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Conforma Compliance Group, Privacy Statement

Effective Date:    June 1, 2024

 

This Privacy Statement describes the practices of Conforma Compliance Group, LLP (“Conforma”, “we” or “us”) with respect to personal information we collect through our Web sites and mobile applications that display or link to this Privacy Statement (the “Sites”).  

 

Collection of Personal Information 

We collect personal information that you voluntarily provide when you visit our Sites. For example, we collect information about you when you:

  • Sign up to receive advisories, articles, announcements or other communications.

  • Register for an event;

  • Apply for a job with Conforma; or

  • Submit a comment or question or otherwise communicate with us through the Sites.

The personal information we collect may include your first and last name, street address, telephone number, email address, communication preferences, password, and other information you submit through the Sites. If you apply for a job through our Sites, we may gather additional information about you, such as your resume, cover letter, work history, reference information, education information, information required to complete a background check and any other information you elect to provide us (e.g., career objectives, willingness to relocate, awards or professional memberships).

We also collect certain information automatically when you visit our Sites (“Technical Information”). Technical Information may include the IP address of your device; the type of browser, device and operating system you use; other identifiers associated with the device you use to access our Sites; the pages you visit and the features you use, including dates and times; and if you navigated from or navigate to another Web site, the address of that Web site. We may collect Technical Information through the use of cookies, clear .gifs, web beacons, local shared objects, Flash cookies or other tags, identifiers or technologies as they may become available or change over time. We may track the total number of visitors to our Sites, the number of visitors to each page of our Sites, whether visitors share our Sites with others, and the domain names of our visitors’ Internet service providers. We may also collect information regarding the effectiveness of our email or other communications, such as whether you open an email we send to you.

Please note that third party ad networks and service providers may receive Technical Information and use and disclose such Technical Information for their own purposes, subject to their own privacy policies. Our Sites also use Wix Analytics and Google Analytics to analyze your website activity. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

 

How We Use Personal Information Collected through the Sites  

We use personal information we collect through our Sites to contact you, to provide you with information that you have requested, to provide additional information which we believe may be of interest to you, to perform an activity you have requested (such as to register you for an event or to evaluate an application for a job opportunity), to enhance or improve the Sites, for security purposes, or otherwise to operate our business. 

Sharing of Personal Information 

We may share personal information with third parties in the following circumstances:

  • When authorized by you.

  • With third party service providers retained to perform services on our behalf. These service providers are not authorized to use or disclose the information except as necessary to provide services to us.

  • If we are required to do so by law or pursuant to legal process, or in response to a request from law enforcement authorities or other government officials.

  • When we believe disclosure is necessary or appropriate to prevent physical harm or financial fraud or theft, or in connection with an investigation of suspected or actual illegal activity.

  • In connection with the sale or transfer of all or a portion of our business or assets to a third party.

Your Choices and Rights

You may unsubscribe from advisories, articles, announcements and other promotional emails received from us by following the unsubscribe link included at the bottom of each such email or by contacting us at info@conformacg.com. Please note that you may continue to receive non-promotional communications to the extent permitted by law. Your browser and your device may enable you to limit the use of cookies and other technologies used to collect Technical Information. You should consult documentation for your browser or device for more information about exercising these options. Please note that you may not be able to use all the features of our Sites if you limit the Technical Information you share with us. To request details of the personal information we hold about you or to delete or rectify any inaccurate personal information about you please contact us at info@conformacg.com We will handle any such request in accordance with applicable law. Please note that we may take reasonable steps to verify your identity before implementing your request.

Information Security 

We maintain administrative, technical and physical safeguards for the Sites designed to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal information we collect through our Sites. The use of the Internet creates inherent information security risks, and we are not able to guarantee the security of our Sites.

 

Data Retention

Your personal information will not be stored for longer than necessary for the purposes for which they were collected or as required under applicable retention policies and/or in accordance with applicable law.  Our retention policies reflect local statute of limitation periods and legal obligations of Conforma.

Transfers of Personal Information

We may transfer the personal information we collect through the Sites to countries with laws that may be deemed not to provide the same level of data protection as the laws in the country in which you reside. Please note that our primary data processing facilities are located in the United States of America. By submitting personal information through the Sites, you consent to the transfer of personal information as described in this Privacy Statement.

Linked Sites 

The Sites may include links to sites operated by external third parties. The inclusion of a link to a third party site does not imply our endorsement of the site or the products and services offered at such site. Please note that this Privacy Statement does not apply to any such third-party sites. You should consult the privacy policies of each site you visit.

