Prefinery Privacy Policy

Last revised on April 1, 2019

Your privacy is extremely important to us and we are committed to fair practices that protect your information. This Privacy Policy is provided to explain our information practices and the choices you can make about the way your information is collected and used.

By using the Prefinery website or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

Scope of this Privacy Policy

Please be aware that this Privacy Policy does not govern all the information Prefinery may process. Our commitment to customers and service providers is governed by a separate Data Processing Amendment.

Our commitments to employees are governed by our internal employment policies.

In all instances we are committed to transparency with our customers, employees and protecting your data privacy.

An Overview of the Sources of Personal Data

Prefinery obtains information about individuals in these main ways:

  • when you visit this website or contact us directly about becoming a customer or obtaining other information,
  • when you become a Prefinery customer,
  • when individuals partipate in a customer's product launch (e.g. submit a customer's waiting list signup form),
  • when a customer uses our service to combine its data with the data residing in other applications (e.g. MailChimp),
  • when you are a service provider to Prefinery, and
  • through the Prefinery employment process.

This Privacy Policy governs how we collect and process information obtained from your visits to our website, when you contact us directly (or interact with us via other media outlets and social media) about becoming a customer or to obtain other information, and when you engage with us as part of the employment process.

Our Data Processing Amendment governs our processing of any information obtained as a result of the customer or service provider relationship. You can read our commitment to customers and service providers, and our fair information practices in the Data Processing Amendment.

Some definitions

This Privacy Policy relates to information collected by Compulsivo, Inc. d/b/a Prefinery (referred to in this Privacy Policy as "Prefinery" "we" or "us" or "our") through your use of the Prefinery website, its features, the services we provide (outside of our paid-for services), and information available through the Prefinery website.

"You" or "your" refers to the individual who uses this website, features, and services, or accesses available information, or engages with us directly by email or telephone.

As used in this Privacy Policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization.

Whose information does Prefinery collect?

Prefinery collects information from three types of individuals:

Our customers are individuals and businesses who have signed up for a Prefinery account. If you are a customer, we will handle information we receive from you under the terms of Prefinery's Data Processing Amendment.

End users are individuals that use goods and services provided by Prefinery Customers. If you interact with Prefinery in the course of signing up for the waiting list for a particular product or service, you are probably an end user. We process "End User Data" which means information about end users of Prefinery customers, which includes but is not limited to, the email address, first name, last name and phone number of an end user.

Personnel are the people who work, and apply to work, for Prefinery. Please refer to the Personnel section of this policy to read about the information Prefinery collects from personnel.

What information does Prefinery collect?

Depending on your use of the Prefinery website, or direct interactions with us, we collect two types of information: personal information and non-personal information.

Personal Information

Personal information identifies you or may be used in combination with other pieces of personal information to identify you. Examples of personal information include your name, company name, job title, address, e-mail address, telephone number, and billing and credit card information. Personal information can also include information that does not identify you, but could be combined with other information in a way that enables you to be identified. This includes information such as age, gender, profession, zip code, IP address, and current location.

Non-Personal Information

Non-personal information is information that cannot be used or combined with other information to identify or contact you, including browser types, operating system types, domain names, language preferences, referrer/exit pages and statistical data involving the use of the Prefinery website.

When does Prefinery use end user information from third parties?

Prefinery will collect End User Data necessary to provide the Prefinery services to our customers.

We may use End User Data to look up and store additional Public Data in order to create a more complete customer profile. "Public Data" is defined as information received from a third party partner named FullContact, a GDPR and Privacy Shield Certified company. Public Data may be claimed, edited or discarded from their systems by following this link and is subject to their Privacy Policy.

If you would like to opt-out of our collection of End User Data, you can disable the "Magic Profiles" feature in your Prefinery project settings.

End users may voluntarily provide us with information they have made available on social media websites. If you provide us with any such information, we may collect publicly available information from the social media websites you have indicated. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.

When does Prefinery use customer information from third parties?

We receive some information from the third parties when you contact us. We also occasionally collect information that is made publicly available on social media websites. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.

Where and when is information collected from customers and end users?

Prefinery will collect personal information that you submit to us. We may also receive personal information about you from third parties as described above.

Registering to Use the Prefinery Service and in the Course of Using the Prefinery services.

Customers will be required to establish an account in order to take advantage of certain features of the Prefinery website. If you wish to establish an account you will be required to provide us with information (including personal information and non-personal information). In addition, we may obtain your personal information from you if you identify yourself to us by sending us an e-mail with questions or comments.

Cookies and Web Beacons

For more information about cookies and "Web Beacons," including a full list of the cookies we use, what they do, and how to disable the non-necessary ones, please refer to our full Cookie Policy.

Log Files

We collect information through our Internet log files, which record data such as browser types, domain names, IP address, and other anonymous statistical data involving the use of the Prefinery services. This information may be used to analyze trends, to administer the Prefinery services, to monitor the use of the Prefinery services, and to gather general demographic information. We may link this information to personal information for these and other purposes such as personalizing your experience on the Prefinery services and evaluating the Prefinery services in general.

Personnel

If you are a Prefinery worker or applicant, we collect information you voluntarily provide to us. We use the information collected for Human Resources purposes in order to administer benefits to workers and screen applicants.

