Terms and Conditions

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1.1 Qompass LLC (“Qompass”) has developed this Privacy Policy in order to demonstrate Qompass' firm commitment to your privacy.

1.2 This Privacy Policy describes how Qompass will collect, use, disclose, retain and protect your Personal Information in order to provide you with access to a variety of resources, including Cloud Services offered and maintained by us and Qompass' Affiliates.

1.3 This Privacy Policy should be read in conjunction with Qompass' Terms of Use and where applicable, Qompass' Services Agreement.

1.4 As used herein, the following terms shall have the following meanings:

“Affiliate” means a corporation that controls, is controlled by, or is under common control with, Qompass.

“Qompass Cloud Services” means those Cloud Services offered by Qompass to its subscribers.

“Cloud Infrastructure” means those computing devices, including servers, networking equipment, data storage devices, and associated software used in the provision of the Cloud Services.

“Cloud Services” means computing resources provided by way of the Internet and may include the provision of storage, software, platform, computing services or other resources.

“Personal Information” means information about an identifiable individual, and may include information such as a person’s name, email address, residential address, telephone number, bank account details, and in some cases, more sensitive information such as but not limited to gender, demographic information, family status, investment particulars, consumption preferences, business expenditures, credit score, accounting data, social security or social insurance numbers, bank account information, passports, drivers licenses and payment card information.”

“Subscriber Data” means any content, information, and data input by you using the Cloud Services licensed hereunder, and data derived therefrom.

2.1 If you have any questions or complaints about this Privacy Policy, please contact our Security and Compliance team.

3.1 For the purposes of this Privacy Policy, the term “website” means www.yourcompass.com, www.qompass.app and any other websites operated by Qompass in providing the Qompass Cloud Services and includes all related webpages, and all related websites operated by Affiliates, but does not include any third-party websites which are linked to or may link from the website whether or not such third-party websites are used in connection with the Qompass Cloud Services.

4.1 Qompass' Security and Compliance Manager is responsible for the oversight and implementation of this Privacy Policy and procedures to protect Personal Information, for receiving your privacy-related questions, and for providing you with information about Qompass' privacy practices, by posting updated information on Qompass' website.

5.1 Qompass collects Personal Information directly from you and only obtains Personal Information from other organizations (e.g., your bank or other third-party service providers) when you provide Qompass with the account numbers, passwords or other credentials required to retrieve the Personal Information and for the purpose of providing you with Qompass Cloud Services. Qompass uses and discloses the Personal Information only as described in this Privacy Policy and Qompass' Terms of Use.

5.2 To the extent Subscriber Data includes Personal Information about others (including any Personal Information of your clients’ or third parties), you represent and warrant that you have obtained all necessary consents to disclose such Personal Information to Qompass, and to allow Qompass to process such Personal Information in accordance with this Privacy Policy.

5.3 You can opt out of any e-mail communication sent by Qompass or its Affiliates. Qompass' e-mails will contain clear and obvious instructions describing how you can be removed from any mailing list. Qompass will remove you at your request within a reasonable amount of time.

6.1 Qompass collects, uses and discloses Personal Information only for the purposes of providing you with Qompass Cloud Services, and in improving Cloud Services or Cloud Infrastructure and for such other ancillary purposes consented to by you as a user of the Qompass Cloud Services, or as required by law.

7.1 Use of Qompass  Cloud Services may require you to provide Subscriber Data. That Subscriber Data may include Personal Information.

7.2 Qompass may collect Personal Information directly from you when you:

· register to use the Qompass Cloud Services;

· use the Qompass Cloud Services;

· provide Subscriber Data;

· contact Qompass for support; and

· visit Qompass' websites.

7.3 You can always choose not to provide Personal Information to Qompass, but it may mean that Qompass is unable to provide you with Qompass Cloud Services.

8.1 Qompass collects, uses and discloses information (which may include Personal Information) for the following purposes:

· To verify your identity.

· To provide you with the Qompass Cloud Services. Qompass may collect contact, billing or credit information including phone numbers, email addresses and physical addresses, or information related to your clients for billing purposes. Qompass Cloud Services may, for example, require data related to you or your clients in order to the provide Qompass Cloud Services, or to promote or offer you products, services and offers (including new and other Services which are offered by Qompass and its Affiliates) that may be relevant to you.

