A Guide to Anti-Money Laundering for Crypto Firms

ComplyAdvantage: Supplemental Privacy Notice for California

Last Updated: 16 June 2022

Additional Rights for California Residents

Defined terms from the main Privacy Notice are used in this Supplemental Privacy Notice for California. Any undefined terms below (I.e., “personal information,” “consumer,” and “sale”) shall have the meaning ascribed to them in the California Consumer Privacy Act (“CCPA”) solely for the purpose of this Supplemental Privacy Notice for California. Please also note that certain information found publicly on the internet is not considered personal information and may not be protected under the CCPA.

The CCPA grants certain rights to California residents regarding their personal information. These rights are not absolute and may be subject to exceptions, exemptions and verification. For instance, we may deny a request if honoring it would reveal personal information about another person or if you ask us to delete information which we are required or permitted by law to keep, such as information used to protect against fraudulent or illegal activity.

Right to Access

You can make a request to access the categories or specific pieces of personal information we have collected, used, or shared about you in the past twelve (12) months. Along with your verified request, we will give you any categories of sources from which the personal information is collected; the purpose for collecting, selling, or sharing; and any categories of third parties with whom we share such personal information.

Right to Delete

You may make a request to delete any personal information we have collected from you, subject to certain exceptions.

Right to Opt-Out of Sale

We are required by law to provide transparency about the personal information we “sell” which, for purposes of the CCPA, means any instance in which we share personal information with third parties in exchange for monetary or other valuable consideration. ComplyAdvantage provides software solutions to help clients prevent and detect financial crime and meet their KYC and AML compliance obligations. Aside from the provision of personal information required to provide these services, ComplyAdvantage does not otherwise share personal information with third parties for monetary value. However, the CCPA defines “sale” very broadly. To the extent that “sale” under the CCPA is interpreted to include data collection on our Services by third-party analytics providers, California residents are entitled to opt out of such “sales”. You can make a request to opt out of our sale of your personal information by emailing us at [email protected] or by clicking the “Do Not Sell My Personal Information” link in the footer of our website. Please note that certain information may be exempt from such requests in some circumstances.

Right to Non-Discrimination

If you choose to exercise any of your rights under the CCPA, we will not differentiate our services as a result of your decision.

Financial Incentives

We do not offer financial incentives in exchange for providing your personal information.

How to Exercise Your Rights

To exercise the rights described above, requests may be made through the Do Not Sell My Personal Information link or by emailing: [email protected]
To make a valid request, you must describe it with sufficient detail to allow us to properly understand what type of request you are making (i.e., which rights you are exercising) and verify the personal information related to you. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with the personal information in our possession.

We will respond to your request consistent with the CCPA. This includes confirming receipt of your response within 10 business days. We aim to fulfill access and deletion requests within 45 calendar days; 15 business days for opt-out requests. However, we may take up to 90 calendar days to fulfill some access and deletion requests.

You may be required to submit proof of your identity for your request to be processed as a verifiable consumer request. Such information may include your name, home address, phone number, or driver’s license. This information will be used only for the purposes of verifying your identity and processing your request.

Use of an Authorized Agent

You can appoint a person or a business entity registered with the Secretary of State to act on your behalf.  In order to do so, you must provide direct confirmation that you have granted the authorized agent the authority to act on your behalf, or a power of attorney as authorized in the CCPA.  We may request more information from you or the authorized agent if needed to verify the authorized agent’s identity or to avoid any breach of security, or instances of fraud.

Minors

We do not knowingly collect personal information of minors under the age of 16, nor are our services developed for, offered to, or directed at children under the age of 16. If you believe that we have collected information of a child under the age of 16, please contact us and we will take appropriate action.

