Privacy Policy

Date of last update: Nov. 7, 2022

This privacy policy (policy) describes how the COMPLY brands (we, our or COMPLY) collect, share, use and otherwise process personal information in connection with our various websites (public sites), 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.

We recognize and respect the privacy of our customers and users of our products, as well as to visitors to our public sites. COMPLY has a tradition of upholding high ethical standards in its business practices, including compliance with laws and regulations applicable to the protection of personal information.

This policy applies to all personal information processed by COMPLY including personal information of citizens of the United Kingdom (UK) and the European Economic Area (EEA), including the member states of the European Union (EU), as well as citizens of Iceland, Liechtenstein, Norway and Switzerland.

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:

  1. Information we collect
  2. How we collection information
  3. Child privacy
  4. How we use your information
  5. How we share your information
  6. International visitors and users
  7. How to access or update your information
  8. Our security measures
  9. Links from our public sites and products to others
  10. Changes to this privacy policy
  11. Contacting COMPLY

1. Definitions.

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

  • COMPLY means Compliance Science, Inc. (ComplySci) and its subsidiaries and affiliates, including its and their respective successors, divisions, and brands including RIA in a Box, NRS, illumis and Itegria.
  • Employer means an entity that is authorized to use products from COMPLY through a contract with a customer, and employs individuals who are required to 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. Personal information does not include information that is encoded or anonymized or maintained in a manner that is not reasonably capable of being associated with an individual.

2. Information we collect

In general, you can visit our public sites without telling us who you are or directly providing us any information about yourself. We may collect and use certain information from our visitors for our general business use, for example, to help us administer our business, improve our services or adjust our site to meet our users’ needs and expectations.

The types of personal information we collect include:

  • Contact information – For example, your name, mailing address, email address and telephone number.
  • Information you share – Any information you choose to share with us through our public site and products.
  • Employment 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 and any other personal information you provide regarding your employment history.
  • Any information your employer requires you to share – This may include HR-related information, financial information and other personal information you or your employer directly or indirectly submit to COMPLY for processing through one of our products.
  • Information regarding your device. This may include 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 regarding your location. This may include information from your device including your exact or an approximate location when you access our public site or products.
  • Log and analytics data. This may include 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. If you are using one of our mobile app products, we may also be able to see where you downloaded the app and the frequency with which you use it.

3. How we collect information

a. Information collected automatically
We may gather usage information from any visitor to our public site or products. Our servers may track and collect information about your browser, domain name, IP address and the web pages you visit. This information generally does not identify you. It is aggregated to measure the number of visits, your use of the site, pages viewed and so on. This information lets us see how visitors are finding our public site and also tells us which pages and screens of our public sites and products are visited the most often so we can make our products and information more useful to everyone. We may share experiential information with third parties to help us develop and improve our public sites and products.

b. Information provided to COMPLY
In addition to the information automatically collected by your browser, we may collect personal information through our public sites and/or products.

Public site: There may be areas on our public sites where you may provide personal information to obtain access to certain products including online services not available to anonymous visitors.

Products: Our products offer services to employers to assist with their compliance, legal and governance obligations. Access to our products is restricted to customers within which we have contracts and their affiliates, either or both of which are employers. 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. The employer determines what information is collected, how it is updated and how long it is held.

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 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.

Your employer may directly or indirectly share your personal information under certain circumstances including

  1. Your employer is required to comply with a legal or governance obligation and has sent us your information in connection with compliance effort. Your consent was likely given as a condition of employment. To verify the consent process please contact your employer’s Human Resources department. If you believe your consent was not obtained, COMPLY may remove your data upon written notice from you after we consult with your employer.
  2. COMPLY also may have received your personal information if a member of your household is employed by an employer that is required to comply with a legal or regulatory obligation and has directly or indirectly provided your personal information to COMPLY to us in connection with their compliance efforts. To verify the consent process, please contact the employer’s Human Resources team or similar department. If you believe your consent was not obtained, you may advise COMPLY to remove your personal information from our records and we will consult with the employer and customer regarding any such requests.

