Privacy Policy

Effective as of January 29, 2021, Vigilance Risk Solutions, Inc. d/b/a CommSafe AI (herein referred to as “CommSafe AI”, “our” or “we”) has updated its Privacy Policy (this “Policy”).

1. Introduction

This Policy details our commitment to protecting the privacy of individuals who:

1. visit our Websites (defined below) (“Website Visitors”) or individuals who request us to contact them via our online web forms;
2. who register to use the products and services which we market for subscription (“Subscribers” or “you”) available at https://commsafe.ai (the “Service(s)”); or
3. attend or register to attend webinars, trainings (on-line or in person), or other events at which CommSafe AI participates (“Attendees”).

For the purposes of this Policy, the term “Websites” shall refer collectively to https://commsafe.ai as well as the other websites that CommSafe AI operates and that link to this Policy. This Policy describes how CommSafe AI collects, uses, shares and secures the personal information that you provide. It also describes your choices regarding use, access and correction of your personal information.

2. Scope Of This Policy

When this Policy applies:

In addition to the Websites that link to this Policy, this Policy applies to the following:

• The CommSafe AI System, which is an integration of G Suite and Office 365, utilized in conjunction with the proprietary intelligence Services to scan for incoming email messages and flag such emails for toxicity. When CommSafe AI accesses the information, this Policy applies. When G Suite and Office 365 utilize the information, their third party privacy policies apply which can be found here and here

When this Policy does not apply – Third party websites:

Our Website may contain links to other websites. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

When this Policy does not apply – Service Data:

With the exception of Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with electronic data, text, messages, communications or other materials submitted to and stored within the Services by you (“Service Data”). Service Data security and privacy practices are detailed in and governed by our Master Subscription Agreement, available here, or such other applicable agreement between you and any member of CommSafe AI relating to your access to and your use of such Services (collectively referred to as the “Service Agreement”).

Subscribers to our Services are solely responsible for establishing policies for, and ensuring compliance with, all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as “data subjects”) with whom our Subscribers interact.

We collect information under the direction of our Subscribers, and have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. The use of information collected through our Services shall be limited to the purpose of providing the service for which Subscribers have engaged CommSafe AI. If you are an individual who interacts with a Subscriber using our Services (such as a customer or user of one of our Subscribers) and require assistance or would either like to amend your contact information or no longer wish to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.

3. Information That You Provide To Us

Account and Registration Information:

We may ask for and may collect personal information about you such as your name, address, phone number, email address, and credit card information, as well as certain related information like your company name and website name, when you register for an account or purchase a license to access or utilize one or more of our Services (an “Account”). We may also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account (an “Agent” or “End-User” as defined in the Service Agreement). We base the processing of your personal information on our legitimate interest, to provide you with the necessary functionality during your use of our Service(s).

We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.

Other Submissions:

We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including: participation in webinars, surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We process your personal information to perform our contract with you for the use of our websites and the Service(s) and to fulfill our obligations under the Service Agreement to you; where we have not entered into the Service Agreement with you, we base the processing of your personal information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request.

4. Information That We Collect From You on our Websites

Cookies and Other Tracking Technologies:

We and our authorized partners may use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites.

We may use web beacons, tags and scripts on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We use AWS and Azzure Cloud to store content information and preferences.

We partner with third parties to either display advertising on the Websites or to manage our advertising on other sites. Our third party partners may also use technologies such as cookies, web beacons, tags, flash, HTML5, scripts, or other tracking technologies to gather information about your activities on our Websites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here and here (or if located in the European Union you may opt into the use of cookies, by clicking here). Please note this does not opt you out of being served ads and you will continue to receive generic, untargeted ads.

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

Analytics:

We collect analytics information when you use the Websites to help us improve them, including through the use of cookies. We may also share aggregated and/or anonymized data about your actions on our Websites with third-party service providers of analytics services. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

5. Information Collected From Other Sources

Social Media Widgets:

The Websites include social media features, such as widgets that link to our Facebook, Twitter, and Linkedin. These features may collect Website Visitors’ Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Website Visitors interactions with these features are governed by the privacy statement of the companies that provide them.

6. How We Use Information That We Collect

General Uses: 

We may use the information we collect about you (including personal information, to the extent applicable) in order to perform our obligations under our Service Agreement with you and on the basis of our legitimate interest including to (a) provide, operate, maintain, improve, and promote the Websites and the Services; (b) enable you to access and use the Websites and the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners (you can opt-out of receiving marketing communications from us by clicking the unsubscribe link embedded in all such emails; (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.

If you have questions about, or need further information concerning, the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.

7. Sharing Of Information Collected

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

We may also share aggregated and/or anonymized information regarding your use of the Services with third parties for marketing purposes based on our legitimate interest to develop and promote Service(s). However, we would never identify you, your Agents or End-Users as the source of the information.

We may collect, and we may engage third-party analytics providers to collect, metrics and information regarding your use of the Service, including evaluating how Agents and End-Users use the Service (“Usage Data”), to develop new features, improve existing features or inform sales and marketing strategies, based on our legitimate interest to improve the Services. When we process Usage Data, any personal information shall be anonymized. Any such third-party analytics providers will not share or otherwise disclose Usage Data, although we may make Usage Data publicly available from time to time.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We always obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at contact@commsafe.ai.