Categories Collected, Used, and Shared

We collect and share the following categories of personal information from the corresponding sources and purposes set forth in the table below:

Categories 

(as prescribed by the CCPA)

What we collect Sources We Collect From Purposes Behind Collection, Use, and Sharing Categories of Third Parties We Disclose To for Business Purposes
Identifiers  Name, alias, online identifier, internet protocol address, account name, email, phone numbers, bank account number Directly from individuals

Purchased from contact databases 

Information made publicly available by the individual  

Recruiters

Feedback from interviews and assessments 

Responding to inquiries

Communicating with you regarding our products and services 

Marketing activities 

Site optimisation 

Contact and consider you in relation to a job vacancy

Third parties who provide CRM and marketing automation

Cloud services provider

Website analytics vendors

Third parties who provide online forms

Customer support servicing tools

Applicant tracking system, aptitude test providers, third party background check providers

Government and legal services providers involved in the visa application process (where applicable)

California Customer Records as defined in §1798.80(e)  Name, address, telephone number, professional activity, recorded telephone conversations Directly from consumers 

Directly from job candidates and employees

Information made public by the individual 

Publicly available corporate registries 

Responding to inquiries

Marketing activities, taking steps prior to entering a contract, and fulfillment of a contract

Sales training purposes (call recordings only)

Feedback requests

Contacting individuals in relation to job opportunities and candidacy

Assessing individuals for suitability for vacancies

Customers

Hosting and cloud storage providers 

Vendors who monitor the accuracy and performance of our data

Third parties who provide customer database, sales and marketing services 

Online form providers

Customer support/servicing tools

Debt collection service providers 

Protected Class Information Under California and Federal Law National Origin  Publicly available government lists covering sanctions, the prevention and detection of unlawful acts, and other protective functions. 

Publicly available websites 

Publicly available news articles

Publicly available corporate registries 

Provision of the services  Customers

Hosting and cloud storage providers 

Third parties who monitor the accuracy and performance of our data

Commercial Information Data on how you use our website, products or services purchased, obtained, or considered, or other purchasing or consuming histories  Your use of our website Site optimisation – analysing aggregated data to update our site’s content and layout to improve relevance for visitors.

Improvement of marketing and services

Website analytics vendors 

Third parties who provide online forms 

Biometric Information N/A
Online Identifiers IP address, unique identifiers tied to cookies, browsing history, search history and information regarding a consumer’s interaction with an internet website, application or advertisement, the means you use to visit (browser version, time zone, operating system, etc.), how long your page views and visits last, the frequency of your visits, and information on how you navigate the site. Your use of our website Site optimisation – analysing aggregated data to update our site’s content and layout to improve relevance for visitors.

 

Improvement of marketing and services

Third parties who provide CRM and marketing automation

 

Website analytics vendors

Geolocation Data IP addresses, country from which access is made (except if use a VPN) Your use of our website Site optimisation – analysing aggregated data to update our site’s content and layout to improve relevance for visitors.

 

Improvement of marketing and services

Third parties who provide CRM and marketing automation

 

Website analytics vendors

Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information Call recordings of voice and images  Direct from individuals Sales training Third party call recording providers, CSM tools, cloud service provider
Professional or Employment-Related Information Professional registration numbers, qualifications, place of study, references, previous roles   Directly from job candidates and employees

Referees

Publicly available websites 

Third party recruitment consultants 

Contact individuals in relation to job opportunities and candidacy

Assess individuals for suitability for vacancies

Third parties who provide applicant tracking systems

Providers of any aptitude testing systems used as part of the hiring process

Third-party background check providers, cloud file storage systems, external recruiters

Government and legal service providers as required as part of a visa application process

Educational Information N/A
Inferences  N/A

 

Do Not Track Signals

ComplyAdvantage does not currently change its behavior in response to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to learn how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how businesses should respond to “do not track” signals, we will re-assess how to respond to those signals.

Shine a Light

California Civil Code Section 1798.83, also known as the “Shine a Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and address of all third parties with which we shared personal information in the immediately preceding calendar year. If you would like to make such a request, please submit your request in writing to us using the information provided below.

Contact Us

If you have any questions regarding this Supplemental Privacy Notice for California, or our privacy practices, you can contact us at [email protected] or  [email protected].