You may contact us in order to (1) update or correct your information, (2) change your preferences with respect to communications and other information you receive from us, or (3) receive a record of the information we have relating to you. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.

Does Prefinery collect information from children under 16 years of age?

We are committed to protecting the privacy of children. The Prefinery Service is not designed for or directed to children under the age of 16. We do not collect personal information from any person we actually know is under the age of 16.

What does Prefinery do with the information it collects from customers?

In general, we use the information collected to provide you with a great overall experience interacting with us and when using the Prefinery website and to help us understand who uses our offerings, for internal operations such as operating and improving the Prefinery website and our services, to contact you for customer service and billing purposes and to facilitate the delivery of Prefinery advertising in some cases, including using your email to send information to you about our services.

We use your information to send you a welcome e-mail after you create an account, when you are invited to Prefinery, or when you sign up for a demo, webinar or to receive our newsletter. We also use your information to send other e-mail communication related to the Prefinery website. We always give you the option to unsubscribe in any email we send you.

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personal information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. We also use the information collected to send announcements and updates regarding changes to our Terms of Service, Privacy Policy or when making pricing changes. You will not be able to unsubscribe from these announcements and updates as they contain important information relevant to your use of the Prefinery website and our services.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Prefinery services. We may link some of this information to personal information for internal purposes or to improve your experience with the Prefinery website and our services, in these cases we will obtain your consent.

What does Prefinery do with the information it collects from end users?

We use End User Data to identify you and to provide product launch and waiting list services to our customers. We will disclose End User Data to the relevant Prefinery customer so that you may partipate in their product launch. If you are interested in how we process the data on behalf of Prefinery customers, please read our Data Processing Amendment.

Third Parties Generally

Third parties may be able to independently directly collect personal and non-personal information without permission from Prefinery, and may include potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers and other similar parties.

Third-Party Processors and Outside Contractors

We may employ vendors, suppliers and independent contractors (collectively, "Sub-processors") to provide specific services and products related to the Prefinery website and our services, such as hosting, credit card processing and fraud screening, customer support, email delivery and mailing list hosting. In the course of providing products or services to us, these Sub-processors may have access to information collected through the Prefinery website or services, including your personal information. We require that these Sub-processors agree to (1) protect the privacy of your personal information consistent with this Privacy Policy, or the Data Protection Amendment and (2) not use or disclose your personal information for any purpose other than providing us with the products or services for which we contracted or as required by law. A current list of the Prefinery Sub-processors can be found here.

Laws and Legal Rights

We may disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personal information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Prefinery Terms of Service, to detect fraud, or to protect the safety and/or security of our users, the Prefinery website, or the general public. Prefinery is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

We also may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

In cases of onward transfer to third parties of data of European Union or United Kingdom or Swiss individuals received pursuant to the EU-U.S. or Swiss-U.S. Privacy Shield, Prefinery is potentially liable.

Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Prefinery or any of its Corporate Affiliates (as defined herein), or that portion of Prefinery or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.

Affiliates

We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Prefinery, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Does this Privacy Policy apply when I link to other websites or services?

The Prefinery website or our services may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than those provided by Prefinery. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us.

When does Prefinery disclose information to other third parties?

Except as set forth in this Privacy Policy, the Cookie Policy or the Prefinery Data Processing Amendment or as specifically authorized by a Prefinery customer, we will not disclose any information to third parties.

Is the information collected through the Prefinery Service secure?

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

For more information about how Prefinery stores and secures customer and company data, please see our Security Policy.

Could my information be transferred to other countries?

Prefinery is incorporated in the U.S. and information collected via our website, through direct interactions with you, or from use of our services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.

Is Prefinery Privacy Shield compliant?

Prefinery complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework ("Privacy Shield") as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and the United Kingdom and Switzerland to the United States in reliance on Privacy Shield. Prefinery has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Prefinery commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or United Kingdom or Swiss individuals with inquiries or complaints regarding this privacy policy should first .

Prefinery has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

What choices do I have regarding the collection, disclosure and distribution of personal information?

Except as otherwise described in this Privacy Policy or in the Data Processing Amendment, as applicable, we will only use personal information for the purposes described above or as otherwise disclosed at the time we request such information from you. You must "opt in" and give us permission to use your personal information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by clicking the unsubscribe link included on the bottom of all such communications, or by .

Do Not Track

The term "Do Not Track" refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.

Can I update or correct my information?

The rights you have to request updates or corrections to the information Prefinery collects depend on your relationship with Prefinery. Personnel may update or correct their information as detailed in our internal company employment policies.

Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization of which you are a customer.

How will I know if there are any changes to this Privacy Policy?

We may revise this Privacy Policy from time to time without notice. Having said that, we will not make changes that result in significant additional uses or disclosures of your personal information without notifying you of such changes via e-mail. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal information, for which an e-mail is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Prefinery website and any services we provide. Your continued use of our services and the Prefinery website following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.

Whom do I contact if I have any privacy questions?

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact our Privacy Agent in any of the following ways:

  • By postal mail or courier:
    Compulsivo, Inc.
    1108 Lavaca St Ste 110-318
    Austin, TX 78701

Applicable Law

This Privacy Policy is governed by the laws of Texas, USA without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy except for those individuals who may have rights to make claims under the EU-U.S. Privacy Shield framework or the Swiss-U.S. Privacy Shield framework.