· To contact you for the purposes of product information, service updates, billing notifications, or notifications relating to the Qompass Cloud Services. In particular, Qompass requires you to give us necessary contact information such as name and email address. We also ask for unique identifiers (log-in password names). Qompass uses such contact information to send information about Qompass' or its Affiliates’ products and services.

· To monitor and/or improve system usage, server and software performance. Qompass may use login information, and IP addresses of computers which access the Cloud Infrastructure to help diagnose any problems with the Cloud Infrastructure, and to administer our website to help identify you and to gather broad demographic information. Qompass may use cookies or tracking technologies to monitor access to the Cloud Infrastructure, to save your password, or otherwise allow offering of the Qompass Cloud Services.

· To assist you with technical support issues.

· To comply with any laws, regulations, court orders, subpoenas or other legal process or investigation and to protect Qompass, its Affiliates and other individuals from harm.

· To improve and enhance Qompass Service offerings. Qompass may use Personal Information provided by its users in an anonymous, and/or aggregated fashion to improve or enhance its Cloud Services and other service offerings

9.1 Qompass relies on you to ensure that the Personal Information you provide to us while using the Qompass Cloud Services is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Upon request, Qompass will provide you with information Qompass holds about you. You are welcome to make changes, request deletions or corrections to this Personal Information at any time by contacting us at the contact information listed in this Privacy Policy. We will respond to your request within a reasonable timeframe. Notwithstanding the foregoing, shall not apply to any Personal Information contained in Subscriber Data. Such Personal Information can only be accessed through, and in such a manner as provided by, the Qompass Cloud Services.

9.2 You are responsible for ensuring that the information you have provided is truthful, accurate, reliable and complete, and does not infringe the rights of others.

9.3 Qompass will retain Subscriber Data provided by you as long as you (or your organization) remain(s) a subscriber of the Qompass Cloud Services in good standing, in accordance with the Qompass Cloud Services Agreement. Qompass will retain and use your Personal Information as necessary to comply with Qompass' legal obligations, resolve disputes, and enforce agreements with Qompass.

10.1 Qompass uses third party data hosting providers (Digital Ocean Web Services) to host its Cloud Services and Subscriber Data on servers located in throughout the world.

10.2 Upon subscribing to the Qompass Cloud Services, Qompass shall inform you of the jurisdiction in which the server that has be allocated to host your Subscriber Data and Personal Information is located. At present, Qompass uses servers in the United States, Australia, Canada, and Europe. You may consent to such allocation, or refuse a server so allocated. If you refuse allocation of a server, Qompass may not be able to provide you with Qompass Cloud Services.

10.3 By entering personal information into the Qompass Cloud Services, you consent to that Personal Information being hosted on servers where allocated. Each data hosting provider’s role is limited to providing a hosting and storage service to Qompass, and Qompass has taken reasonable measure to ensure that our data hosting providers will not access the data, and will use the necessary level of protection for, Personal Information. They do not control, and are not permitted to access or use your personal information, except for the limited purpose of storing the information.

10.4 If You do not want Your Personal Information to be transferred to a server as described above, You should not provide Qompass with Personal Information or use the Qompass Cloud Service.

11.1 Qompass is committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from unauthorized access, modification and disclosure. Your Personal Information is stored on secure servers that are encrypted, and all data transferred between you and the Qompass Cloud Services is encrypted.

11.2 However, the Internet is not in itself a secure environment and Qompass cannot give an absolute assurance that your Personal Information will be secure at all times. Transmission of Personal Information over the Internet is at your own risk and you should only enter, or instruct the entering of, Personal Information to the Qompass Cloud Services within a secure environment.

11.3 Qompass will advise you at the first reasonable opportunity upon discovering or being advised of an incident where your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by unauthorized persons or in an unauthorized manner.

12.1 Qompass makes no claim to your Subscriber Data. Upon request, Qompass will provide you with a list of the third-party service providers used to host your Subscriber Data, and the countries in which our servers are located.

13.1 Qompass makes clear and transparent notice of its privacy practices publicly available through this Privacy Policy. Qompass reserves the right to change this Privacy Policy at any time, and any amended Privacy Policy is effective upon posting to the website. Qompass will make every effort to communicate any significant changes to you via email or notification via the Qompass Cloud Services. Your continued use of the Qompass Cloud Services will be deemed acceptance of any amended Privacy Policy.