Privacy Policy

Date of last update: September 5, 2025

This privacy policy (policy) describes how Comply Technologies, Inc., its affiliates, and subsidiaries (collectively, we, our or Comply) collect, share, use and otherwise process personal information in connection with our various websites (public sites) that link to this policy, products and services including any consulting, SaaS platforms and other applications we provide to our customers (products) or matters which otherwise reference this policy. Accordingly, this policy should be considered notice to you and any individuals whose personal information we process.

This updated policy is effective as of the date of last update and applies to our use of your personal information as of that date.

Table of contents

Definitions
Personal information we collect
How we collect personal information
The personal information we collect on behalf of Employers
How we use your personal information and the basis on which we use it
How we share your personal information
Your choices and rights
California privacy disclosures
Retention
Our security measures
Our policy towards children
International visitors and users
Links from our public sites and products to others
Changes to this privacy policy
Contacting Comply

1. Definitions

For purposes of this policy, the following definitions shall apply:

Employer means an entity that is authorized to use products or services from Comply, and that employs individuals who submit to Comply certain personal information regarding themselves and/or others for processing under the terms of the policies of their Employer and/or applicable law.
Personal information means any information or set of information which identifies, relates to, describes, is reasonably capable of being associated with or could be used by or on behalf of Comply to identify an individual.

2. Personal information we collect

The types of personal information we collect include:

Identifiers – For example, your name, mailing address, email address, username, password, and telephone number.
Contents of communications with us – Any information you choose to share in communications with us, including through our public site and products.
Professional or education-related information – If you apply for a job through one of our public sites, we collect the personal information you include in your application including your name, mailing address, email address, phone number, resume / CV, academic history, certifications, GPA, professional memberships and any other personal information you provide regarding your employment history.
Internet or other electronic network activity information – For example, information on the type of device you use to access our public site and/or products, including a device identifier, IP address or operating system, information about the browser you are using to view our public sites and online products, the site you came from or visited when you leave. We may also be able to see where you downloaded the mobile app version of our product and the frequency with which you use it.
Geolocation data – information about the city or state where you are located.

3. How we collect personal information

a. Personal information collected automatically

We may gather identifiers and internet or other electronic network activity information from any visitor to our public site or products using cookies and other similar technologies, such as pixels, tags, and web server logs. A cookie is a text file sent to your devices (e.g., computer, laptop, smartphone, or tablet) by the webpage server for the webpage you visit. For more information about our use of these technologies and for a description of your choices with respect to the use of these technologies, please review our linked Cookie Policy | Comply.

b. Personal information you provide to Comply

In addition to the information automatically collected by your browser, we collect personal information through our public sites and/or products. To obtain access to certain products including online services not available to anonymous visitors, we require you to provide us with personal information such as your name and email address. If you send us an email or message through contact forms on our public sites or the product, we will retain your contact information and message content to respond to your inquiries or contact you regarding customer service or other reasons related to our public sites and products.

4. The personal information we process on behalf of Employers

Our products offer services to Employers to assist with their compliance, legal and governance obligations. Access to our products is restricted to customers with which we have contracts and their affiliates. Employers contract with Comply for many reasons including, in some cases, to assist in their collection of certain personal information necessary for their compliance with applicable laws and regulations. We process this personal information as a processor, meaning that the Employer determines what information is collected, how it is updated and how long it is held, and the processing of this personal information, including as described below, is subject to the Employer’s privacy notice. Employers are responsible for compliance with all data privacy and security laws and regulations applicable to Comply’s collection of personal information in connection with the use of the products, whether directly or indirectly through your Employer, a third party (e.g., your brokerage firm) or you. This includes, without limitation, your Employer’s receipt of any required consents and your Employer’s provision of mechanisms for you to exercise your data rights, including to access, update, correct or delete personal information from the products.

If you or your Employer use our products, you will be required to provide identifying information (e.g., a username) and select a password, which will be used to access our products, including any personal information stored therein. During the registration process we collect information (registration information), which may include your name, email address and brokerage account number(s) and associated holdings. This information may be submitted by you, your Employer, your brokers or other parties. Some of this information may be optional depending on your Employer’s compliance requirements. In delivering products, we may view transactional information in the brokerage accounts you or an Employer designate. Comply is not responsible for the accuracy of any information provided to us.

5. How we use your personal information and the basis on which we use it

Our use of personal information is subject to the policy in effect at the time of use. The provisions of this policy supersede all previous notices or statements regarding our privacy practices with respect to this public site and our products.

