Effective date: January 1st, 2025

This Privacy Policy describes how Compli-Wise LLC (“OSHAWISE”) collects, uses and discloses information, and what choices you have with respect to the information.

‍1) Scope of this Privacy Policy

This Privacy Policy applies to OSHAWISE’s products and services, including applicable mobile and desktop applications (collectively, the “Services”), OSHAWISE.com and other OSHAWISE websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with OSHAWISE. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of OSHAWISE’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the OSHAWISE platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “MSA”), including the processing of any data submitted through the Services (“Service Data”). The organization (e.g., your employer or another entity or person) that agreed to the MSA (“Customer”) controls its instance of the Services and any associated Service Data (the “Customer Instance”).

‍2)‍ Information OSHAWISE Collects and Receives

OSHAWISE may collect, generate, and receive Service Data and other information and data (“Other Information”; Service Data and Other Information collectively “Information”)) in a variety of ways:

• Service data. Customers and individuals granted access to a Customer Instance by a Customer (“Authorized Users”) may submit Service Data to OSHAWISE when using the Services.

• Usage information.

• Account information. To create or update a OSHAWISE account, you or a Customer (e.g., your employer) supply OSHAWISE with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide OSHAWISE (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
• Usage information.
• Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users interact with the Services. For example, OSHAWISE logs what Third Party Services are connected with the Services (if any).
• Log data. As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
• Device information. OSHAWISE collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether OSHAWISE collects some or all of this information often depends on the type of device used and its settings.
• Location information. OSHAWISE receives information from you, your Customer and other third parties that may help OSHAWISE approximate your location. OSHAWISE may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. OSHAWISE may also collect location information from devices in accordance with the consent process provided by your device.
• Cookie information. OSHAWISE uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. 

• Third-Party Services. A Customer can connect Third-Party Services to its Customer Instance. Typically, Third-Party Services are software services that integrate with OSHAWISE Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Customer Instance. OSHAWISE may also develop and offer OSHAWISE applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with OSHAWISE. For example, if a single sign-on service is connected with OSHAWISE, OSHAWISE may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to OSHAWISE to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to OSHAWISE. When a Third-Party Service is enabled, OSHAWISE is authorized to connect and access Other Information made available to OSHAWISE in accordance with any permission(s) granted by Customer (including, by its Authorized User(s)). OSHAWISE does not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.

• Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.

• Third-party data. OSHAWISE may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners, or others that OSHAWISE engages with to make OSHAWISE’s own information better or more useful. This data may be combined with Other Information OSHAWISE collects and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

• Additional information provided to OSHAWISE. OSHAWISE receives Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in an educational program hosted by OSHAWISE or a vendor, request support, interact with our social media accounts or otherwise communicate with OSHAWISE.
• Information transferred via the Google API. OSHAWISE’s use and transfer of information received from Google API’s to any other app will adhere to Google API Services User Data Policy, including Limited Use requirements.
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3) How OSHAWISE Uses Information

Service Data will be used by OSHAWISE in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law. OSHAWISE is a processor of Service Data and Customer is the controller.

In addition, OSHAWISE uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, OSHAWISE uses Information:

• To provide, update, maintain and protect our Services, Websites, and business. This includes use of Service Data and Other Information to support delivery of the Services under an MSA, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.

• As required by applicable law, legal process, or regulation.
• To communicate with you by responding to your requests, comments, and questions. If you contact us, OSHAWISE may use Information to respond.

• To develop and provide additional features. OSHAWISE tries to make the Services as useful as possible for Customers and Authorized Users, and OSHAWISE may use aggregated and anonymized Services Data and Other Information to develop new Services or improve existing Services.

• To send emails and other communications. OSHAWISE may send you service, technical and other administrative emails, messages, and other types of communications. OSHAWISE may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, OSHAWISE sometimes sends emails about new product features, promotional communications, or other news about OSHAWISE. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from OSHAWISE please reach out through the contact mechanisms described below.

• For billing, account management, and other administrative matters. OSHAWISE may need to contact you for invoicing, account management, and similar reasons and OSHAWISE uses account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, OSHAWISE may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

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‍4) Data Retention

OSHAWISE will retain Service Data in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law.

OSHAWISE may retain Other Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Other Information for the period of time needed for OSHAWISE to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

• We retain customer data and credentials up to 365 days following account termination unless deletion is requested earlier.
• We retain applicant data for up to three (3) years unless deletion is requested earlier.
• We retain website visitor information in accordance with retention periods stated in the Cookie Policy.

 5) How OSHAWISE Shares and Discloses Information

This section describes how OSHAWISE may share and disclose Information.  OSHAWISE does not intend to collect personal information of individual consumers, and does not sell or share personal information of individuals with other businesses or organizations. The extent to which OSHAWISE collects or processes personal information is limited to business contact information for a limited number of employees of the Customers. This business contact information is necessary for OSHAWISE to perform the services requested by the Customers. Other, case-by-case instances where OSHAWISE might share business contact information of Customers’ designated employees are described below. ‍

