Privacy policy

OVERVIEW

This Privacy Policy (“Policy”) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the Website, or by purchasing or using the Service, you accept the privacy practices described in this Policy.

This Policy applies to the ComplyCube owned and operated website available at https://www.complycube.com and its subdomains (“Website(s)”). ComplyCube (“we,” or “us”) knows that you care how information about you is used and shared. This Privacy Policy explains what information of yours will be collected by ComplyCube when you access the Websites and ComplyCube Service, how the information will be used, and how you can control the collection, correction and/or deletion of information. It also details the steps we take to protect your information.

Policy is incorporated into, and is subject to, the ComplyCube Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the ComplyCube Terms of Service.

DEFINITIONS AND INTERPRETATION

1. “Client” means a customer of ComplyCube.
2. “Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
3. “GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
4. “Personal Data” means any information relating to an identified or identifiable natural person.
5. “Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
6. “Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
7. “Service” means collectively any online facilities, tools, services or information that we make available through the Website either now or in the future.
8. “User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
9. “Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
10. “We/Us/Our” means ComplyCube, the trading name and a registered trademark of TEEMO TECHNOLOGY LTD, with company number: 12392069, whose registered address is at Crown House, 27 Old Gloucester St, London, UK, WC1N 3AX.

THE INFORMATION WE COLLECT ON THE SERVICE

We collect different types of information from or through the Service from the following categories of data subjects: 

1. Customers of ComplyCube (“Client(s)”);

2. Employees, agents, or representatives of Clients, who primarily use the Restricted Areas of the Website for the purpose of accessing the Service in such capacity (“User(s)”); and

3. Individuals other than Users, who use the Public Area, but have no access to the Restricted Areas of the Website or Service (“Visitor(s)”); hereinafter, each separately or collectively referred to as “you” or “your”.  

The legal bases for ComplyCube’s processing of personal data are primarily that the processing is necessary for providing the Service in accordance with ComplyCube’s Terms of Service and that the processing is carried out in ComplyCube’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.

1. User-provided Information. When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer service-related requests.
2. Information Collected by Clients. A Client or User may store or upload into the Service Client Data. ComplyCube has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.
3. “Automatically Collected” Information. When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs” or “web beacons.” This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
4. Integrated Services. You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.
5. Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.

HOW WE USE THE INFORMATION WE COLLECT

We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:

1. Operations: We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.
2. Improvements: We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require ComplyCube to process Client Data, then the data will only be used in anonymized or aggregated form.
3. Communications: We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
4. Cookies and Tracking Technologies: We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting https://www.allaboutcookies.org.
5. Analytics: We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing.. We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.

TO WHOM WE DISCLOSE INFORMATION

Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

1. Unrestricted Information Any information that you voluntarily choose to include in a Public Area of the Service, such as a public blog comment, will be available to any Visitor or User who has access to that content.
2. Service Providers We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
3. Non Personally Identifiable Information We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
4. Law Enforcement, Legal Process and Compliance We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
5. Change of Ownership Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or Visitor Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy. Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Client Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.
6. Transfer of Personal Data. In case your Personal Data is provided to service providers outside the EEA/UK, and where applicable, we will implement appropriate safeguards to protect your Personal Data, including Standard Contractual Clauses as adopted by the European Commission. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA/UK. Moreover, ComplyCube requires its service providers to implement appropriate security measures to ensure the protection of your Personal Data in accordance with applicable data protection legislation.

YOUR CHOICES

1. Access, Correction, Deletion

   We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.

   You may update, correct, or delete your account information and preferences at any time by accessing your account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

   You may have the following rights: right to obtain confirmation from us as to whether we process your Personal Data, right of access, right to withdraw consent, right to restriction of processing, right to object to processing and right to data portability as well as right to lodge a complaint with the relevant data protection authority. 

   This provision does not apply to Personal Data that is part of Client Data. In this case, the management of the Client Data is subject to the Client’s own Privacy Policy, and any request for access, correction or deletion should be made to the Client responsible for the uploading and storage of such data into the Service. You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.