We use your personal information for the following business purposes:

Providing Employers with our products to assist Employers with their compliance, legal and governance obligations. We do this to comply with our contractual obligations with our customers.
Communicating with you and providing support, such as to provide you with information about the products, including promotional material, addressing your inquiries and feedback, requests, and other communications you send us, and providing you and the Employers and customers with whom we work with customer support services. It is in our legitimate interest to provide you and Employers with appropriate responses and provide you with information about our services.
Operating, evaluating, and improving our business, such as performing accounting, auditing, record keeping, and other internal functions; storing and managing data; tracking purchases and customer data; conducting research and surveys; and analyzing and improving our public sites and products. We do this to comply with our contractual obligations to you or Employers and customers, and because it is in our legitimate interest to use personal information to manage our business and improve our products and services.
For marketing advertising purposes, such as to deliver targeted advertising and to evaluate the effectiveness of advertising campaigns. This may include sharing personal information with third-party advertisers or supplementing our data with information obtained from external sources to improve the relevance of our marketing efforts. It is in our legitimate interest to provide more relevant and interesting advertising messages and other marketing communications. Where necessary, we will obtain your consent before sending such marketing messages or contacting you by phone for marketing purposes.
Complying with law, such as to carry out fraud prevention checks or comply with other legal or regulatory requirements, including when required to interact with regulators and law enforcement agencies, where this is explicitly required by law.
Exercising our legal rights, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims, or violations of law or our terms and conditions, where it is necessary to do so.
Protecting against harm, such as when we deem the use of personal information as being necessary to protect the rights and safety of us, you, or others, or as required to comply with our policies.

Where required by applicable law, we process personal information on the basis of your consent, for example, to send you direct marketing communications or when collecting personal information via cookies or other similar technologies. To the extent we obtain your consent to process your personal information, you may have the right to withdraw your consent under applicable local law. To exercise this right, please contact us at privacy@comply.com. With respect to tracking technologies, you may withdraw your consent by following the instructions in our Cookie Policy | Comply or cookie banner.

We may de-identify and/or aggregate personal information so that it cannot be linked to you or any other individual. De-identified and aggregated data is not considered “personal information”. We may use and share that aggregated or de-identified information for any purpose, for example to conduct research and analytics, improve our products and the user experience, and develop new offerings. When we maintain and use de-identified data, we will not attempt to re-identify the data unless expressly permitted or required by law.

6. How we share your personal information

We may share your personal information:

With our affiliates and subsidiaries – We may share your personal information among the Comply group of companies and brands whether to operate our business, help manage public sites, deliver our products, develop new products, or market and promote our offerings, which we believe may be of interest to you.
With our customers/Employers in connection with the delivery of products to them.
With our service providers and business partners – We may share your personal information with third parties who help operate our business, manage our public sites, deliver our products, develop new products, as well as advertise and promote our offerings which we believe may be of interest to you.
To comply with laws or protect our rights – This may include responding to a lawful court order, subpoena, or request from a governmental or quasi-governmental agency or regulatory agency or investigative body, including to meet national security or law enforcement requirements, or to enforce our terms and conditions of use, acceptable use policies and the like.
In connection with a merger, acquisition or other reorganization but only to the extent it is reasonable and necessary to do so in relation to such transaction and any related diligence, transfer of assets or other sale of Comply or a portion thereof.
Your choices and rights

You may have certain rights regarding our processing of your personal information under applicable local law. Depending on the jurisdiction in which you live, these may include rights to:

request information about our processing of your information;
request a copy of your personal information;
rectify, correct, or update the information we hold about you;
request deletion of your information;
opt out of “sales” of personal information or “sharing” of personal information for cross-context behavioral advertising purposes (as these terms are defined under applicable law), by clicking here: Cookie Policy | Comply. Where required by law, we also honor requests to opt-out submitted via privacy preference signals recognized under applicable local law, such as the Global Privacy Control;
opt out of certain profiling activities;
restrict or limit our use of your information;
object to our use of your information;
ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances (referred to as data portability);
where you have provided consent, withdraw such consent to our processing of your personal information at any time;
not be unlawfully discriminated against for exercising your rights; and
lodge a complaint with your local data protection authority.

These rights may be limited or denied in some circumstances. For example, we may retain your personal information where required or permitted by applicable law.

To exercise your rights under applicable local law or if you are an authorized agent submitting a request on behalf of an individual under applicable local law, you may submit a request through our online webform or by emailing us at privacy@comply.com. You or your authorized agent may be asked to provide information such as your email address, name, date of submission, and content of submission so that we can verify your identity. Authorized agents may also be required to provide a copy of the consumer’s signed permission authorizing the agent to submit requests on the consumer’s behalf.

