Privacy Policy

EasyComp,Inc.

PrivacyStatement

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Effective: February,2025

Welcome to our website. This Privacy Statement describes the types of information that EasyComp, Inc. or its subsidiaries or affiliates ("EasyComp," “we” or “us”) collects from and about our customers and their corporate representatives (our “Customers”) on our website, www.easycomp.ai or and (collectively, the “Site”). Our Site and the services we provide are aimed at companies and their representatives and not at individual consumers or households.

Your privacy is important to us. This Privacy Statement is for informational purposes and sets forth our policy with respect to the collection, use and disclosure of business information that we collect when engaging with prospective and existing Customers and their representatives (the “Customer Representatives” and from Customers' employees or others who are authorized to use the EasyComp products and services (the “Authorized Users”) when we provide our services. By using the Site, or engaging us to provide our services, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement.

EasyComp provides a sales commission management application (the "Platform") for its customers, though which they can create incentive plans and process their own employee and corporate customer databases information to calculate sales incentives and provide management of their sales teams.

EasyComp collects identifiable information from and about Customer Representatives, including those who have access to EasyComp's products or services on behalf of one of our Customers ("Authorized Users"), Customer employees whose information is shared with EasyComp by our Customer, as well as information about our Customers' corporate customers and their transactions or interactions with our Customers, as detailed in our Customer's databases (the “Customer Data”). When EasyComp collects and uses Customer Data on behalf of its Customers in order to provide our services, EasyComp is generally a processor, or “service provider” and not a controller, of that Customer Data.

EasyComp does not receive consumer household information from its Customers, nor does it sell or share Customer Representative information with third parties (excluding subprocessors).

By accessing or using the Site, you consent to the information collection, disclosure and use practices described in this Privacy Statement. Certain features or services referenced in this Privacy Statement may not be offered on the Site at all times. Please also review our Terms of Service, which governs your use of the Site, and which is accessible at https://www.easycomp.ai.

Your Privacy Rights

If you are a Customer Representative, Authorized User or corporate customer and would like to exercise your rights or opt-out of EasyComp processing your information which may include sharing your information with our subprocessors, on behalf of a Customer because your employer has a contractual relationship with us, please contact your employer directly in order to exercise your privacy rights.

EasyComp has no responsibility or liability to Customer employees or Customer Representatives, including Authorized Users, in connection employment or other decisions our Customers make through the use of our products or services. EasyComp also has no responsibility or liability to its Customer's corporate customers and relies on consents procured from its Customers' for access to this information, and only uses this information in accordance with our Customers' written instructions.

Information Collection

If you access our services through your employer, the use of your information by EasyComp is subject to our agreement with them.

We collect personal information about Customer Representatives in a range of forms, including personal business information, when they choose to provide it to us. Personal information (or personal data) means information about an individual from which that person can be identified. It does not include personal information where the identity has been removed (anonymous personal information). This may include when Customer Representatives contact us with inquiries or otherwise contact us.

We collect business contact information from Customer Representatives or other Customer employees including name, address, email address, telephone number, mobile telephone number or geolocation information or any other information they provide while using our Services on behalf of a Customer, such as login or password. We may also receive information from our Customers in connection with compensation, bonus or other employee incentive plans that may include performance or other information.

We may only be able to change how we share personal information of Customer Representatives in accordance with our agreement with our Customers or our Customer’s instructions. The Customer decides how the information you provide is collected and used, including what is shared with us for our use. Your use of the Site is subject to our privacy statement and terms of use, as well as the contract with our Customer. If you have questions about the collection and use of your information, please contact the Customer, who may be your employer.

If Customers make purchases through the Site, they may provide certain payment information, such as payment card or other financial account information, and billing address. A third-party payment processor collects and processes that information directly from our Customers in order to process payments on our behalf; we do not collect or retain your payment information.

Authorized User Notice

If you have access to EasyComp's products or services on behalf of one of our Customers, you are considered an “Authorized User” under our Customer’s contract with us. We collect Authorized Users’ personal information on behalf of our Customers and our Customers decides how the information is collected and used, including what is shared with us for our use. Your device activities are subject to our privacy statement and terms of use, as well as the contract with our Customer. If you have questions about the collection and use of your information on a Site as part of services we provide to a Customer, please contact the Customer, who may be your employer.

