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ComplyAdvantage: Supplemental Privacy Notice for USA
Last Updated: 30 September 2026
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 (together, the “CCPA”). 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 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. In response to your verified request, we will also give you the categories of sources from which the personal information was collected, the purposes for collecting, selling or sharing it and the categories of third parties with whom we share it.
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 or Sharing
We are required by law to provide transparency about the personal information we “sell” or “share” which, for purposes of the CCPA, means any instance in which we disclose personal information with third parties in exchange for monetary or other valuable consideration (a “sale”) or disclose personal information to a third party for cross-context behavioral advertising (“sharing”). 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” and “sharing” very broadly. To the extent that “sale” or “sharing” under the CCPA is interpreted to include data collection on our Services by third-party analytics or advertising providers, California residents are entitled to opt out of such “sales” or “sharing”. You can make a request to opt out of our sale or sharing of your personal information by emailing us at [email protected] or by clicking the 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.
Right to Limit Use and Disclosure of Sensitive Personal Information
To the extent we use or disclose sensitive personal information for purposes other than those permitted under the CCPA, you have the right to request that we limit that use and disclosure.
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 of personal information (as prescribed by the CCPA) |
What we collect |
Sources we collect from |
Purposes for 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
|
Responding to inquiries
|
Third parties who provide CRM and marketing automation
|
|
California customer records as defined in §1798.80(e) |
Name, address, telephone number, professional activity, recorded telephone conversations |
Directly from consumers
|
Responding to inquiries
|
Customers
|
|
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
|
Provision of the services |
Customers
|
|
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
|
Website analytics vendors
|
|
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
|
Third parties who provide CRM and marketing automation
|
|
Geolocation data |
IP addresses, country from which access is made (except if use a VPN) |
Your use of our website |
Site optimization – analyzing aggregated data to update our site’s content and layout to improve relevance for visitors
|
Third parties who provide CRM and marketing automation
|
|
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
|
Contact individuals in relation to job opportunities and candidacy
|
Third parties who provide applicant tracking systems
|
|
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 Nevada
Nevada Revised Statutes Chapter 603A gives Nevada consumers a right to direct an operator not to make a sale of covered information. For this purpose, a sale is an exchange of covered information for monetary consideration. ComplyAdvantage does not sell covered information for monetary consideration. Nevada residents may submit a verified opt-out request by emailing [email protected].
Supplemental Privacy Notice for Other US States
We are providing this notice to residents of the states listed below on the basis of the following comprehensive consumer privacy laws:
- Colorado Privacy Act 2021 (“CPA”);
- Connecticut Act Concerning Personal Data Privacy and Online Monitoring 2022 (“CTDPA”);
- Delaware Personal Data Privacy Act 2023 (“DPDPA”);
- Indiana Consumer Data Protection Act 2023 (“INCDPA”);
- Iowa Consumer Data Protection Act 2023 (“ICDPA”);
- Kentucky Consumer Data Protection Act 2024 (“KCDPA”);
- Maryland Online Data Privacy Act 2024 (“MODPA”);
- Minnesota Consumer Data Privacy Act 2024 (“MCDPA-MN”);
- Montana Consumer Data Privacy Act 2023 (“MCDPA”);
- Nebraska Data Privacy Act 2024 (“NDPA”);
- New Hampshire Privacy Act 2024 (“NHPA”);
- New Jersey Data Privacy Act 2024 (“NJDPA”);
- Oregon Consumer Privacy Act 2023 (“OCPA”);
- Rhode Island Data Transparency and Privacy Protection Act 2024 (“RIDTPPA”);
- Tennessee Information Protection Act 2023 (“TIPA”);
- Texas Data Privacy and Security Act 2023 (“TDPSA”);
- Utah Consumer Privacy Act 2022 (“UCPA”) and
- Virginia Consumer Data Protection Act 2021 (“VCDPA”).
Defined terms from the main Privacy Notice are used in this Supplemental Privacy Notice for Other US States. Depending on your state of residence and the law that applies, you may have one or more of the rights described below.
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. Where applicable law requires additional information about disclosures to third parties, we will provide that information in the form and to the extent required by that law.
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 rights available to you under an applicable state privacy law, we will not discriminate against you as a result of your decision, except where permitted by law.
Right to Opt Out
We are required by law to provide transparency about personal information we “sell”. The meaning of “sale” varies by state law. Under the VCDPA, a sale is an exchange of personal data for monetary consideration. Under the CPA, CTDPA and certain other applicable state laws, a sale can include an 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 an applicable law interprets “sale” to include data collection on our Services by third-party analytics providers, residents who have an opt-out right under that law may opt out of such “sales”. Where applicable law provides the right, residents may also opt out of targeted advertising and certain profiling in furtherance of decisions that produce legal or similarly significant effects.
If you are a resident of a state identified in this notice as having an opt-out right, you can make a request to opt out by emailing us at [email protected] or by clicking the relevant privacy 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 respond to browser “Do Not Track” settings.
Cookies and Opt-Out Preference Signals
ComplyAdvantage does not set non-essential cookies or similar tracking technologies unless and until a visitor gives consent through the cookie banner presented on its website. Where required by applicable US privacy law, ComplyAdvantage recognises opt-out preference signals, such as Global Privacy Control, as a request to opt out of the sale or sharing of personal information and targeted advertising.
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 link in the footer of our website 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 in accordance with applicable law. Where required, we will confirm receipt of your request within 10 business days. We aim to fulfil valid access, correction and deletion requests within 45 calendar days. We will deal with opt-out requests within the period required by applicable law. Where we extend the response period, we will notify you as required by law.
If applicable state law gives you a right to appeal a decision about your privacy request, you may appeal by emailing [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].