To exercise your rights with respect to your personal information that has been provided to Comply through the delivery of our products to customers, please contact your Employer (or, where applicable, that of your spouse / relative). Employers are responsible for providing you with a mechanism to exercise your rights. We will work closely with your Employer to ensure such information is accessible for such purposes.

8. California privacy disclosures

This section applies to the personal information of residents of California and supplements the other sections of this policy.

For information on the categories of personal information that we have collected in the past 12 months and their sources, the purposes for which we process that personal information, and how we disclose that personal information, please refer to Sections 2, 3, 5 and 6 of this policy. We do not use and disclose sensitive personal information as defined under California privacy law.

We may disclose your personal information to third parties for the business purposes outlined in Section 3 of this policy. We also may “sell” or “share” your personal information, as defined by applicable law, with third parties for those business purposes. To opt out of the “sale” or “sharing” of your personal information, click here or the “Do Not Sell or Share my Personal Information” link on our homepage.

In the preceding twelve (12) months, we may have sold or shared your personal information, or disclosed it for a business purpose, to the following categories of third parties:

Category	Examples	Categories of Third Parties to Whom We Disclosed Personal Information for Business Purposes	Categories of Third Parties to Whom We Sold or Shared Personal Information
Identifiers	Name, mailing address, email address, telephone number, IP address	Service providers, Affiliates / Subsidiaries, Employers	Business partners
Contents of communications with us	Messages via contact forms	Service providers, Affiliates / Subsidiaries, Employers	N/A
Internet or other similar network activity	IP addresses, information regarding your interaction with any of our public websites or online products	Service providers, Affiliates / Subsidiaries	Business partners
Professional or employment-related information	Current Employer, salary, job title, experience, skill, or expertise	Service providers	N/A
Education information	Education level and history	Service providers	N/A

We do not have actual knowledge that we sell or share personal information of minors under 16 years of age.

9. Retention

Your personal information will be held for only so long as it is needed for Comply’s business purposes as described above, and in accordance with applicable corporate document retention schedules. These schedules are designed to comply with applicable data privacy and other legislation, and to assist Comply in maintaining business records which it may need to conduct its business and to respond to lawful requests for information in connection with legal claims or disputes.

10. Our security measures

While we cannot guarantee the security of personal information, Comply does employ certain administrative, physical and technical security measures to protect against the loss, misuse and alteration of the information under our control.

We use Transport Layer Security (TLS) encryption to protect your personal information during the transmission of data between your web browser and our servers. Please be aware that any information you send by email is not encrypted and is susceptible to interception over the internet.

While we take steps to protect your personal information, you also play a role in protecting your information, including by not sharing your log-in or password with anyone. Comply will never ask you for this information. If we receive instructions using your log-in and password, we will assume that the instructions have been authorized by you.

11. Our policy towards children

Our public sites and products are not directed to children under the age of 16. We do not knowingly attempt to collect or solicit any information from anyone under the age of 16 through our products or public sites. In the event we become aware we have inadvertently collected personal information from someone under the age of 16, we will delete that information as quickly as possible. If you believe we may have collected personal information from someone under the age of 16, please contact us at privacy@comply.com.

12. International visitors and users

If you are visiting our public site from outside the United States, you expressly and affirmatively consent to our processing of your personal information in the United States. You acknowledge and agree the level of data protection in the United States may not be equal to the level of protection under the laws of other countries. Cross-border transfers of personal information related to citizens of the EEA, EU and UK, including onward transfers, will be subject to standard contractual clauses and/or international data transfer agreements, as applicable.

For more information about international transfer safeguards, please contact us by emailing privacy@comply.com.

13. Links from our public sites or products to others

Comply’s public sites and products may contain links to third-party websites, plug-ins, applications and other online services. When you access these external resources, the owners of those resources may collect certain information about you subject to their own separate policies. Access to those resources is not subject to this policy. Comply is not responsible for the privacy practices or the content of any resources we do not own or directly control, and we encourage you to carefully read the applicable policies and terms and conditions applicable to such resources.

14. Changes to this privacy policy

We may amend this policy from time to time. The use of your personal information is subject to the policy and the terms of use in effect at the time of use. The provisions contained in this policy supersede all previous notices or policies regarding our privacy practices with respect to the public sites and products. Please check this page periodically for updates. Where required by law, we will provide you with additional notice of policy updates.

15. Contacting Comply

If you have any questions, comments, rights requests or any other issues arising under regarding our policy or our website, you can contact us at privacy@comply.com.

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