Effective as of July 19, 2023.

At Accompa we recognize that privacy is very important to you, and we want you to know that we are committed to safeguarding your information. This document details the types of personal information we receive and collect when you use our services, as well as the steps we take to safeguard such information.

Accompa, Inc. (“ACCOMPA”, “We”) is dedicated to establishing a trusting relationship with our users (“You”, “Customers”), based on respect for personal identity and information. This privacy policy covers the ACCOMPA website, the Accompa requirements management software, and/or other websites and services provided by ACCOMPA (“Service”, or “Services”).

PROTECTION OF CUSTOMER DATA

• We’re dedicated to protecting the security, confidentiality and integrity of data You store into Accompa. Please see section 3 of our Terms of Service for details.

PROTECTION OF CUSTOMER COMMUNICATION

We collect the e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages users access or visit, and information volunteered by the user (such as survey information and/or Web site registrations). The information we collect is used to improve the content of our Web pages and the quality of our Services, and is not shared with or sold to other organizations for commercial purposes, except to provide services You have requested, when we have Your permission, or under the following circumstances:

• When it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law.
• We transfer information about You if Accompa is acquired by or merged with another company. In this event, Accompa will notify You before information about You is transferred and becomes subject to a different privacy policy.

INFORMATION GATHERING AND USAGE

• When You register for our Services we ask for information such as Your name, company name, email address, billing address, and credit card information.
• ACCOMPA uses collected information for the following purposes: provisioning Services, billing, identification and authentication, Services improvement, contact for support and general communication, and research.

COOKIES

• A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to Your browser from a web site’s computers and stored on Your computer’s hard drive. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Your browser’s help instructions.
• Cookies are required to use our Services.
• ACCOMPA uses session ID cookies to record current session information, and uses persistent cookies for purposes such as remembering Your email address to enable quicker login. You are required to log-in to the Service after a certain period of time has elapsed to protect You against others accidentally accessing Your account contents.

CLEAR GIFS

Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the click trail of users of our Services. The clear gifs are invisible on the page and are about the size of the period at the end of this sentence. Clear gifs are not tied to users’ personally identifiable information.

We also use clear gifs in our HTML-based emails to let us know which emails the recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, they may do so by following the Opt-out Directions in these emails.

LOG FILES

Like most Web sites, ACCOMPA servers use log files to analyze trends, administer the site, track user movements in the aggregate, and gather broad demographic information for aggregate use.

THIRD PARTY INTERMEDIARIES

We use outside companies to provide us certain services such as billing credit cards, website analytics, and email services. These companies do not use personally identifiable information for any secondary purposes.

COMMUNICATIONS FROM ACCOMPA

• Special Offers and Updates: We send all new customers a welcoming email to introduce their new Services. Established users will occasionally receive emails containing information about us, updates on new Service features, Service usage tips, and member satisfaction questions.
• Invoices and Account Statements: We send our users’ billing administrators regular emails summarizing invoices and credit card charges. These emails are a part of the ACCOMPA service, and users cannot opt-out of receiving them, though they can deactivate their account. Information identifying the credit card is not included in these communications.
• Service Announcements: On rare occasions it is necessary to send out a strictly Service related announcement. For instance, if our Service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. These communications are not promotional in nature.
• Customer Service: We communicate with users on a regular basis to provide requested Services and regarding issues relating to their accounts. Generally, users may not opt-out of these communications, though they can deactivate their account.

SURVEYS

Periodically, ACCOMPA requests information from users via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of ACCOMPA’s Services. Users’ personally identifiable information is not shared with third parties. Though we may use an intermediary to conduct these surveys, they may not use customers’ personally identifiable information for any secondary purposes.

REFERRAL PROGRAMS

Periodically, ACCOMPA offers referral services, asking a user to inform a friend about our Service. We collect the name and email address of the friend, and will send an automatic email invitation to the friend. ACCOMPA stores this information for the sole purpose of sending this email and tracking success of the programs.

SAFEGUARDS

ACCOMPA takes every precaution to protect user’s information. When users submit sensitive information via ACCOMPA’s Services, their information is protected both online and off-line.

When our registration/order forms ask users to enter sensitive information (such as credit card number), that information is encrypted and is protected with the best encryption software in the industry – usually referred to as SSL. While on a secure page, such as our paid order form, the lock icon on the bottom of Web browsers such as Firefox and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just ‘surfing’.

While we use SSL encryption to protect sensitive information online, we also employ security measures to protect user-information off-line. All of our users’ information, not just the sensitive information mentioned above, is carefully restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerks or a customer service representative) are granted access to personally identifiable information, on an as-needed basis. Finally, the servers that store personally identifiable information are in a fully secure environment.

DO NOT TRACK (DNT) REQUESTS

Some internet browsers have enabled ‘Do Not Track’ (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don’t wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals..

DISCLOSURE

ACCOMPA may disclose personally identifiable information ONLY under special circumstances: To comply with a judicial order or lawfully issued subpoena, or when Your actions violate the Terms of Service.

NOTIFICATION OF CHANGES
ACCOMPA may periodically update this policy. ACCOMPA will notify You about significant changes in the way we treat personal information by sending a notice to the primary email address specified in Your ACCOMPA Services account or by placing a prominent notice on our Web site.

QUESTIONS
Any questions about this Privacy Policy should be addressed to info@accompa.com or by mail at: Accompa Inc., 5201 Great America Pkwy, Ste 320, Santa Clara, CA 95054 (USA).

Important Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights.

You have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

How to exercise your information, access and deletion rights.

You may submit a request to exercise your information, access or deletion rights by emailing us at info@accompa.com. We will need to verify your identity to process your information, access and deletion requests and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.

We do not sell your personal information.

Based on our current understanding of the CCPA, we do not sell your personal information as defined in the CCPA.

Personal information we collect, use and disclose.

The chart below describes the categories of Personal Information we collect by reference to the categories specified by the CCPA (California Civil Code § 1798.140(o)).

Statutory category of personal information (PI)	PI we collect	Sources of the PI	Business/commercial purpose for PI collection	Parties to whom we disclose PI for a business purpose
Identifiers (general)	– Contact information – Profile information	– You – Third party sources	– Service delivery – Research & development – Marketing – Compliance & Protection	– Service providers
Commercial Information	– Communications – Marketing Information	– You – Third party sources	– Service delivery – Research & development – Marketing – Compliance & Protection	– Service providers
Financial Information	– Transaction information	– Our Customers	– Service delivery – Compliance & Protection	– Payment processors – Service providers
Identifiers (online)	– Device data	– You – Automatic collection	– Service delivery – Site operation – Research & development – Marketing – Compliance & Protection	– Service providers
Internet or Network Information	Online activity data	Automatic collection	– Service delivery – Site operation – Research & development – Marketing – Compliance & Protection	– Service providers
Professional or Employment Information	– Contact information – Profile information	– You – Third party sources	– Service delivery – Research & development – Marketing – Compliance & Protection	– Service providers
Sensory Information	-Communications	– You	– Marketing – Compliance & Protection	– Service providers
Inferences	User preferences derived from any of the information listed above that we collect from Customers	– Us	– Service delivery – Site Operation – Research & development – Marketing – Compliance & Protection	– Service providers

We may further disclose each category of Personal Information to our affiliates, to our professional advisors, in connection with our compliance and protection activities and in connection with business transfers.

This chart describes our practices as of, and during the 12 months preceding, the effective date of this Privacy Policy.