Referrals:

If you choose to use our referral service to tell a friend about our products and services, we will ask you for your friend’s name and email address. You must only provide your friend’s name and email address if you have a reasonable belief they will not object to us contacting them. If you do, we will automatically send your friend an email inviting him or her to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact us at contact@commsafe.ai to request that we remove his/her information from our database.

Community Forums:

The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at contact@commsafe.ai. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

CommSafe AI Group Sharing:

We may share information, including personal information, with any member of CommSafe AI, and they will use that information only for the purposes already described in this Policy. We may also share Service Data with contractors in order to improve our product quality and model performance.

With Your Consent:

We may also share personal information with third parties when we have your prior written consent to do so.

8. Other Important Privacy Information

Notice to End-Users:

Our Services are intended for use by enterprises. Where our Services are made available to you through a Subscriber of ours, that enterprise is the data controller of your personal information. Your data privacy questions and requests should initially be submitted to the CommSafe AI Subscriber in its capacity as your data controller. CommSafe AI is not responsible for our Subscribers’ privacy or security practices which may be different than this Policy.

CommSafe AI’s Subscribers are able to:

• restrict, suspend or terminate your access to the Services; and
• amend your personal information, including your end-user profile.

Data retention:

Where CommSafe AI is the data controller of personal information (for example, personal information relating to Website Visitors, Attendees and individuals who register to use our Services), then we retain the personal information we collect where we have an ongoing legitimate business need to do so (for example, to provide you with our Services, to enable your participation in an event, and to comply with applicable legal, tax or accounting requirements). Data is stored and utilized for purposes of improving product quality and model performance.

If your personal information is processed within a Subscriber’s Service Data, we will process the personal information for as long as we are instructed to do so by the relevant Subscriber that is the data controller of the Subscriber Service Data.

9. How to Exercise Your Data Protection Rights

You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations.

Correcting, updating and removing your information:

An individual who seeks to exercise their data protection rights in respect of personal information stored or processed by us on behalf of a Subscriber of ours within the Subscriber’s Service Data (including to seek access to, or to correct, amend, delete, port or restrict processing of such personal information) should direct his/her query to our Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the personal information, we will respond to their request within thirty (30) days. We will retain personal information that we process and store on behalf of our Subscribers for as long as needed for legitimate business purposes.

Accessing and updating or deleting your information:

Our Services and related documentation give Agents and End-Users the ability to access, update and delete certain personal information from within the Service. For example, you can access your Agent or End-User profile and make updates to your personal information. In cases where we act as the data controller of your personal information, we will provide you with information about whether we hold any of your personal information upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Deactivating your user profile: 

If you no longer wish to use our Services, CommSafe AI’s Subscriber may be able to deactivate your End-User account. First, please contact CommSafe AI’s Subscriber with your request. If you are a CommSafe AI Subscriber and are unable to deactivate an End-User account through your administrator settings, please email contact@commsafe.ai. Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Services.

Request that we stop using your information:

You may request that your personal information no longer be accessed, stored, used and otherwise processed where you believe that CommSafe AI do not have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this Policy. Where you gave us consent to use your personal information for a limited purpose, you can contact us to withdraw that consent. You can also opt-out of our use of your personal information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. Please note that an End-User of a CommSafe AI Subscriber should first contact CommSafe AI’s Subscriber with a request to stop access, storage, use of personal information. If there is delay or dispute as to whether we have the right to continue using your personal information, we will restrict any further use of your personal information until the request is honored or the dispute is resolved, provided the CommSafe AI Subscriber does not object (where applicable).

Opt-out of communications:

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to contact@commsafe.ai. You may opt-out of receiving promotional communications from us by using this unsubscribe link within each email. Even after you opt-out from receiving promotional messages from us, if you are an Agent, then you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.

Other data protection rights:

If you wish to exercise any other data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to contact@commsafe.ai and we will respond to your request in accordance with applicable data protection laws.

You have the right to complain to your local data protection authority if you are unhappy with our data protection practices.

10. Children’s Personal Information

We do not knowingly collect any personal information from children under the age of 16. If you are under the age of 18, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us through the Websites or Services, please contact us at contact@commsafe.ai, and we will use commercially reasonable efforts to delete that information.

11. Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to handle your personal information in accordance with this Policy.

12. Reserved

13. Changes and Updates To This Policy

This Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective.

Your continued use of the Services after any such updates will constitute acceptance of those changes. If you do not accept the terms of an update that is made to this Privacy Policy, you may contact us by mail or email at the address listed above to request that your user account be deleted.

To see when this Privacy Policy was last updated, please see below.

14. Contact Us

If you have questions or complaints regarding this Policy or about the CommSafe AI’s privacy practices, please contact us by email at contact@commsafe.ai or at:

Vigilance Risk Solutions, Inc. d/b/a CommSafe AI
Attn: Legal
2159 India St.
San Diego, CA 92101

(This Privacy Policy was last updated on January 4, 2020).