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Privacy Policy

 Last Updated On: April 15, 2014

ComplyGlobal Pte. Limited­­­­, is a company engaged in the business of providing a cloud-based software solution to manage and track legal, regulatory and internal Company compliances. Protecting consumer privacy is important to the Company. The Company and its affiliates in the United States and across other countries (hereinafter collectively referred to as the “ComplyGlobal”, “Company”, “We”, “Us” or “Our” which expression shall mean and include its affiliates, successors and permitted assigns) adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (“Principles”) with respect to that data. If there is any conflict between this Privacy Policy (the “Policy”) and the Principles, the Principles shall prevail. This Policy describes Your privacy rights regarding Our collection, use, storage, sharing and protection of Your Personal Information that You may provide via this Website and the policies adopted by Us to that effect. It applies to the www.complyglobal.com Website (the “Website”) and all related sites, applications, Services (as defined under the Terms of Use) and tools where this policy is referenced, regardless of how you access or use them. Please be sure to read this entire Policy before using or submitting information to this site. 

If you reside in the United States or the EU, then the Personal Information provided to or gathered by ComplyGlobal is controlled by ComplyGlobal Limited­­­­. If you reside outside the United States or the EU, then the Personal Information provided to or gathered by ComplyGlobal is controlled by ComplyGlobal Pte. Limited­­­­, Singapore. If you have any concern about providing information to Us or having such information displayed on the ComplyGlobal services or otherwise used in any manner permitted in this Privacy Policy and the Terms of Use, you should not become a customer of ComplyGlobal or visit Our Website. If You have already registered, You should close Your account.

ComplyGlobal reserves the right to modify the Policy without prior consent of the Users. In case of any material changes to the Policy, the Users will be notified by email (sent to the email address specified in the User’s account) or by means of a notice on this Website prior to the change becoming effective. The Users are encouraged to periodically review this page for the latest information on its privacy practices. The term “User(s)” shall mean and include all companies and private organizations that visit the Website and provide information to ComplyGlobal through any of the modes referred to in the clause on “Collection of Information” below.

YOUR CONSENT

Use of this site constitutes Your consent to application of such laws and regulations and to the terms of Our Policy. Whenever you submit information via this site, you consent to the collection, use and disclosure of that information in accordance with this Policy. 

COLLECTION OF INFORMATION

We collect Your Personal Information in the following ways: 

The term "Personal Information" or “Information” shall mean information that (i) is transferred from the EU to the United States of America; (ii) is transferred from any other country (other than the EU and the United States of America) to Singapore (ii) is recorded in any form; and (iii) is transferred from Switzerland to the United States of America; is recorded in any form; and (iv) is about, pertains to or can be associated with a specific person and could be used to identify that person.

We do not consider Personal Information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person. If You are using the Website on behalf of a company or other legal entity, You are nevertheless, jointly and severally, bound by this Policy even if Your company has a separate arrangement with Us.

This site actively collects information from its visitors both by asking You specific questions and by permitting You to communicate directly with Us via e-mail. During the use of the Website, We may collect and process such information from the Users, including but not limited to the below mentioned:

  1. Information that the Users provide to ComplyGlobal by filling in forms on the Website. This includes contact information such as name, email address, mailing address, phone number, financial information including but without limitation, if any, unique identifiers such as user name, account number, password and preferences information such as favorite lists and transaction history;
  2. Information that the Users provide when the Users write directly to ComplyGlobal (including by way of e-mail); 
  3. Information that the Users provide to ComplyGlobal over telephone. ComplyGlobal may make and keep a record of the information shared by the Users with ComplyGlobal;
  4. Information that the Users provide to ComplyGlobal by completing surveys, questionnaire, etc.;
  5. Information relating to logs is automatically reported by the User’s browser each time the User accesses a web page. When the User uses the Website, ComplyGlobal servers automatically record certain information that the User’s web browser sends whenever the User visits any website. These server logs may include information such as the User’s web request, Internet Protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. ComplyGlobal uses this information, which does not identify Users, to analyze trends, to administer the website, to track Users’ movements around the Website and to gather demographic information about the User base as a whole. ComplyGlobal does not link this automatically collected data to personally identifiable information.
  6. When You visit the Website or use ComplyGlobal Services, We collect information sent to Us by Your computer or other access device. The information sent to Us includes data on the pages You access, Your computer IP address, device identifiers, and the type of operating system You are using, Your location, mobile network information, standard web log data and other information. Web log data includes the browser type You are using and traffic to and from Our site. When You visit the Website or use ComplyGlobal Services, We also collect information about Your transactions and Your activities.