On behalf of our Customers, we collect information from and about Authorized Users including , including your first name, last name, email address, user name, device identifiers (including employee name), internet activity information such as website URLs and domains, IP addresses and other metadata from websites, characteristics of websites and browsing activity, and general geographic location or any other information required to collect while using the services that we provide to a Customer. We may only be able to change how we share personal information of Customer Representatives in accordance with our agreement with our Customers or our Customer’s instructions. We expect our Customers to notify Authorized Users about the types of information we collect on our Customers' behalf.

This Site is not intended to collect personal health information or other sensitive information about Customer Representatives or Authorized Users. Any such information should remain with the Customer and should be shared and used only in accordance with our contracts with our Customers and the Customer’s privacy and other policies and procedures.

If a Customer Representative provides us with the name of their company, we may use the name of the company (but not other information) on a list of current or former customers for promotional purposes.

If you use a third party service to link to us or communicate with us (such as a social network or third party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services.

Information Collected From Other Sources

We may obtain information about prospective customers and Customer Representatives from other sources, including from websites and social networks that individuals use to connect with our Customers. This information may include purchase or browsing history, anonymous identifier, demographic information, interests, and publicly-observed data, such as from social media and online activity that we may review or analyze for our internal customer acquisition or support purposes or in order to provide a service to our Customers.

Information Obtained from Third Parties

If we receive Customer Data about you from or on behalf of our Customers, we will only use that information for the specific reason for which it was provided to us.

Information Use

In addition to providing services to our Customers, we may use the information we collect from and about Customer Representatives on our Site to:

● Assess the needs of your business to determine suitable products;

● Send you requested product or service information;

● Respond to customer service requests;

● Send you a newsletter and marketing communications;

● Respond to your questions and concerns;

● Improve the content and functionality of our Web site and marketing efforts;

● Conduct research and analysis;

● Display content based upon your interests;

● Comply with applicable laws, including to respond to requests from public and government authorities;

● Enforce this Privacy Statement;

● Protect our rights, privacy, safety or property, and/or that of you or others.

● Develop new programs, products or services

● Protect the security or integrity of the Services and our business; and

● As described to you at the point of data collection or in our Agreement with our Customer.

EasyComp may use such aggregated, deidentified, or anonymized data for its own research and development purposes, to improve its products and services and for machine learning purposes to train its AI models and algorithms.

Information Sharing

We may share Customer Representative information as further described below. We may also share certain Customer Data that we receive from our Customers with our Service Providers or subprocessors, in order to provide our services to our Customers.

We may contract with third parties to perform functions related to the Site and services we provide to our Customers. These third parties will have access to only that Customer Representative information and Customer Data needed to perform their business functions, but may not use or share that information for other purposes. These companies are authorized to use your personal information only as necessary to provide these services to us and/or to support the services we provide to our Customers.

We may share the information we collect from and about Customer Representatives:

(1) with third parties that we believe may provide promotional materials, and goods and services that may be of interest to you;

(2) with our Service Providers, if the disclosure will enable them to perform a business, professional or technical support function for us, including as part of our agreement with our Customers. If we use a service provider that uses artificial intelligence or machine learning (the "AI Tools") to support our Services, the AI Tools and services will not use your identifiable information to train its model or platform;

(3) as necessary if we believe that there has been a violation of this Privacy Statement, our Terms of Use, of our rights, or the rights of any third party;

(4) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

(5) to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law; and

(6) as described to you at the point of collection or in our Agreement with a Customer.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Information We Automatically Collect and cookie policy

As is true of most web sites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system. For information about what we collect from Device Users, please see "Device User Information" above.

We and our third party service providers, including advertisers, analytics, and third party content providers, such as Google Analytics, may automatically collect certain information from you as a Site visitor or Customer Representative whenever you access or interact with the Site. This information may include, among other information:

• the browser and operating system you are using

• the URL or advertisement that referred you to the Site

• the search terms you entered into a search engine that led you to the Site

• areas within the Site that you visited, and

• other information commonly shared when browsers communicate with websites.

When service providers receive this information, they are not permitted to use the information collected on our behalf except to help use conduct and improve our business.