Additional Notice for California and Virginia Consumers

This part of our Privacy Statement applies to consumers who reside in the State of California or Virginia.

We describe the personal information we have collected from consumers in the twelve (12) months preceding the effective date of this Privacy Statement in the part of our Privacy Statement titled “Collection of Personal Information.”  The information we have obtained includes the following:

  • Identifiers such as a real name, postal address, telephone number, Internet Protocol address, email address, password, social security number, driver’s license number, or other similar identifiers.

  • Personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute). This means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, identifiers listed above.

  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

  • Electronic, visual or similar information.

  • Professional or employment-related information.

  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

  • Inferences drawn from any of the information identified in this Additional Notice to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., we may collect this information in connection with website analytics or job applications).

  • Sensitive personal information such as social security number, driver’s license number, or passport number in each case as further described above in the relevant categories.

We collect this personal information when you use our Sites.  For more information, please see “Collection of Personal Information” above. 

 

Disclosures of Personal Information about California or Virginia Consumers

We have not disclosed to other businesses or third parties any personal information for monetary or other valuable consideration within the twelve (12) months preceding the effective date of this Privacy Statement. 

We have disclosed personal information to our service providers for business purposes in the prior twelve (12) months. The information we have disclosed for business purposes may include some or all of the categories listed above. For more information about the categories of entities to which we have disclosed this information and the purposes for which we have disclosed the information, please see “Sharing of Personal Information” above.

Use of Personal Information about California or Virginia Consumers

We use the personal information we collect about California and Virginia consumers for the purposes disclosed within the this Privacy Statement.  For more information, please see “How We Use Personal Information Collected through the Sites” above. 

The business purposes for which we may use personal information about California and Virginia consumers include:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with California and Virginia law and other applicable standards;

  • Helping to ensure security and integrity to the extent the use of a consumer's personal information is reasonably necessary and proportionate for these purposes;

  • Debugging to identify and repair errors in our systems;

  • Short-term, transient use including non-personalized advertising shown as part of a consumer’s current interaction with us;

  • Performing services on our behalf on behalf of another, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying identity information, processing payments, and other services.

  • Undertaking internal research for technological development and demonstration.

  • Conducting activities to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide.

We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, purposes disclosed elsewhere in this Privacy Statement, or for purposes compatible with the context in which the personal information was collected.

We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers.

 

Your Privacy Rights 

If you are a California or Virginia resident, you have certain rights in the information listed in this Additional Notice, subject to applicable exclusions, limitations, and conditions of applicable law. You may exercise these rights free of charge except as otherwise permitted under applicable law. These rights are as follows:

  • Right to Delete. You have the right to request that we delete personal information that we have collected about you. Please note if you have requested a service that requires the use of your personal information, we may not be able to provide that service if you choose to delete your personal information.

  • Right to Access. You may request that we disclose to you: 

    • whether we are processing personal information about you;

    • the categories of personal information we have collected about you;

    • the categories of sources from which the personal information is collected;

    • our business or commercial purpose for collecting, selling, or sharing personal information;

    • the categories of third parties to whom we disclose personal information;

    • the specific pieces of information we have collected about you;

    • the categories of personal information about you, if any, that we have sold or shared and the categories of third parties to which we have sold or shared the information, by category or categories of personal information for each category of third party to whom we sold or shared the personal information; and

    • the categories of personal information about you that we disclosed for a business purpose and the categories of recipients to whom we disclosed the information for a business purpose.

As used above, “sale,” “sold,” “selling,” “shared,” and “sharing” have the meanings provided in the California Consumer Privacy Act of 2018 and the Virginia Consumer Data Protection Act, each as amended.

  • Right to Correct. You have the right to request that we correct inaccurate personal information that we have collected about you.

  • Right to Appeal. If you are a Virginia resident and we decline to take action on a request that you make in accordance with the foregoing to exercise the foregoing privacy rights, then you may appeal our decision by directly responding to our denial decision email or as provided below under “Requests to Exercise Your Rights.”

 

Requests to Exercise Your Rights

You may request to exercise these rights by:

As required or permitted under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights.

Do Not Track

Please note that our Sites are not designed to respond to "do not track" requests from Web browsers.

Changes and Questions 

Conforma may revise this Privacy Statement from time-to-time. Please check this page periodically for changes. If you have questions about this Privacy Statement or our practices with respect to personal information, please send your request to info@conformacg.com.

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