ENComplyAdvantage: Supplemental Privacy Notice for USA
Last Updated: 19 July 2023
For matters not covered in the Supplemental Privacy Notice for the USA, please refer to the Privacy Notice available here.
Supplemental Privacy Notice for California
Additional Rights for California Residents
We are providing this notice on the basis of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CPPA”). 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 CPPA 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 CPPA.
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 Correct
You have the right to request that we correct inaccurate personal information that we store about you, subject to certain exceptions.
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.
Right to Data Portability
You have the right to obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format.
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 |
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.
Supplemental Privacy Notice for Colorado, Connecticut, Nevada and Virginia
We are providing this notice to Colorado, Connecticut, Nevada and Virginia residents on the basis of:
- Colorado Privacy Act 2021 (“CPA”);
- Connecticut Act Concerning Personal Data Privacy and Online Monitoring 2022 (“CTDPA”);
- Nevada Revised Statutes Chapter 603A 2019 (“Chapter 603A”);
- Virginia Consumer Data Protection Act 2021 (“VCDPA”).
Defined terms from the main Privacy Notice are used in this Supplemental Privacy Notice for Colorado, Connecticut, Nevada, Virginia.
Right to Access
Subject to certain exceptions, you have the right to confirm whether we are processing your personal data and to access your personal data.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.
Right to Delete
Subject to certain exceptions, you have the right to delete personal data provided by or obtained about you.
Right to Portability
You have the right to obtain a portable copy of the personal data that you provided to us.
Right to Non-Discrimination
If you choose to exercise any of your rights under the CTDPA or VCDPA we will not differentiate our services as a result of your decision.
Right to Opt Out
We are required by law to provide transparency about the personal information we “sell”. For purposes of the Chapter 603A and VCDPA a “sale” means any instance in which we share personal information with third parties in exchange for monetary consideration. Pursuant to the CPA and CTDPA a “sale” is the exchange of personal data for monetary or other valuable consideration by a controller to a third party.
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. To the extent that “sale” under the CPA and CTDPA is interpreted to include data collection on our Services by third-party analytics providers, Colorado and Connecticut residents are entitled to opt out of such “sales”. Colorado, Connecticut, Nevada and Virginia residents also have the right to opt out of targeted advertising (as defined under the applicable law).
If you are a resident of Colorado, Connecticut, Nevada or Virginia, 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.
Clauses applicable to all states covered in the Supplemental Privacy Notice for the USA
Financial Incentives
We do not offer financial incentives in exchange for providing your personal information.
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.
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.
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. 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.
We will respond to your request consistent with the applicable regulations. 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 under the CPPA or 60 days under Chapter 603A. However, in some circumstances, we may take up to 90 calendar days to fulfill some access and deletion requests.
Connecticut, Colorado and Virginia residents have the right to appeal our decision regarding a request related to their rights by email sent to [email protected].
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 applicable laws. 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.
Contact Us
If you have any questions regarding this Supplemental Privacy Notice for the USA, or our privacy practices, you can contact us at [email protected] or [email protected].