Privacy Notice

This Privacy Notice describes the data protection practices of Rebric Inc. DBA Compliable (“Rebric,” “Compliable,” “we,” “us,” or “our”). This Privacy Notice applies to information we collect and use about you when you access the Compliable website located at https://www.compliable.com/ (“Website”) and/or its related online software as a service designed to assist individuals and companies in completing gambling license applications and renewals (collectively, the “Services”).

PLEASE READ THIS PRIVACY NOTICE CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, PLEASE DO NOT ACCESS THE COMPLIABLE WEBSITE, ENGAGE US FOR OUR SERVICES, OR OTHERWISE USE OUR SERVICES.

INFORMATION WE COLLECT AND FROM WHAT SOURCES
We collect information about you as set forth below and through the means discussed below. Please note that we need certain types of information so that you can access our Website, or we can provide the Services you request. If you do not provide us with the required information, or ask us to delete it, you may no longer be able to access the Website or use our Services.

Information Collected

While parts of the Services may not require you to provide any information that can directly identify you by name (such as simply browsing the  Website), the specific types of information we collect will depend upon the Services you request or otherwise use and the information you choose to provide. The types of data we may collect include:

• Contact information such as first and last name and email address
• Customer and transaction information such as information about purchases or other transactions with us and information about your customer service interactions with us
• Usage Data (defined below)
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications
• Other information you choose to directly provide to us in connection with our delivery of the Services, such as phone number, current and former address, social security number, driver’s license number, passport number, and other government-related identification information, biometric information and physical characteristics, emergency contact information, ethnicity, gender, education information, criminal history information, date and place of birth, citizenship status, bankruptcy, legal, and child support history, military service history, and tax-related information.

Sensitive Personal Information

Compliable recognizes that certain jurisdictions have enacted laws with different requirements regarding the processing of certain sensitive personal information. “Sensitive Personal Information” includes special categories of personal data identified by European and other data privacy laws. This may include personal identity numbers; certain financial account information in combination with account access credentials; racial or ethnic origin; political opinions; religious, philosophical, or other similar beliefs; membership of a trade union or profession or trade association; physical or mental health; biometric or genetic data; sexual life information; or criminal record (including suspected criminal activities). Compliable does not require such Sensitive Personal Information from you when using the Website generally. In the cases where we do seek to collect Sensitive Personal Information, for example when providing Services to you or your current or prospective employer in connection with assisting in the completion of online gambling license applications, we will seek to do so in accordance with applicable data privacy laws. Your employer may, as required by applicable data privacy laws, obtain your consent for the processing of your Sensitive Personal Information and sharing it with us or for directing you to use the Services to provide us with your Sensitive Personal Information in connection with our provision of contracted Services to your employer in our role as a service provider (or data processor, in certain jurisdictions). Please contact your current or prospective employer regarding any processing of your Sensitive Personal Information. Do not provide us with unsolicited Sensitive Personal Information for reasons not related to the Services. We do not request or require any Sensitive Personal Information except in certain circumstances related to Services provided to our customers, as indicated above.

Information You Or Your Employer Provide to Us

We collect a variety of information that you or your employer provide directly to us. For example, we collect information from you or your employer through:

• The Services we provide and when processing orders, gaming license application requests, and other explicit requested information;
• Requests or questions you submit to us via online forms on our Website; and
• Requests for customer support and technical assistance.

Information We Collect Through Automated Means

When you use the Services, we collect and analyze information via temporary cookies, such as your IP address, browser types, location, browser language, operating system, referring and exit pages and URLs, error logs, and other similar information (collectively, “Usage Data”). For detailed information about the cookies we use, please refer to our Cookie Notice .

Information we obtain from other third parties.

We may receive personal information about you from third-party sources such as marketing partners, social media and other cloud-based platforms, identity providers, publicly-available sources, business partners, and data providers.

Recruiting Information

If you choose to apply to work with or for Compliable through our Websites or by otherwise contacting us regarding opportunities to become an agent or contractor for us, we may collect the following:

• Contact Information, such as your first and last name, email and mailing addresses, phone number, professional title and company name
• Resume Information, such as qualifications, skills, employment or education history, or other resume information
• Reference information, such as name and contact details of your references.
• Social Media Information, such as if you provide us a link to or other access to a social media account, we may collect or access any information you permit to be shared through or from your social media account and other information depending on the social media platform.
• Compensation information that you voluntarily provide and which may depend on your region and applicable laws and regulations.
• Background check information, subject to applicable law.