Some of the information that you submit may be personally identifiable information (that is, information that can be uniquely identified with you such as Your full name, address, e-mail address, phone number and so on).

You may also choose to provide Us with access to certain Personal Information stored by third parties such as social media sites (e.g., Facebook and Twitter). The information We may receive varies by site and is controlled by that site. By associating an account managed by a third party with Your ComplyGlobal account and authorizing ComplyGlobal to have access to this information, You agree that ComplyGlobal may collect, store and use this information in accordance with this Policy. 

ComplyGlobal complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. ComplyGlobal has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view ComplyGlobal’s certification, please visit http://www.export.gov/safeharbor/

NOTICE OF USE OF INFORMATION

 At ComplyGlobal, We use the information We obtain about Our customers for the following activities:

  1. To provide, deliver and assist Us in providing and delivering any products and services to You and to help Us improve and develop these services;
  2. To send You and keep You informed about commercial communications, subject to any choices You have made, about ComplyGlobal or third party products and services, loyalty programmes or other updates;
  3. To verify any of the information You provide in order to effect, administer and enforce transactions, to manage Our customer relationships, to provide the requested products and services, to sign up agents, to ensure Your eligibility for any services, or products You apply for, and to maintain accuracy of Our records;
  4. To allow You to change web pages during Your visit without having to re-enter Your password;
  5. To store Your preferences and other information and to track activity on Our Website;
  6. To better understand the effectiveness of Our promotional campaigns;
  7. To deliver Information specific to Your interests on additional websites;

Except as otherwise stated, We may use Your information to improve the content of Our site, to customize the site to Your preferences, to communicate information to you (if you have requested it), for Our marketing and research purposes, and for the purposes specified in this Policy.

In the event the Information is collected for a purpose other than that stated herein, the Company shall inform You of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. Company shall provide You with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when You are asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected for.

CHOICE TO OPT OUT

In connection with our services, products and/or promotions, we may disclose Your Information to non-agent partners from time to time. If you wish that Your Information is not disclosed to non-agent partners, then we may not be able to provide services, products and promotions to You.

If you need additional information on how Your Information may be disclosed to non-agent partners, please write to info@complyglobal.com

SHARING OF PERSONAL INFORMATION                                      

We may share Personal Information with Our other corporate entities and affiliates, non-agent partners who represent Us across various jurisdictions, and who would be assisting Us in providing the services as sought by You. While ComplyGlobal strives to ensure that the Personal Information shared with other corporate entities, affiliates and partners are not subject to misappropriation or misuse, and that the third-party subscribes to the Principles or are subject to applicable law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection. ComplyGlobal shall not be responsible for misappropriation or misuse of Personal Information that may be attributed to such corporate entities and affiliates, partners.

We may also share Personal Information with Our other corporate entities and affiliates, partners to help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of Our services; and to facilitate joint or co-branded services that you request where such services are provided by more than one corporate entity. Those entities and affiliates may not market to you as a result of such sharing unless you explicitly choose so. 

We may disclose Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders or other legal process. We may disclose personal information to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: enforce Our Terms of Use or Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of Our Users or the general public. 

We and Our affiliates will share some or all of Your Personal Information with another business entity should We (or Our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business.

DATA SECURITY

Company shall take reasonable steps to protect the Information from loss, misuse and authorized access, disclosure, alteration and destruction. Company has ensured that appropriate physical, electronic and managerial procedures have been put it place whether personally or through a third party, to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. We cannot guarantee the security of Information on or transmitted via the internet.

Company shall only access Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by You.

COOKIES 

The Website uses “cookies”. A cookie is a small text file that’s stored on Your computer, tablet or phone when you visit a Website that helps the site remember information about you and Your preferences.

Some cookies are deleted when you close down Your browser. These are known as Session Cookies. Others remain on Your device until they expire or you delete them from Your cache. These are known as Persistent Cookies and enable Us to remember things about you as a returning visitor.

