PRIVACY POLICY

Purpose

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

• The personal data we will collect;
• Use of collected data;
• Who has access to the data collected;
• The rights of site users; and
• The Site's cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

Consent

By using our Site users agree that they consent to:

• The conditions set out in this Privacy Policy.

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal basis to collect and process the personal data of users in the EU:

• Processing of user personal data is necessary for us or a third pary to pursue a legitimate interest. Our legitimate interest is not overriden by the interests or fundamenal rights and freedoms of users. Our legitimate interest(s) are: Contacting potential clients in response to their inquiries regarding our services.

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically

When you visit and use our Site, we may automatically collect and store the following information:

• IP address; and
• Hardware and software details.

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

• IP address;
• Hardware and software details;
• First and last names;
• Email address;
• Your country; and
• Phone number.

This data may be collected using the following methods:

• Filling out a client inquiry form.

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

• Functioning of the website.

The data we collect when the user performs certain functions may be used for the following purposes:

• To contact potential clients about the services we offer.

Who We Share Personal Data With

Employees

We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Third Parties

We may share user data with the following third parties:

• usebasin.com
• Subcontractors we engage to answer client inquiries on our behalf

We may share the following user data with third parties:

• Inquiry form data

We may share user data with third parties for the following purposes:

• Answering inquiries of potential clients

Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

• If the law requires it;
• If it is required for any legal proceeding;
• To prove or protect our legal rights; and
• To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data

User data held by us will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data

We have security measures in place to protect user data. All data is only accessible to our employees. Our employees are bound by confidentiality agreements and a breach of this agreement would result in the employee's termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

Your Rights as a User

Under the GDPR, you have the following rights:

• Right to be informed;
• Right of access;
• Right to rectification;
• Right to erasure;
• Right to restrict processing;
• Right to data portability; and
• Right to object.

Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our director here:

privacy@codecompass.ca

Do Not Track Notice

Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not respond to browser-initiated DNT signals. We are not responsible for and cannot guarantee how any third parties who interact with our Site and your data will respond to DNT signals.

Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Contact Information

If you have any questions, concerns or complaints, you can contact our director, at:

privacy@codecompass.ca