We may use cookies, web beacons, pixel tags, log files, or other technologies to automatically collect certain information when you use our Site or interact with our emails and online or mobile advertisements.

For example, we may automatically collect certain non-personal information from you such as your mobile device identifier or MAC address, browser type, operating system, device model, software version, Internet Protocol (“IP”) address, mobile or ISP carrier information, and the domain name from which you accessed the Site. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Site. If such information is linked to your Personal Information, we will treat it as Personal Information under this Privacy Statement.

We also may collect information about your use of the Site including the date and time you access the Site, the areas or pages of the Site that you visit, the amount of time you spend using the Site, the number of times you return, whether you open forward or click-through emails and ads, and other usage data so that we can understand the statistical use trends of our Site in order to make improvements. This information may be stored and used with your personal information attached to it. For more information on our use of cookies, click [link to cookie policy].

We may also use third-party tools or services, such as Google Analytics, to assist us with analyzing and improving the Site. These service providers are not permitted to use the information collected on our behalf except to help use conduct and improve our business.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.

Tracking Options, EEA/UK/Switzerland and California Do Not Track Disclosures.

We strive to provide you with choices regarding the personal information you provide to us.

You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. To learn more about the use of cookies or other technologies to deliver more relevant advertising and your choices about not having this information used by certain Service Providers (defined below), please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site, as well as information collected offline or from third party sources to help us tailor our communications to you and to improve our services.

We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about Customer Representatives and Customer Data may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Site in a manner that is consistent with this Privacy Statement.

Your California Privacy Rights

Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: privacy@easycomp.ai You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your e-mail address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Legal Requirements

We may disclose Customer Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

Children

Protecting children’s privacy is important to us. We do not direct the Site to, nor do we knowingly collect any personal information from, children under the age of 16.

Links to Other Web Sites

This Privacy Statement applies only to the Site. The Site may contain links to third-party sites or applications, including social media sites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites or applications. The links to third-party sites from the Site does not imply that we endorse or have reviewed the third-party sites.

Data Security

The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about You. While we make every effort to help ensure the integrity and security of our network and systems, the transmission of information via the internet is not completely secure. E-mail sent to or from the Site may not be secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Data Storage and Retention

Your personal information is stored on our Service Providers’ servers in the United States. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement even if you are from an area outside the United States. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with use of the Site, or to fulfill any legal or contractual obligations we may have.

Access to Your Personal Information

You may also send us an email at privacy@easycomp.ai to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if we believe doing so would violate any law or legal or audit requirement or cause the information to be incorrect.

Changes to Our Privacy Statement

We reserve the right to revise this Privacy Statement at any time. When we do, we will post the changes on the Site. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. Your continued use of the Site after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

Please also feel free to contact us at privacy@easycomp.ai if you have any questions about our Privacy Statement or the information practices of the Site.

Visitors from the EEA,UK or Switzerland

If you are a resident of the EEA ,UK or Switzerland we are a data controller when we collect Customer Representative information and a data processor when we receive Customer Data in order to perform services for our Customers who are the data controllers.

Our legal basis for collecting and using your personal data or information is to do so with your consent, as provided to us by our Customers; in performance of a contract with our Customers or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. You may contact our Customers at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights to:

● Access your personal data or information;

● Delete, or request deletion of, your personal data or information;

● Object to or restrict processing of your personal information;

● Request portability of your personal information;

● Complain to your local data protection authority at any time;

● Object to automated decision making; and

● Update your personal data or information.

Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights. If we are the data controller, you can contact us to exercise these rights. If we are the data processor, you must contact the controller to exercise these rights:

● Access your personal data or information;

● Delete, or request deletion of, your personal data or information;

● Object to or restrict processing of your personal information;

● Request portability of your personal information;

● Complain to your local data protection authority at any time;

● Object to automated decision making; and

● Update your personal data or information.

To withdraw consent or exercise these rights, please contact our Privacy Officer at privacy@easycomp.ai.

If we ask you to provide personal data to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your personal data is required and if not, the consequences of not sharing your personal data with us.

Similarly, if we collect and use your personal information in reliance on our or a third party's legitimate interests and those interests are not already listed above (see "Information Use" section), we will let you know what those legitimate interests are.

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