Privacy Policy

COSO IT LLC. Privacy Policy

EFFECTIVE 03 Mar 2016

Please read our Privacy Policy with respect to our collection, use and disclosure of personal information we collect from visitors through our website www.cosoit.com (the “Site”), the use of our services (“Services”) and our downloadable software (“Software”). By using the Site, the Services or the Software or submitting information to COSO IT LLC. (“COSO IT”) via a form or using our support services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.

Safe Harbor

COSO IT complies with the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. COSO IT has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit https://www.export.gov/safeharbor/

In compliance with the US-EU and US-Swiss Safe Harbor Principles, COSO IT commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact COSO IT at: legal@cosoit.com

COSO IT has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by COSO IT, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Personal Information You Provide to Us

You can generally visit our Site without revealing any personal information about yourself. We may, however, collect any information you voluntarily choose to enter or submit to us on our Site when you contact us or register to receive whitepapers, the Software or the Services or that you provide to us in the course of requesting or receiving support services from us. The types of personal information collected include full name, title, company, address and telephone number, as well as any additional information you may provide on a form on our Site. The amount and type of personal information that COSO IT collects depends on the nature of your interaction with the Site, Software and Services. For example, if you register for an academic license, we will also ask for the name of your academic institution and the purpose for which you will use the Software and Services. Additionally, if you apply for a job with us through our Site, we will collect any personally identifiable information that you include with your submission and in your resume. As a user of our Software and Services, we may have access to any personally identifiable data that you elect to import into the Software and/or upload to the Services.

How We Use Information

We use your personal information for as the following purposes: responding to your requests for information or requests to use our Services or our Software; providing you with requested information such as whitepapers; improving our Software and Services; customizing the content you see on the Site; and to send you targeted marketing regarding products and/or services which we believe may be of interest to you. We will not use any of your sensitive personal information for a purpose other than its original purpose for which we collected it or the purpose authorized subsequently by you, unless you have provided opt-in consent.

Anonymous Information Collected Automatically

The Site may track the total number of visitors to the Site, the number of visitors to each page of the Site, browser type, IP addresses, external websites linked to and other usage statistics collected and used in aggregate form collected through the Site and we may analyze this data for trends and statistics in the aggregate but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Site, track users’ movement, and gather broad demographic information for aggregate use.

Cookies

Cookies are alphanumeric identifiers that we may transfer to your computer’s hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our site are visited and by how many people. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.

On our Site, we may use session cookies to make it easier for you to navigate the Site by saving your preferences and to improve and track the overall Site experience. For our password protected areas of the Site, we may set a persistent cookie to authenticate your login and authorization to use the password protected areas.

This Site also uses Google Analytics, a web analytics service provided by Google, Inc. ("Google") and third party analytic cookies such as Act-On. Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may find more information about Act-On cookies at the Act-On website. Act-On and Google may track your use of this Site as well as across other third party websites.

If you reject cookies, you may still use our Site, but your ability to use some areas of our Site may be limited. Most major browsers allow you to block or delete certain cookies from your system. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser. You may be able to remove persistent cookies by following directions provided in your Internet browser's "help" file.

Will COSO IT Share Any of the Personal Information it Receives?

COSO IT neither rents nor sells personal information to anyone. We will share your personal information with third parties only in the ways that are described in this privacy policy. We may employ other companies and people to perform tasks on our behalf and need to share your personal information with them to have them assist us in providing our products or services to you. Such third parties must: (i) subscribe to the Safe Harbor Privacy Principles; (ii) be subject to the EU Directive on Data Protection or another adequacy finding; or (iii) COSO IT will enter into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant Safe Harbor Privacy Principles. Unless we give you the choice to opt-out and you do not exercise your opt-out right, COSO IT’s service providers do not have any right to use personal information we share with them beyond what is necessary to assist us or for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by you. You hereby consent to our sharing of personal information for the above purposes. We will not disclose your sensitive personal information to a third party unless you have provided us with affirmative or explicit (opt in) consent.

We may release personal information when we believe in good faith that release is necessary to comply with any law or requests from law enforcement or government; enforce or apply our terms of use and other agreements; or protect the rights, property, or safety of COSO IT, our employees, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. We will not sell your personal information to any company or organization, but we may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which COSO IT participates or to a purchaser or acquirer of all or substantially all of COSO IT’s assets to which this Site relates. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Security

COSO IT takes steps that are reasonably designed to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, including through secure socket layer, password protection and, for certain transmissions to our Services, encryption. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and the Site, and the Site and you, will be free from unauthorized access by third parties. Users of the Site do so at their own risk with respect to such communications.

Children

COSO IT’s Site, Software and Services are not intended for children under the age of 13. The Site, Software and Services are not intended for children under 13 years of age. COSO IT does not knowingly collect personal information from children under 13.

Links to 3rd Party Sites

Our Site includes links to other websites whose privacy practices may differ from those of COSO IT. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Changes to this Privacy Policy

COSO IT may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes in the way we use personal information, we will notify you by posting an amendment to the Privacy Policy on the Site and we will send registered users a notice of the change prior to the change becoming effective. Such modifications will become effective on the day they are posted. As such, COSO IT encourages you to frequently review this Privacy Policy for any modifications.

Email Communications, Opt-Out & Access

If you wish to: (i) remove your personal information from our system in order to stop receiving information from us, (ii) update your personal information, or (iii) have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please send us a detailed message (with sufficient information for us to identify your personal information) at privacy@cosoit.com . We will make every effort to resolve your concerns.

COSO IT allows an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Individuals can request access by emailing COSO IT at privacy@cosoit.com . We will respond to your request within 30 business days.

We will retain your information for as long as your account is active or as needed to provide you our Software and Services and we also may continue to retain backup or archival copies of your information made in the normal course of business. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. COSO IT will take reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

Contact Us

If you have questions or concerns about this Privacy Policy, please contact us through the information below:

COSO IT LLC.
Attn: PRIVACY