Privacy Policy

Introduction

Schellman Compliance, LLC and its subsidiaries, divisions, affiliates, and related entities ("we," "us," or "Schellman") recognize the importance of protecting the privacy of your personal information and want you to be familiar with how we collect, use and disclose the information you provide by engaging our services on the website, mobile website, social media site, software, email exchanges, mobile apps, and other online services on which this Privacy Notice (the “Notice”) is posted, including but not limited to any services, features, pages, and functions contained or offered therein, and any transactions, orders, sales, purchases, or acquisitions of goods, products, or services (collectively, the “Service”).

Your use of the Service is conditioned on your agreement with this Privacy Notice and our AuditSource Terms of Use and our Open API Terms of Use, as applicable.  Please read this Notice and our Terms of Use carefully before using our Service or making any transaction, order, or purchase, as they contain important information on who we are and how and why we collect, store, use, and share your personal information. This Notice also explains your rights in relation to your personal information and how to contact us or relevant data protection authorities in the event you have a complaint.

By making any transaction, order, or purchase or by visiting or otherwise using the Service in any manner, you acknowledge and accept without limitation or qualification, that you have read and understood the Notice and Terms of Use and you agree to be bound by them. 

This Notice is written in the English language. We do not guarantee the accuracy of any translated versions of this Notice. To the extent any translated versions of this Notice conflict with the English language version, the English language version of this Notice shall control.  

If you have any questions or comments about the Notice or our privacy practices, please contact us by email at privacy@schellman.com.

Collection of Personal Information

Information you provide to use 
Schellman will collect personal information from you directly when you interact with our Service, contact us for any reason, use our services, create an account, subscribe to any service including our blog, share reviews, sign up to receive offers or emails from us, join our mailing list, submit resumes or work history, or retain our services.

Information we obtain indirectly
We may receive personal information about you from information provided to us by our customers, as well as third-party affiliates or partners and from marketing companies that provide us with such information as a part of their relationship with us.

We may combine this with information that we already have collected about you. Such collected information could include contact details (such as email address) and previous purchase history or interests.

Information we obtain automatically 
When you use our Service, we collect certain information about you automatically through our use of cookies (more information about our use of cookies follows later in this Notice) and similar technologies such as standard internet log information and usage information, including your IP address, browser type and language, access times, location, usage data, and referring website addresses. 

Categories of Personal Information Collected and Purpose for Collection

We collect the following categories of personal information: (1) contact information including your name, email address, street address, city, state, zip code; (2) authentication information, including the username and password that you use to register an account; (3) comments, reviews, suggestions; (4) personal preferences including service preferences, online preferences, and interests; (5) online behavior information including online activity, preferences, and time spent viewing features; and (6) IP address or mobile network information.

Schellman takes commercially reasonable measures to ensure we only collect and process the minimum amount of personal information from you that is necessary to conduct our business, provide you with web-based and mobile applications, communicate with you, provide customer support, verify user identities, provide you with information on our services and content, maintain and improve our website, and comply with legal requirements.

Unless otherwise required by law, the personal information we collect will only be retained for so long as the information is needed to fulfill these purposes, to comply with your requests with respect to the Service, or until you ask for your personal information to be deleted.  

Use and Disclosure of Personal Information

Schellman may store and use your personally identifiable information for the following purposes:

• Product or service fulfillment;
• Marketing, promotional, and advertising purposes, such as to inform you of products or services available from us;
• Internal operations, such as improving your customer experience – this includes auditing current interactions and optimizing user experience;
• Detecting security incidents, protecting against malicious, deceptive activity, and taking all necessary and appropriate steps to mitigate current and future risk;
• Debugging and repairing internal information technology as necessary;
• Undertaking internal research for technological development and demonstration; and
• To share with trusted third-party service providers to help us perform activities to improve your customer experience with your consent.

Schellman does not trade, rent, or sell your personal information to third parties, share your personal information with third parties for cross-context behavioral advertising, or process it for targeted advertising or consumer profiling.

We may share or disclose your personal information for the following limited purposes:

• With third party service providers who perform services and functions on our behalf to support our interactions with you. These service providers may assist with technical operation of and administrative and maintenance purposes related to our Service, provide analytics, process orders, transactions and payments, provide customer service, and deliver gifts and other items to you as a gesture of goodwill and appreciation. We may also share non-identifying information, such as aggregate statistics or usage information, with third parties to demonstrate how Schellman is used, spot industry trends, or provide marketing materials for Schellman. Any aggregated information shared in this way will not contain any personally identifiable information, and Schellman is not limited in its use of aggregate information that does not permit direct association with any specific individual, such as the number of users of our services and the geographic distribution of our users. Third parties with access to your personal information are prohibited from using your personally identifiable information beyond what is necessary to assist or provide services to us, and they are required to maintain the information’s confidentiality and adhere to privacy, security, and legal obligations in a way that is consistent with this Notice and any applicable law.
• As required by applicable law, statute, rule, regulation or professional standard, or through subpoena, search warrant or other legal process. Schellman cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Accordingly, we may disclose any information about you to government or law enforcement officials or private parties as Schellman, in its sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Schellman, a user of the Service, or a third party, to protect the safety of the public or any person, to take emergency action, or to prevent or stop activity Schellman considers to be or to have the potential to be, illegal, unethical, or legally actionable. In addition, Schellman may disclose information about you to counter or prevent any malicious access or use of the Service or to prevent harm or loss to any user of the Service.
  For regulatory compliance purposes, to the extent permitted or required by applicable law.
• When explicitly requested or consented to by you (e.g., to deliver publications or reference materials that you request). If you agree to have your personal information shared with a third party, your personal information will be disclosed to the third party and will be subject to the privacy notice and business practices of that third party. To the extent that we obtain your consent to process your personal information, you may withdraw this consent at any time by emailing us at: privacy@schellman.com.
• In the event we sell our business or control of our business changes. Schellman may provide your personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Schellman’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information maintained by the Service is among the assets transferred. In such a case, unless prohibited by applicable law, your information would remain subject to the privacy notice applicable at the time of such transfer, unless you discontinue use of our Service.

