the unlawful disclosure of Social Security numbers.

If you wish to exercise your privacy rights, please contact us via email at privacy@commure.com, or at the mailing address below.  You may authorize an agent to submit such requests on your behalf. We may require you to verify your identity or require your authorized agent to verify their identity, your identity, and their authority to act on your behalf before fulfilling a request to exercise your rights.

Changes to the Commure Privacy Statements

We may update the Commure Privacy Statements from time to time to reflect changes in our practices or business, the Site or Services, or other factors. If we do, we will post the updated Commure Privacy Statement(s) as well as the effective date of such updates.

Because the Commure Privacy Statements can change at any time, we encourage you to periodically review them to stay informed about our collection, processing, and sharing of your personal information.

Children

Our Site and Services are not directed toward children. Children under the age of eighteen years old are not eligible to use our Services, and we therefore ask that children do not submit any personal information to us, or use our Services provided on, through or via our Site. If you are a parent or guardian of a child and believe that your child provided us with their personal information, please contact us at privacy@commure.com.

A Note on Protected Health Information (PHI)

Commure processes PHI on behalf of HIPAA Covered Entities and complies with the HIPAA Privacy and Security Rule as well as the applicable privacy practices of the HIPAA Covered Entities with whom it contracts.

Questions, Concerns, or Complaints

If you have any questions, concerns, or complaints regarding the Commure Privacy Statements or our practices regarding your personal information, please contact us at:

Mail:
Commure, Inc.
160 S. Whisman Rd
Mountain View, CA 94041
Attn: Privacy Department

Email: privacy@commure.com