Email contact: If your email address is submitted through the public sites or if you send us an email or request information, COMPLY will retain your contact information and use it to respond to your inquiry. We may also use your email and contact information for our general business purposes, including to notify you about product updates and technical notifications (e.g., firewall or IP address changes). You may unsubscribe or change your email address for these communications at any time by following the instructions in each such email. If your email address is in our application, COMPLY may use your email address to respond to your inquiries or communicate with you regarding the application. By providing personal information through our public sites, you explicitly agree to our collection and use of all such information as described in this policy. You agree we may use the personal information you provide to respond to your inquiries or contact you regarding customer service or otherwise related to our public sites and products.

c. Cookies
Our public sites and online products use cookies and other similar technologies to help personalize your online experience and to remember you when you return to the site. A cookie is a text file which is anonymously placed on your hard disk by a webpage server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies or other technologies placed when you visit our site do not personally identify you, but they do allow us to monitor certain statistics, which help us improve our services, such as how many site visitors view certain pages on our website. Some cookies are deleted once you leave our sites (session cookies), while other cookies remain after your leave our public sites and products (persistent cookies) so you are recognized when you return to that public site or product, as applicable.

You can accept or decline most cookies. Some cookies are essential for use of our public sites or products. Others may improve performance and functionality, allow for the collection of analytics and customization, advertising, social networking and more. How you manage cookies may be up to you or your IT department. Many web browsers automatically accept cookies, but you can typically modify your browser setting to decline cookies if you choose. If you choose to decline certain cookies, you may not be able to fully experience the interactive features of our websites or services, such as being automatically recognized as a registered user.

You can also manage your cookie preferences through our public sites. Please click here to review the terms of our cookie policy, including how to manage cookie preferences on our sites. Please be aware deleting cookies may affect your use of or access to certain public sites and products in the future.

4. Child privacy
Our public sites and products are intended for adults. We do not knowingly attempt to collect or solicit any information from anyone under the age of 13 through our products or public sites. In the event we become aware we have inadvertently collected information from someone under the age of 13, we will delete that information as quickly as possible. If you believe we may have collected personal information from someone under the age of 13, please contact us at privacy@comply.com.

5. How we use your information
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 the personal information we collect to help us better maintain and develop our public sites and products to meet the needs of our visitors and customer users. We sometimes use aggregated data (independent of any personal identifiers) for research and commercial purposes. This information may include the areas of our public sites and products are accessed most often.

We use the personal Information we collect through our products only to perform the services for which we are contractually engaged. Each employer submitting personal information to us is responsible for ensuring the information is accurate, complete and current. We may make automated decisions on compliance issues based upon our customer’s instructions.

6. How we share your information

We may share your personal information as:

  • Internally – We may share your personal information among the COMPLY group of companies and brands whether to help manage public sites, delivery of our products, development of new products or marketing and promotion of our offerings, which we believe may be of interest to you.
  • With our customers/employers and their respective affiliates 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 manage our public sites and delivery of our products and development of new products, as well as advertising and promotion of our offerings which we believe may be of interest to you.
  • To comply with laws or protect ourselves – This may include responding to a court order or subpoena, or in connection with a request from a governmental or quasi-governmental agency or regulatory agency or investigative body 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.
  • For other reasons we may describe to you – This may include, but is not limited, to:
    • The personal information provided to us in connection with our products is used only to identify you as part of the products we provide to our customers. It is possible we may be asked by an employer to provide or an employer may provide certain brokers a list of your accounts as part of the products we provide.
    • In cases of onward transfer of personal information related to citizens of the EEA, EU and UK, subject to standard contractual clauses and/or international data transfer agreements, as applicable.

7. 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.

When you and your employer use our products, you and your employer are responsible for compliance with all data security laws and regulations applicable to COMPLY’s collection of personal information 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 consent and providing a mechanism for you to access, update, correct or delete personal information from the products, as described above.

You understand and agree personal information submitted through our public sites and products is transferred to COMPLY in the United States, where it may be used to respond to your requests or deliver products to our customers. If you do not want COMPLY to use any personal information about you which has been collected through our delivery of products to customers, please contact your employer. Failure to grant consent to your employer or a decision to withdraw consent from them could impact COMPLY’s ability to provide products.

8. How to access or update your information

Individuals whose personal information is processed by COMPLY have the right to access, correct or delete their personal information. We have different methods of addressing changes depending on how we collected information:

If personal information about you has been provided to COMPLY through the delivery of our products to customers, please contact your employer. Employers are responsible for providing you a mechanism to update, correct, delete or make changes to your personal information. We will work closely with your employer to ensure such information is accessible for such purposes.
If you provided any personal information through our public site(s) you may contact us at privacy@comply.com.

9. 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 Secure Sockets Layer (SSL) encryption to protect your personal information during the transmission of data between your web browser and our servers. Please be aware 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.

10. 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.

11. Changes to this privacy policy

We may amend this policy from time to time. The use of your personal information is subject to policy and terms of use in effect at the time of use. The provisions contained in this privacy 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.

12. Contacting COMPLY

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