Authorization to Provide Information

You are responsible for the personal information you provide or make available to us in connection with your use of the Services or our recruiting activities. All personal information you provide in connection with our recruiting activities must be truthful, accurate and not misleading in any way. You may not provide information that is obscene, defamatory, infringing, malicious, or that violates any law. You are responsible for providing any notices and obtaining any consents necessary for us to collect and use personal information of your references as described in this Privacy Notice whether the references are provided in connection with your use of the Services or our recruiting activities.

How we Use Your Information

We, or our service providers, use your information for various purposes depending on the types of information we have collected from you, in order to:

• Develop, provide, deliver, and improve the Services. For example, your information is hosted and processed by our Services in order to create an account for you and to create and display to you gaming license applications based on information you or your employer provide. We may use your information to refine and improve the Services such as to add new features and improve the user experience and to accommodate gaming license applications for new jurisdictions. We may also use your information to communicate with you about your use of the Website or Services such as to confirm your identity.
• Respond to your request for information and provide you with more effective and efficient customer service and technical support. For example, we use your information to respond to your requests for information about our Services and, if you are a current customer or employee of a customer and submit a request for technical support, to identify you as associated with a current customer and provide more accurate and personalized technical support.
• Market, promote, and conduct advertising for the Services. For example, we use your information to send you marketing communications via email or other contact methods where you have provided consent (as required by applicable law).
• Operate, maintain, secure, and improve current and future Websites. For example, our Websites may collect your information through forms that you submit and may collect information automatically, such as Usage Data, about your use of the Website and Services to inform us about Website and Services performance and areas of improvement.
• Comply with any procedures, laws, and regulations which apply to us or our processing. For example, we comply with subpoenas and other court orders to process data where we have determined there is a legal requirement for us to do so. We may provide information to government gaming authorities or agencies as required by applicable law and in relation to their investigations.
• Establish, exercise, or defend our legal rights. We may process your personal information in connection with establishing, exercising, or defending our legal rights where it is necessary for our legitimate interests or the legitimate interests of others or for fraud prevention. For example, we may process information you provide to identify any fraudulent, harmful, unauthorized, unethical or illegal activity such as use of another individual’s identity and we may use your information as necessary to defend ourselves in litigation or enforce our rights or agreements with others.
• Conduct recruiting and hiring activities for opportunities with Compliable. If you apply to work with or for Compliable, we will review the information you submit to determine if your qualifications and experience match any available opportunities at Compliable, to conduct background checks and verify the information you provide, communicate with you regarding any opportunities, improve our recruiting processes, process your onboarding if hired, and comply with applicable labor and employment laws.
• Other legitimate purposes as required or permitted by applicable law. We may process your information for other purposes consistent with those in this Privacy Notice and as may be permitted or required by applicable law.

Combined Information. For the purposes discussed in this Privacy Notice, we may combine the information that we collect through the Services with information that we receive from your engagement with the  Website or from your employer and use such combined information in accordance with this Privacy Notice.

Aggregate/Deidentified Data. We may aggregate and/or deidentify any information collected through the Services so that the information can no longer be linked to you or your device. We may use the aggregated and/or deidentified information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

Cookies and Similar Technologies

To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers may use Internet server logs and cookies. For detailed information about our use of cookies, please refer to our Cookie Notice.

