“Personal Information” means: any information that identifies an individual, such as, name, social security number or other government issued number, date of birth, physical and email addresses, telephone number, biometric data, mother’s maiden name, or other personally identifiable information.
Information We Collect and How We Obtain It
For Comprise consumer customers (i.e., individuals who use our Products, Website(s) and Mobile Apps) we may collect personal information such as your name, email address, library card number and PIN (Personal Identification Number). In addition, Comprise may record location data indicating where you are using our Products, Website(s) or Mobile Apps as well as collect geolocation data from your personal device which can be done through IP, Wi-Fi or GPS.
Comprise will try to collect personal information directly from the individual concerned unless authorized by that individual to collect it from a third party such as the entity (most often a public library) sponsoring the use of our Products, Website(s) or Mobile Apps, or as otherwise permitted by law.
Purposes for Collecting Personal Information
Through our Products, Website(s) and Mobile Apps, Comprise collects, uses and discloses to certain third parties personal information for the following primary purposes:
to develop, manage and deliver our products and services to our customers;
to ensure high standards of service to customers;
to contact customers with product and service updates, upgrades and enhancements;
to meet regulatory requirements; and
to verify a customer’s identity.
Comprise will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified.
Consent can be implied when you are informed that information will be used for certain purposes and you submit the information with this knowledge, or consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.
Comprise may collect, use or disclose personal information without your knowledge or consent in the following limited circumstances:
When the collection, use or disclosure of personal information is permitted or required by law (including subpoenas, search warrants, court orders and government orders);
In an emergency that threatens an individual’s life, health or personal security;
When the personal information is available from a public source (e.g. a telephone directory);
When we require legal advice from a lawyer;
In connection with criminal justice, taxation or regulatory activities;
To protect ourselves from fraud or to protect the rights and property of Comprise;
To investigate an anticipated breach of an agreement or a contravention of law; or
You may request that your personal information be removed from our databases and records, by giving reasonable notice. All communications with respect to the withdrawal of consent should be made in writing and addressed to Comprise Compliance Officer.
Limited Use, Disclosure and Retention
Comprise may share personal information with our employees, contractors, consultants, service providers, business partners and other parties who require such information to assist us with providing you with our products and services. By providing personal information to Comprise, you will be deemed to have consented to the disclosure of your personal information to such parties.
The use, collection and disclosure of personal information may involve Comprise transferring personal information across borders. If this occurs, we will comply with all applicable trans-border data flow privacy laws.
Comprise will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for legal or business purposes. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous.
Comprise Technologies is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.
Comprise will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used.
You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Comprise Compliance Officer and must provide sufficient detail to identify the personal information and the correction being sought.
Safeguarding Personal Information
Comprise will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Comprise as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the personal information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically).
Comprise will use appropriate security measures when disposing of and destroying personal information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.
Comprise will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Comprise will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Comprise and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a regulatory body in any relevant jurisdiction.
Comprise will also regularly review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Requests for Access
You have the right to access your personal information, subject to limited exceptions under applicable laws such as lawyer-client privilege, disclosure that would reveal personal information about another person, legal obligations and proprietary rights. Comprise Compliance Officer will assist you with your request. This includes:
Identification of and access to any or all of your personal information under Comprise custody or control.
An explanation of how that personal information is or has been collected, used or disclosed by Comprise.
All requests should be made in writing (by mail, fax or email), provide sufficient detail to identify the information being sought, and be directed to Comprise Compliance Officer who may require further information defining the request more succinctly.
We will respond to written requests within thirty (30) days of receiving such request. We will either make the requested information available within that time period, or provide written notice of an extension where additional time is required to fulfill the request. If Comprise cannot fulfill your request in full or in part, you will be provided with a response in writing that documents the reason for refusal and the recourse available to you.
Comprise Technologies, Inc.
1041 Route 36, POB 425
Navesink, NJ 07752
Specific details about the inquiry or complaint must be provided. All complaints will be investigated and will be responded to in accordance with the section above as well as applicable laws. If the Comprise Compliance Officer is unable to address your concerns, the issue may be escalated to the office of the CEO or to the relevant regulatory authority.
© 2014, 2018 Comprise Technologies, Inc.