ISMS Copilot Website Privacy Policy
Last updated: July 27, 2024
This privacy notice for ISMS Copilot ("Company," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
- Visit our website at https://ismscopilot.com, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
This privacy notice only covers the use of our public website (ismscopilot.com) and does not cover our app or any related services (app.ismscopilot.com). Consult our Application Privacy Policy here.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us using the contact form in the website footer.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice. You can find more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
- What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with ISMS Copilot and the Services, the choices you make, and the products and features you use.
- Do we process any sensitive personal information? We do not process sensitive personal information.
- Do we receive any information from third parties? We do not receive any information from third parties.
- How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, and comply with law. We may also process your information for other purposes with your consent.
- In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
- How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
- What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
- How do you exercise your rights? The easiest way to exercise your rights is by contacting us using the contact form in the website footer. We will consider and act upon any request in accordance with applicable data protection laws.
1. WHAT INFORMATION DO WE COLLECT
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our services, or when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services. The personal information we collect may include the following:
- Names
- Email addresses
Sensitive Information. We do not process sensitive information.
Information automatically collected
In Short: Some information — such as your browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your browser and device characteristics, operating system, language preferences, referring URLs, device name, country, and information about how and when you use our Services. This information is primarily needed for our internal analytics and reporting purposes.
The information we collect includes:
- Usage Data. We use PostHog to collect anonymized usage data to understand how visitors interact with our website. This includes information such as the pages visited, time spent on the site, and actions taken. This data helps us improve our website's functionality and user experience.
2. HOW DO WE PROCESS YOUR INFORMATION
In Short: We process your information to provide and improve our Services and communicate with you. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To provide and improve our Services. We may process your information to deliver and enhance the services you request.
- To respond to user inquiries. We may process your information to respond to your inquiries and address any potential issues you might have.
- To send administrative information to you. We may process your information to send you details about our services, changes to our terms and policies, and other similar information.
- To send you marketing and promotional communications. With your consent, we may process the personal information you provide to send you marketing and promotional communications. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS" below.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Send users information about our services.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Service Providers. We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. This includes tally.so for contact forms and ConvertKit for newsletters.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our website is at your own risk. You should only access the website within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS
In Short: We do not knowingly collect data from or market to children under 18 years of age.We do not knowingly solicit data from or market to children under 18 years of age.
By using our website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of our website. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us using the contact form in the website footer.
8. WHAT ARE YOUR PRIVACY RIGHTS
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right to:
- Request access and obtain a copy of your personal information.
- Request rectification or erasure.
- Restrict the processing of your personal information.
- Data portability, if applicable.
- Object to the processing of your personal information in certain circumstances.
You can make such a request by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE" below. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.
If you are located in Switzerland, the contact details for the data protection authorities are available here.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. This will not affect the lawfulness of the processing before its withdrawal.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you to send you service-related messages that are necessary for the administration and use of our website, to respond to service requests, or for other non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at contact@ismscopilot.com.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. As no uniform technology standard for recognizing and implementing DNT signals has been finalized, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
However, we respect your privacy and provide you with the ability to manage your cookie preferences. If you are located in the EU, you will be presented with options to accept or decline different types of cookies when you visit our website. These preferences allow you to control the data collected through cookies.
If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
1. Every individual who is in the State of California for other than a temporary or transitory purpose.
2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect
We have collected the following categories of personal information in the past twelve (12) months, only if you provide it to us with your consent:
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, email address (only if provided with consent) - YES
As indicated by the "NO", the following categories haven't been collected:
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information - NO
C. Protected classification characteristics under California or federal law
Gender and date of birth - NO
D. Commercial information
Transaction information, purchase history, financial details, and payment information - NO
E. Biometric information
Fingerprints and voiceprints - NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements - NO
G. Geolocation data
Device location - NO
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities - NO
I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us - NO
J. Education Information
Student records and directory information - NO
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics - NO
L. Sensitive Personal Information
NO
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at contact@ismscopilot.com, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
ISMS Copilot has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. ISMS Copilot will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
- Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
- Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information;
- The categories of personal information that we collect;
- The purposes for which the collected personal information is used;
- Whether we sell or share personal information to third parties;
- The categories of personal information that we sold, shared, or disclosed for a business purpose;
- The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- The business or commercial purpose for collecting, selling, or sharing personal information; and
- The specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
- Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
- Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at contact@ismscopilot.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
- Consumer: A natural person who is a resident of Virginia acting in an individual or household context. It does not include a natural person acting in a commercial or employment context.
- Personal data: Any information linked or reasonably linkable to an identified or identifiable natural person. It does not include de-identified data or publicly available information.
- Sale of personal data: The exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your Rights Under the Virginia CDPA
- Right to be informed whether or not we are processing your personal data.
- Right to access your personal data.
- Right to correct inaccuracies in your personal data.
- Right to request deletion of your personal data.
- Right to obtain a copy of the personal data you previously shared with us.
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
ISMS Copilot has not sold any personal data to third parties for business or commercial purposes. ISMS Copilot will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise Your Rights
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at contact@ismscopilot.com, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification Process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to Appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at contact@ismscopilot.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
12. DO WE MAKE UPDATES TO THIS NOTICE
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE
If you have questions or comments about this notice, you may email us at contact@ismscopilot.com.
