Privacy Policy
Last Updated September, 2023
Congruity360 InfoGov, Inc. (“Congruity360”) is a data management platform for information security, data management, governance, and privacy teams in regulated, data-heavy industries.
This Privacy Policy explains how we handle the personal information of website visitors, our business contacts, and other representatives of prospective and existing customers in connection with our websites and services.
In our capacity as a service provider, we may process personal information pertaining to our customers’ employees, clients, or other end users. This information is governed by our customers’ own privacy policies, as well as our agreements with our customers.
Personal Information We Collect
Personal information you provide:
- Contact details such as your first and last name, organization name, address, email and phone number.
- Communications that we exchange with you, including when you contact us with questions, feedback or otherwise.
- Marketing data such as your preferences for receiving our marketing communications and details about your engagement with them.
Automatic data collection. We, our service providers and our business partners may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the services, online resources and our communications, such as:
- Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings and general location information such as city, state or geographic area.
- Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the services, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them.
We collect this information using cookies and other similar technologies. For more information, please visit our Cookie Policy.
Third party sources. We may combine personal information we receive from you with information we obtain from other sources, such as social media companies and publicly available sources.
How We Use Personal Information
We use personal information for the following purposes or as otherwise described at the time of collection:
Providing and supporting our services. We use personal information to operate, maintain, and provide you with our services. In particular, we will use personal information to perform our contractual obligation under our terms of use, such as to allow you to use the services.
Communicating with you about our services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our services, including by sending announcements, updates, security alerts and support and administrative messages.
Improving, monitoring, personalizing, and protecting our services. It is in our legitimate business interests to improve and keep our services safe for our users, which includes:
- understanding your needs and interests, and personalize your experience with the services and our communications;
- troubleshooting, testing and research and to keep the services secure; and
- investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.
Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the services and promote our business.
Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use personal information for the following marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing communicationssection below.
- Interest-based advertising. We may engage third-party advertising companies, such as Google, to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising for our services to them or similar users on other online platforms. For more information, or to understand your choices, please visit our Cookie Policy.
Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interest. Where we seek your consent, you may withdraw your consent at any time.
Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and internal policies;
- enforce the terms and conditions that govern the services;
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
- comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
How We Disclose Personal Information
We may disclose personal information to the following entities:
Service providers. Companies and individuals that provide services on our behalf or help us operate the services or our business (such as hosting, information technology, customer support, email delivery and website analytics services).
Advertising partners. Third party advertising companies, including for the interest-based advertising described above, that may collect information on the website through cookies and other automated technologies.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Congruity360 (including, in connection with a bankruptcy or similar proceedings).
Privacy Rights and Choices
Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the How to Contact Us section below. You may continue to receive services-related and other non-marketing emails.
Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our services, you may request the following in relation to personal information:
- Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
- Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
- Additional rights, such as to object to and request that we restrict our use of personal information.
To make a request, please email us or write to us as provided in the How to Contact Us section below. We may ask for specific information from you to help us confirm your identity.
Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the How to Contact Us section below. Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.
Other Sites and Services
Our services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.
Job Applicants
When you visit the Work With Us portion of the website, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics and to respond to surveys. We may also use this information to provide improved administration of the services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our terms of use.
Security
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.
Children’s Privacy
Our services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
International Data Transfers
You will provide personal information directly to our website in the United States. We may also transfer personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.
When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the How to Contact Us section below.
Retention of Personal Information
Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.
How to Contact Us
Congruity360 is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).
If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@congruity360.com, or write to us at:
Congruity360 InfoGov Inc.
456 Bedford Street
Fall River, MA 02720
If you are based in the EEA or UK, you can contact us at: privacy@congruity360.com or in writing to:
Congruity 360 InfoGov, Inc.
c/o Electronic Document Consultancy Ltd.
8 Fulmar Crescent
Lisburn, Northern Ireland
BT28 3HT