GDPR Addendum to our Privacy Policy

Effective or updated date: May 25, 2021

This GDPR addendum to our privacy policy applies between you, the User of this Website and CompleteCSM the owner and provider of this Website. CompleteCSM takes the privacy of your information very seriously. This GDPR addendum to our privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. This GDPR addendum to our privacy policy should be read alongside, and in addition to, our Terms and Conditions, and our Privacy Policy. Please read this GDPR Addendum to our privacy policy carefully.

Definitions and interpretation

1.    In this GDPR Addendum to our privacy policy, the following definitions are used:

Datacollectively all information that you submit to CompleteCSM via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookiesa small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below ( Cookies);
Data Protection Lawsany applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPRthe UK General Data Protection Regulation;
CompleteCSM, we  or usCompleteCSM, Inc. a company incorporated in the United States of America, whose registered office is at 2734 Sylvan Way, Mckinney, TX,  75072; 
UK and EU Cookie Lawthe Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or youany third party that accesses the Website and is not either (i) employed by CompleteCSM and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to CompleteCSM and accessing the Website in connection with the provision of such services; and
Websitethe website that you are currently using, completecsm.ai, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this GDPR Addendum to our privacy policy, unless the context requires a different interpretation:

a.   the singular includes the plural and vice versa;

b.   references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this GDPR Addendum to our privacy policy;

c.   a reference to a person includes firms, companies, government entities, trusts and partnerships;

d.   “including” is understood to mean “including without limitation”;

e.   reference to any statutory provision includes any modification or amendment of it;

f.   the headings and sub-headings do not form part of this GDPR Addendum to our privacy policy.

Scope of this GDPR Addendum to our privacy policy

3.    This GDPR Addendum to our privacy policy applies only to the actions of CompleteCSM and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4.    For purposes of the applicable Data Protection Laws, CompleteCSM is the “data controller”. This means that CompleteCSM determines the purposes for which, and the manner in which, your Data is processed.

Data collected

5.    We may collect the following Data, which includes personal Data, from you:

a.   name;

b.   job title;

c.   contact Information such as email addresses and telephone numbers;

in each case, in accordance with this GDPR Addendum to our privacy policy.

How we collect Data

6.    We collect Data in the following ways:

a.   data is given to us by you ; and

b.   data is collected automatically..

Data that is given to us by you

7.    CompleteCSM will collect your Data in a number of ways, for example:

a.   when you contact us through the Website, by telephone, post, e-mail or through any other means;

b.   when you register with us and set up an account to receive our products/services;

c.   when you elect to receive marketing communications from us;

d.   when you use our services;

in each case, in accordance with this GDPR Addendum to our privacy policy.

Data that is collected automatically

8.    To the extent that you access the Website, we will collect your Data automatically, for example:

a.   we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

b.   we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our use of Data

9.    Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

a.   internal record keeping;

b.   improvement of our products / services;

in each case, in accordance with this GDPR Addendum to our privacy policy.

10.      We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

11.      When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Who we share Data with

12.      We may share your Data with the following groups of people for the following reasons:

a.   our employees, agents and/or professional advisors – to obtain advice from professional advisers;

in each case, in accordance with this GDPR Addendum to our privacy policy.

Keeping Data secure

13.      We will use technical and organisational measures to safeguard your Data, for example:

a.   access to your account is controlled by a password and a user name that is unique to you.

b.   we store your Data on secure servers.

14.      Our Data center is contained within Amazon Web services in the United States and it is certified to SOC 2. This family of standards helps us manage your Data and keep it secure.

15.      Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected].

16.      If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

17.      Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this GDPR Addendum to our privacy policy or until you request that the Data be deleted.

18.      Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

19.      You have the following rights in relation to your Data:

a.   Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b.   Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

c.   Right to erase – the right to request that we delete or remove your Data from our systems.

d.   Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.

e.   Right to data portability – the right to request that we move, copy or transfer your Data.

f.   Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

20.      To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected].

21.      If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

22.      It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

23.      This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This GDPR Addendum to our privacy policy does not extend to your use of such websites. You are advised to read the GDPR Addendum to our privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

24.      CompleteCSM may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of CompleteCSM. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this GDPR Addendum to our privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

25.      We may also disclose Data to a prospective purchaser of our business or any part of it.

26.      In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

27.      This Website may place and access certain Cookies on your computer.    CompleteCSM uses Cookies to improve your experience of using the Website and to improve our range of products and services.   CompleteCSM has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

28.      All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

29.      Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling CompleteCSM to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

30.      This Website may place the following Cookies:

Type of CookiePurpose
Strictly necessary cookiesThese are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

31.      You can find a list of Cookies that we use in the Cookies Schedule.

32.      You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

33.      You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

34.      It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

35.      For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Effective or updated date: May 25, 2021