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU
You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at: contact@ismscopilot.com.
This privacy notice for ISMS Copilot ("Company," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
- Visit our website at https://ismscopilot.com, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
This privacy notice only covers the use of our public website (ismscopilot.com) and does not cover our app or any related services (app.ismscopilot.com). Consult our Application Privacy Policy here.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us using the contact form in the website footer.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice. You can find more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
- What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with ISMS Copilot and the Services, the choices you make, and the products and features you use.
- Do we process any sensitive personal information? We do not process sensitive personal information.
- Do we receive any information from third parties? We do not receive any information from third parties.
- How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, and comply with law. We may also process your information for other purposes with your consent.
- In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
- How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
- What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
- How do you exercise your rights? The easiest way to exercise your rights is by contacting us using the contact form in the website footer. We will consider and act upon any request in accordance with applicable data protection laws.
1. WHAT INFORMATION DO WE COLLECT
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our services, or when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services. The personal information we collect may include the following:
- Names
- Email addresses
Sensitive Information. We do not process sensitive information.
Information automatically collected
In Short: Some information — such as your browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your browser and device characteristics, operating system, language preferences, referring URLs, device name, country, and information about how and when you use our Services. This information is primarily needed for our internal analytics and reporting purposes.
The information we collect includes:
- Usage Data. We use PostHog to collect anonymized usage data to understand how visitors interact with our website. This includes information such as the pages visited, time spent on the site, and actions taken. This data helps us improve our website's functionality and user experience.
2. HOW DO WE PROCESS YOUR INFORMATION
In Short: We process your information to provide and improve our Services and communicate with you. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To provide and improve our Services. We may process your information to deliver and enhance the services you request.
- To respond to user inquiries. We may process your information to respond to your inquiries and address any potential issues you might have.
- To send administrative information to you. We may process your information to send you details about our services, changes to our terms and policies, and other similar information.
- To send you marketing and promotional communications. With your consent, we may process the personal information you provide to send you marketing and promotional communications. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS" below.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Send users information about our services.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Service Providers. We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. This includes tally.so for contact forms and ConvertKit for newsletters.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our website is at your own risk. You should only access the website within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS
In Short: We do not knowingly collect data from or market to children under 18 years of age.We do not knowingly solicit data from or market to children under 18 years of age.
By using our website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of our website. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us using the contact form in the website footer.
8. WHAT ARE YOUR PRIVACY RIGHTS
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right to:
- Request access and obtain a copy of your personal information.
- Request rectification or erasure.
- Restrict the processing of your personal information.
- Data portability, if applicable.
- Object to the processing of your personal information in certain circumstances.
You can make such a request by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE" below. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.
If you are located in Switzerland, the contact details for the data protection authorities are available here.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. This will not affect the lawfulness of the processing before its withdrawal.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you to send you service-related messages that are necessary for the administration and use of our website, to respond to service requests, or for other non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at contact@ismscopilot.com.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. As no uniform technology standard for recognizing and implementing DNT signals has been finalized, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
However, we respect your privacy and provide you with the ability to manage your cookie preferences. If you are located in the EU, you will be presented with options to accept or decline different types of cookies when you visit our website. These preferences allow you to control the data collected through cookies.
If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
1. Every individual who is in the State of California for other than a temporary or transitory purpose.
2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect
We have collected the following categories of personal information in the past twelve (12) months, only if you provide it to us with your consent:
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, email address (only if provided with consent) - YES
As indicated by the "NO", the following categories haven't been collected:
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information - NO
C. Protected classification characteristics under California or federal law
Gender and date of birth - NO
D. Commercial information
Transaction information, purchase history, financial details, and payment information - NO
E. Biometric information
Fingerprints and voiceprints - NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements - NO
G. Geolocation data
Device location - NO
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities - NO
I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us - NO
J. Education Information
Student records and directory information - NO
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics - NO
L. Sensitive Personal Information
NO
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at contact@ismscopilot.com, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
ISMS Copilot has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. ISMS Copilot will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
- Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
- Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information;
- The categories of personal information that we collect;
- The purposes for which the collected personal information is used;
- Whether we sell or share personal information to third parties;
- The categories of personal information that we sold, shared, or disclosed for a business purpose;
- The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- The business or commercial purpose for collecting, selling, or sharing personal information; and
- The specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
- Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
- Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at contact@ismscopilot.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
- Consumer: A natural person who is a resident of Virginia acting in an individual or household context. It does not include a natural person acting in a commercial or employment context.
- Personal data: Any information linked or reasonably linkable to an identified or identifiable natural person. It does not include de-identified data or publicly available information.
- Sale of personal data: The exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your Rights Under the Virginia CDPA
- Right to be informed whether or not we are processing your personal data.
- Right to access your personal data.
- Right to correct inaccuracies in your personal data.
- Right to request deletion of your personal data.
- Right to obtain a copy of the personal data you previously shared with us.
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
ISMS Copilot has not sold any personal data to third parties for business or commercial purposes. ISMS Copilot will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise Your Rights
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at contact@ismscopilot.com, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification Process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to Appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at contact@ismscopilot.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
12. DO WE MAKE UPDATES TO THIS NOTICE
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE
If you have questions or comments about this notice, you may email us at contact@ismscopilot.com.
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU
You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at: contact@ismscopilot.com.