Children’s Privacy: No Users Under Eighteen Years of Age

Schellman’s Services are not targeted for use by children. Schellman will never knowingly request or collect personal information from any child. If you are under eighteen years old, please do not provide your information through our Service. Upon notification that a child has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records. If you believe we might have any information from a child, please contact us at privacy@schellman.com.

In addition, if you are a California resident under the age of eighteen, while we do not allow users under the age of eighteen and you should notify us so we may delete your information, specifically, you may request us to remove content or information posted on our websites or stored on our servers by (a) submitting a request in writing to privacy@schellman.com, and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to erase or otherwise eliminate content or information if (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that the minor cannot be individually identified; (iv) the minor does not follow the instructions posted herein on how to request removal of such content or information; or (v) the minor has received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.

Security

The security and confidentiality of your personal information is important to us. If you choose to provide us with your personal information, you understand that we are transferring it to Schellman’s locations and systems in the United States or to the locations and systems of Schellman’s service providers around the world. We follow reasonable commercial standards for organizational, technical, and administrative measures to protect the personal information submitted to us, both during transmission and once it is received, to prevent the loss, misuse, and alteration of the information under its control.  

Please be advised, however, that while we take reasonable security measures to protect your personal information, such measures cannot be guaranteed to be secure. 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 personal information. Thus, Schellman disclaims liability for loss, misuse, and alteration of your information under its control to the maximum extent permitted under law, and by using the Service, you agree to assume any security risk related to personal information.

The security of your account relies on your protection of your user profile information. You are responsible for maintaining the security of your user profile information, including your password and for all activities that occur under your account. You may not share your password with anyone.  

We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information to login to your account. Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us immediately. If you believe someone else has obtained access to your password, please change it immediately.

If you believe any personal information you have submitted to us is unsecure or that someone has accessed your account, or become aware of any other security violations, please notify us immediately at privacy@schellman.com.

Do Not Track Signals, Cookies, and Other Technologies

Currently, we do not respond to “Do Not Track,” “DNT,” or similar signals.

We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity and interactions with our Service which allows us to keep track of analytics and certain statistical information that enables us to improve our services and provide you with more relevant content and advertising.

Some of the cookies we use are necessary to enable you to move around the Service and use its features.  We also use functional cookies to record information about the choices you have made and to allow us to tailor the Service to our users; for example, to remember your language or region or that you have already completed a survey. This information is usually anonymized and is not used for any other purpose.  We may also use analytic services to help us understand how effective our content is, what interests our users have, and to improve how the Service works. In addition, we use web beacons or tracking pixels to count visitor numbers and performance cookies to track how many individual users access the Service and how often. This information is used for statistical purposes only and it is not our intention to use such information to personally identify any user.

Most web browsers are set to accept cookies by default but will allow you to see what cookies you have, delete them on an individual basis, or block cookies from particular or all websites (“opting out”).  Please note that if you choose to remove, reject, or opt-out from cookies, this could affect the availability and functionality of the Service.

Linked Sites

The Service may link to third party owned or operated websites including, but not limited to social media websites (each a "Linked Site"), as a convenient method of accessing information that may be useful or of interest to you.  This Privacy Notice and the practices we follow do not apply to these Linked Sites. 

When you click on a link to a Linked Site, you will leave our Service and go to that Linked Site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these Linked Sites or their content. The terms of this Notice do not apply to these Linked Sites or their content, or to any collection of your personal information by third parties through the Linked Sites, and Schellman is not responsible for the privacy practices or the content of such Linked Sites. Schellman expressly disclaims any liability that may arise from your use or provision of any of your information whatsoever to Linked Sites. You understand and agree that by clicking on a link to a Linked Site that you have left our Service.  

User Contributions

Some features of the Service may now or in the future allow you to provide content, such as written comments or reviews or interactive responses, to be published or displayed on public areas of the Service (“User Contributions”). Be careful about giving out information in public areas of the Service. The information you share in public areas may be viewed by any user of the Service. We cannot control the actions of other users of the Service with whom you may choose to share your User Contributions.

Unsubscribe

If you no longer wish to receive emails from us, you may opt-out of receiving such emails by following the unsubscribe instructions contained in any such email or by contacting us at privacy@schellman.com with the subject “unsubscribe.” 

Consent to Processing and International Transfer

The Service is controlled and operated by us from the United States. Schellman may process, transfer, and store your information on servers located in a number of countries, including the United States. As a result, your personal information may be subject to data protection and other laws that may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate. By using the Service, or by providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside or are a citizen.

Changes to Our Privacy Notice

We reserve the right to change or modify this Privacy Notice or our Service at any time by publishing an updated version here, and any changes are effective upon being posted unless we advise otherwise. If we make any material changes to this Notice, we will notify you by posting an announcement on the website or sending you an email. 

We encourage you to frequently review this website for the latest information on our privacy practices. Use of information we collect now is subject to the Privacy Notice in effect at the time such information is used. You are bound by any changes to our Privacy Notice once you use the Service after such changes have been posted. Please review the “Last Updated” legend at the top of this page to see when this Privacy Notice was last revised. If you do not accept the terms of our Privacy Notice, we ask that you do not register with us and that you do not use our Service. Please exit the Schellman Service immediately if you do not agree to the terms of this Privacy Notice.