We use Session Cookies for the following purposes:

  • To allow you to carry information across pages of the Website and avoid having to re-enter information.
  • Within registration to allow you to access stored information.
  • To compile anonymous, aggregated statistics that allow Us to understand how Users use Our Website and to help Us improve the structure of Our Website. 

We use Persistent Cookies for the following purposes:

  • To help Us recognize you as a unique visitor (just a number) when you return to Our Website and to allow Us to tailor content to match Your preferred interests.
  • To compile anonymous, aggregated statistics that allow Us to understand how Users use Our Website and to help Us improve the structure of Our Website.
  • To internally identify you by account name, email address, customer ID and location (geographic and computer ID/IP address).
  • To tailor content to Your preferences.

Third parties may also serve cookies via this Website. These Third Party Cookies are used for the following purposes:

  • To serve content on Our site and track whether this content is clicked on by Users. 
  • To control how often you are shown particular content. 
  • To count the number of anonymous Users of Our site.
  • For Website usage analysis.

You can set Your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it.

You can also set Your browser to block the placing of cookies at all, but you should realize that this can limit the use of Our Website or services.

LINKS TO OTHER SITES

Our Website links to other Websites that may collect personally identifiable information about you. Please be informed that ComplyGlobal does not control other websites and that, in any case, this Policy does not apply to those websites. We encourage you to read the privacy and cookie policy of every website that you visit.

E-MAIL ADDRESS

If you subscribe to Our e-mail alerts, We collect Your e-mail address. This address will only be used for keeping you informed as indicated. If you wish to unsubscribe from Our e-mail alert list, you can do so at any moment as indicated in every e-mail you receive or by contacting Us through ComplyGlobal.

REFERRALS

If the User wishes to introduce ComplyGlobal / the Website to any other person / entity, the User will be asked to provide such person / entity’s name and email address. ComplyGlobal will automatically send such person / entity an email inviting it or to visit the Website. ComplyGlobal stores this information for the purpose of sending this email and keeping a record of the number of persons / entities so referred by the Users. ComplyGlobal may send additional emails to the said person / entity in connection with services offered by ComplyGlobal.

RIGHTS TO ACCESS, CORRECT OR DELETE YOUR INFORMATION, AND CLOSING YOUR ACCOUNT

You have a right to (1) access, modify, correct or delete Your Personal Information controlled by ComplyGlobal; (2) change or remove Your content, and (3) close Your account. You can also contact Us for any account information which is not on Your profile or readily accessible to you. If You close Your account, Your information will generally be removed from the Service within Forty-Eight (48) hours. We generally delete closed account information and will de-personalize any logs or other backup information within Thirty (30) days of account closure, except as noted below.

DATA RETENTION

We retain the Personal Information You provide while Your account is in existence or as needed to provide You Services. ComplyGlobal may retain Your Personal Information even after You have closed Your account if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes that may come up, prevent fraud and abuse, or enforce this Policy and Our Terms of Use. We may retain Personal Information, for a limited period of time, if requested by legal or Governmental Authorities. ComplyGlobal’s Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but We generally delete or de-personalize closed account data consistent with the above mentioned section, except in the case of Our plug-in impression data, which We will try to de-personalize at the time of collection, but in any event, We will de-personalize within seven (7) days.

SEVERABILITY

ComplyGlobal has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. 

NO WAIVER 

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

ENFORCEMENT

The Company uses a self-assessment approach to ensure compliance with this privacy policy and periodically verifies that the policy is accurate and comprehensive for the information intended to be covered, prominently displayed, completely implemented and assessable and in conformity with the Principles. We encourage interested person to raise any concern using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. 

If a complaint or dispute cannot be resolved through our internal processes, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider. 

FOREIGN JURISDICTION

ComplyGlobal makes no representation that the content contained on the Website is appropriate to be used or accessed outside the United States of America. If the Users use or access the Website from outside the United States of America, they are requested to do an independent research on their compliance with the laws of the relevant jurisdiction wherein they are domiciled. 

CONTACT

Any questions, grievances or concerns regarding the Company’s Safe Harbor Policy or data collection and processing practices should be addressed to: 

ComplyGlobal Limited­­­­
Attn: Legal Department
Address: 10 East 33rd Street, 6th Floor
New York, NY 10016