How We Share and Disclose Your Information

Compliable will share your information in the following ways:

• Third Parties: We share your information with third parties in order to fulfill the purpose for which you have provided it. Depending on your role and your relationship with our customer, this may or may not include sharing your information with our customer (your current or prospective employer). Please contact us as set forth below or contact your current or prospective employer to learn whether your information will be shared with the employer.
• Service Providers: We provide access to or share your information with select third parties who perform services on our behalf. They have access to your information to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, product content and features, research, customer service, data storage, security, fraud prevention, payment processing, marketing and advertising, and legal services.
• Governmental Agencies: We may share your information with certain governmental agencies as required by law or as authorized by your prospective or current employer for purposes of applying for and evaluating gaming licenses. This sharing of information may be required in order to perform the Services.
• Protection of Compliable and Others: We may disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g., a subpoena or court order); (b) enforce this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties such as rights of privacy or intellectual property rights; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Compliable, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
• Partners: We may share your information with partners such as distribution or joint marketing partners pursuant to our agreements with those parties. For example, if we engage with a reseller or another company in the gaming or gaming license industry, we may share your information with such parties so they may contact you directly.
• Consent: We may share your information when we have your consent, for example, with prospective customers with whom you have agreed to speak regarding the Services you received from us. With your consent, we may also share your information with Government Agencies as set forth above.
• Business Transfers: As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including information processed in accordance with this Privacy Notice) may be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
• Aggregate/Deidentified Information: From time to time, we may share aggregate/deidentified information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
• Intracompany: We may share your information with our affiliates and subsidiaries to operate our business, for example, if we establish a presence in a country outside of the USA, we may share your information with our subsidiaries and affiliates in such other countries.

For a list of third parties that process your personal information on our behalf when we provide gambling license application services, please see Subprocessors below.

Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and used it, requirements of applicable laws, the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the resolution of any pending or threatened disputes, and enforcement of our agreements.

When we no longer require the personal information, we will either delete or deidentify it or, if this is not possible, securely store it in accordance with this Privacy Notice and cease use of the personal information until deletion is possible. If we deidentify your personal information (so that it can no longer be associated with you), we may retain this information for longer periods.

How we Protect your Information

Compliable takes technical and organizational security measures to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Do not share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we use measures to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. 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 our Website or through our Services.

Children’s Privacy

The Services are intended for general audiences and not for children under the age of 18. If we become aware that we have inadvertently collected or received personal information from children under the age of 18  without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of children under the age of 18 without parental consent.

Users Located Outside the United States

The Website and our Services are hosted in and provided from the United States, and your use of our Website and Services is governed by United States law. If you are using the Website or Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our systems and facilities, and those of our third party providers and recipients of information, are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Website and Services, you consent to your information being transferred to our systems and facilities, and to the systems and facilities of those third parties with whom we share information as described in this Privacy Notice. Please see our Regional Privacy Notice for further information applicable to individuals located in the European Union and United Kingdom.

Rights and Choices

Choosing not to share your Personal Information.

You may choose not to provide personal information. If you choose not to provide personal information (or ask us to delete it), we may not be able to provide you with our Services or certain functionality of the Website. We will tell you what information you must provide to receive the Service or Website functionality by designating it as required at the time of collection or through other appropriate means.

Marketing Communications and Sharing

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding Services, promotions, surveys and special events that might appeal to your interests by following the instructions located at the bottom of any commercial emails you may receive, by using the SMS text options provided in any SMS text messages, or by emailing us at privacy@compliable.com. Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational or transactional emails, such as those reflecting our relationship or transactions with you, or important notifications regarding the Services we are providing to you.

Cookies and Browser Web Storage

Please see the Cookies and Similar Technologies section above.

Privacy Notice for Residents of Certain U.S. States

Some U.S. state laws provide state residents with additional privacy rights. We do not, as a matter of course, sell your personal information as defined by such laws regulating the “sale” of personal information.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at any time to reflect changes in the law, our data collection and use practices, our Services, or advances in technology. We will make the revised Privacy Notice accessible through the  Website and the Services, so you should review the Privacy Notice periodically. The “Last Updated” date included at the end of this Privacy Notice will indicate when it was last updated. If we make a material change to the Notice, you will be provided with appropriate notice in accordance with legal requirements. By continuing to access the  Website or using the Services, you are confirming you have read and understand the latest version of this Privacy Notice.

Contact Information

Please feel free to contact us if you have any questions about this  Privacy Notice or our associated information practices.

You may contact us as follows:
Compliable Inc.
1644 Platte St
Denver, CO 80202
privacy@compliable.com

Last updated: January [12], 2022

Subprocessors

We may engage the below third party processors who may process your personal information (“Subprocessors”) in the performance of our gambling license application services.