• Displaying and operating the Services. Because of the nature and functionality of the Services, Information will be displayed as part of the Services to Authorized Users in a Customer Instance. For example, information about which of Customer’s employees have accepted an invite to use the Services may be displayed as part of the Services.
• Third-party service providers and partners. OSHAWISE may engage third parties as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services. To the extent necessary and applicable, these third-party service providers and partners will be bound by appropriate and commercially reasonable confidentiality obligations. 
• Third-Party Services. Customer may enable or permit Authorized Users to enable Third- Party Services. OSHAWISE requires each Third-Party Service to disclose all permissions for information access in the Services, but OSHAWISE does not guarantee that they do so. When enabled and as requested by Customer, OSHAWISE may share Information with Third-Party Services. Third-Party Services are not owned or controlled by OSHAWISE and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the service provider for any questions.
• Corporate affiliates. OSHAWISE may share Information with its corporate affiliates, parents, and/or subsidiaries.
• During a change to OSHAWISE’s business. If OSHAWISE engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of OSHAWISE’s assets or stock, financing, public offering of securities, acquisition of all or a portion of OSHAWISE’s business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to appropriate and commercially reasonable confidentiality arrangements.
• Aggregated or de-identified data. OSHAWISE may disclose or use aggregated or de-identified Information for any purpose. For example, OSHAWISE may share aggregated or de-identified Information with prospects or partners for business or research purposes.
• To Comply with Laws. If a law enforcement or government agency sends OSHAWISE a demand for Information about a Customer, OSHAWISE shall attempt to redirect the agency to request that data directly from the Customer. As part of this effort, OSHAWISE may provide the Customer’s basic contact information to the law enforcement or government agency. If compelled to disclose Information to a law enforcement or government agency, then OSHAWISE will give the Customer reasonable notice of the demand and cooperation to allow the Customer to seek a protective order or other appropriate remedy unless OSHAWISE is legally prohibited from doing so. OSHAWISE will not voluntarily disclose Information related to a Customer to any law enforcement or government agency, unless required by public authorities, including to meet national security or law enforcement requirements.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of OSHAWISE or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With consent. OSHAWISE may share Information with third parties when OSHAWISE has consent to do so.

‍6) Security

OSHAWISE takes the security of its services and the data associated with those services very seriously. OSHAWISE uses industry-standard technical and organizational measures to protect Information from loss, misuse, and unauthorized access or disclosure. All Information is encrypted at rest and in transit. While no security measures can guarantee perfect security, these steps take into account the sensitivity of the Information OSHAWISE collects, processes, and stores, and the current state of technology. Given the nature of communications and information processing technology, OSHAWISE cannot guarantee that Information in our care will be absolutely safe from intrusion by others during transmission through the Internet or while stored on our systems or otherwise. When you click a link to a third-party site, you will be leaving our site and OSHAWISE doesn’t control or endorse what is on third-party sites.

‍7) Age Limitations

To the extent prohibited by applicable law, OSHAWISE does not expect, intend or market the use of its Services and Websites to be accessed by anyone younger than 18 years old. If OSHAWISE learns that anyone younger than 18 has unlawfully provided Personal Data, OSHAWISE will take steps to delete such information.

‍8) Changes to This Privacy Policy

OSHAWISE may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or OSHAWISE may make changes to our services or business. OSHAWISE will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If OSHAWISE makes changes that materially alter your privacy rights, OSHAWISE will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should cease interacting with the Services. Contact the applicable Customer if you wish to request the removal of Personal Data under their control.

‍9) Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Service Data. In general, OSHAWISE is the processor of Service Data and the controller of Other Information.‍

‍10) Your Rights

Individuals located in certain US States such as California and Virginia have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information (in a portable form or otherwise), as well as to seek to update, delete or correct this Information. Where possible and as outlined in this Privacy Policy, you can request to limit your use and disclosure of this Information. You can exercise your privacy rights by sending a request to via email at: privacy@OSHAWISE.com or in writing to:
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OSHAWISE

Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204 

‍To the extent that OSHAWISE’s processing of your Personal Data is subject to applicable laws covering the processing of Personal Data, OSHAWISE relies on its legitimate interests, described above, to process your data. OSHAWISE may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to OSHAWISE’s use of your Personal Data for this purpose at any time.‍

‍11) Your California Privacy Rights

This section provides additional details about the personal information OSHAWISE collects about California consumers and the rights afforded to them under the California Consumer Privacy  Act, as amended by the California Privacy Rights Act or “CCPA.”‍

For more details about the personal information OSHAWISE has collected over the last 12 months, including the categories of sources, please see the Information OSHAWISE Collects and Receives section above. OSHAWISE collects this information for the business and commercial purposes described in the How OSHAWISE Uses Information section above. OSHAWISE shares this information with the categories of third parties described in the How OSHAWISE Shares and Disclose Information section above. Subject to certain limitations, the CCPA also provides California consumers the right to request to know more details about the categories or specific pieces of personal information OSHAWISE collects (including how OSHAWISE uses and disclose this information), to delete their personal information, correct their personal information that may be occurring, and to not be discriminated against for exercising these rights. Please also note that OSHAWISE does not collect sensitive personal information as defined under the CCPA.

 

California consumers may make all other requests to access, correct, or delete pursuant to their rights under the CCPA by contacting us at support@oshawise.com, or by mailing us at:
‍

OSHAWISE

‍Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204 
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OSHAWISE will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

‍12) Your Virginia Privacy Rights

Subject to certain limitations, the Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers the right to request to access personal information we collect about you, correct inaccuracies in you personal data, to request a portable copy of your personal information, and to delete your personal information. You also have the right opt-out from the processing your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, which OSHAWISE does not do. You also have the right to opt out of targeted advertising and selling (as such terms are defined under the VCDPA), however, OSHAWISE does not participate in selling of your personal information. 

 

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

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OSHAWISE will honor the exercise rights or appeals of decisions of Virginia residents requested via email at support@oshawise.com or in writing to:

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OSHAWISE

‍Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204 

13) Contacting OSHAWISE

Please also feel free to contact OSHAWISE if you have any questions about this Privacy Policy or OSHAWISE’s practices, or if you are seeking to exercise any of your statutory rights. OSHAWISE will respond within a timeframe that is compliant with all applicable regulations 

You may contact us at support@oshawise.com or at our mailing address below:

OSHAWISE

‍Attn: Data Privacy Officer

1070 Bannock St #150

Denver, CO 80204