2. Navigation Information You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature .
3. Opting out from Commercial Communications

   If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.

   Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

   ComplyCube has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly. If the Client requests ComplyCube to remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “How to Contact Us” section, and include sufficient information for ComplyCube to identify the Client or its customer or third party and the information to delete or amend.

THIRD-PARTY SERVICES

The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

DATA SECURITY

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through the public Internet, and we also employ application-layer security features to further anonymize Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

DATA RETENTION

We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will delete our clients’ data upon their request when tell us when they no longer require us to store the information we’ve collected on their behalf.

We may also store information for longer than described above where we have a legitimate legal reason for so doing, for example, where we are under a binding legal order not to destroy information. The Client may choose the location of personal data processing (including storage) to comply with the applicable laws.

DATA CONTROLLER AND DATA PROCESSOR

ComplyCube does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. ComplyCube is largely unaware of what Client Data is actually being stored or made available by a Client or User to the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and its Users.

Because ComplyCube does not collect nor determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, ComplyCube is not acting in the capacity of a data controller in terms of the GDPR and does not have the associated responsibilities under the GDPR. ComplyCube should be considered only as a processor acting on behalf of its Clients and Users as to any Client Data containing Personal Data that is subject to the requirements of the GDPR. Except as provided in this Privacy Policy, ComplyCube does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of ComplyCube in connection with ComplyCube’s provision of Services to Clients. Such actions are performed or authorized only by the applicable Client or User.

The Client or the User is the data controller under the GDPR for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data. Under the GDPR, we rely on Article 6.1(a)(b)(c) as the lawful basis for processing this information. Processing is therefore lawful as ComplyCube only processes personal data in the following instances:

1. 1. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
   2. to perform a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
   3. to comply with a legal obligation to which the controller is subject.

The Article 9.2(a) GDPR exception applies for biometric Special Category Data as you have explicitly consented to the processing.

ComplyCube is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is ComplyCube responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.

YOUR RIGHTS

Depending on where you live and subject to applicable data protection law, you may have the following rights, right to obtain confirmation from us as to whether we process your Personal Data; right of access, right to rectification, right to withdraw consent, right to erasure, right to restriction of processing, right to object to processing and right to data portability.  If you would like to exercise these rights please contact the relevant Client that carried out your related check or contact us at privacy@complycube.com. Please be aware that for most requests, ComplyCube will need to notify the Client so the Client can fulfil the request.  This is necessary where ComplyCube is acting on the Client’s behalf.

You are not required to pay any charge for exercising your rights unless a reasonable cost is to be charged where requests are unfounded or excessive, or repetitive in nature.

You may also have a right to lodge a complaint with your local data protection authority or regulator.

HOW WE USE COOKIES

Our site (https://www.complycube.com) uses cookies to distinguish you from other users of our site. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual, therefore providing a good experience whilst at the same time allowing us to improve our site. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. By accessing our site, you are consenting to us using cookies on your system. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This will prevent you from taking full advantage of the website.

TYPES OF COOKIES

Cookies fall into any of four categories:

• Strictly necessary, which are required for the site’s essential functions to work properly.
• Performance cookies, which allow us to analyse how the site is used in order to improve it. These cookies contain no personal information that identifies a visitor, and all information collected is aggregated and therefore anonymous. By using our site, you agree that we can place these types of cookies on your device.
• Functionality necessary, which allow the website to remember choices that you make, such as user name, language, etc. These cookies do not allow your browsing activity on other sites to be tracked by ComplyCube. When you choose to allow your browser to remember your login details, you agree that we can place these types of cookies on your device.
• Targeting necessary, which are used to deliver adverts more relevant to the user and their interests. For logged in users, there are no ads served at all, so these cookies only apply to logged-out visitors.

CONTROL OVER COOKIES

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

CHANGES AND UPDATES TO THIS POLICY

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy 

If this Policy is going to be changed due to ComplyCube’s intention to further process the Personal Data for a purpose other than that for which the Personal Data were collected, it will provide you prior to that further processing with information on that other purpose and with any relevant further information.

HOW TO CONTACT US