Last updated: June 30, 2023

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”), GeoComply Solutions Inc. (“GeoComply,” “we,” or “us”) is providing the following details regarding the categories of Personal Information that we collect, use and disclose about California residents, including (1) personnel and agents of our customers, (2) individuals who interact with us directly (e.g., through our websites, Services, events, or social media), and (3) job applicants. This California Privacy Notice does not apply to our employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role at GeoComply. This California Privacy Notice also does not apply to end users of customers of our B2B solutions and services (the “Services”). Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

Categories of Personal Information Collected and Disclosed

The chart below sets out the CCPA categories of Personal Information we collect about California residents, as well as the categories of Personal Information we have collected and disclosed for our operational business purposes within the last twelve (12) months.

Personal Information collected				Disclosed to which categories of third parties for operational business purposes
Category	Collected from customer personnel	Collected from those who directly interact with us	Collected from job applicants
Identifiers	Name, contact information, IP address, account name and online identifiers	Name, contact information, IP address and online identifiers	Name, contact information, IP address and online identifiers	Our affiliated entities and trusted third-party service providers
Personal information as defined in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, contact information, and employment information (organization name, job title, and business unit or department)	Name, contact information, and employment information (organization name, job title, and business unit or department)	Name, contact information, education history, employment, employment history, government identification (e.g., Social Security number, driver’s license, or state-issued identification card as appropriate)	Our affiliated entities and trusted third-party service providers
Protected classification characteristics under California or federal law	None	None	Age, gender, requests for physical or mental accommodations (all optional to provide)	Our affiliated entities and trusted third-party service providers
Commercial information	Records of products or Services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.	None	N/A	Our affiliated entities and trusted third-party service providers
Biometric information	None	None	None	N/A
Internet or other similar network activity	Interaction with our Services	Interaction with our digital properties or advertisements	Interaction with a job posting	Our affiliated entities and trusted third-party service providers
Geolocation data	Approximate location	Approximate location	Approximate location	Our affiliated entities and trusted third-party service providers
Audio / visual information	Audio or visual information, such as web meetings and webinars	Audio or visual information, such as web meetings and webinars	Audio or visual information, such as video interviews	Our affiliated entities and trusted third-party service providers
Professional or employment-related information	Organization name, job title, and business unit or department	Organization name, job title, and business unit or department	Employment history, including for example employer(s), positions held, duration of employment, and work location; as well as background checks / verification of candidates who progress to the final stages of consideration	Our affiliated entities and trusted third-party service providers
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R Part 99))	None	None	None	N/A
Inferences drawn from personal information listed above to create a profile	None	None	None	N/A
Sensitive Personal Information	None	None	Citizenship and immigration status, and potentially Social Security number, driver’s license or state identification card number	Our affiliated entities and trusted third-party service providers

Data Collected and Disclosed through our Services

The personal information identified in the table below are from customers or individuals who are using GeoComply products and services.

Personal Information collected				Disclosed to which categories of third parties for operational business purposes
Category	Collected from customer personnel for compliance licensing	Collected from Player Location Check (PLC), Location Validator (GLV), Core for location verification	Collected from ID Comply for Identity Verification
Identifiers	Name, contact information, IP address, account name and online identifiers	IP address, device ID, pseudonym, device fingerprint	Name, contact information, email address, social security number, selfie-photo	Our customers, our affiliated entities, and trusted third-party service providers
Personal information as defined in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, contact information, criminal history, employment history, passport, licenses, birth certificates, marriage/divorce info, financial information, education, tax information, and vehicle registrations.	None	Government ID	Our customers, our affiliated entities, and trusted third-party service providers
Protected classification characteristics under California or federal law	National origin, ethnicity, marital status, sex, age, and military and veteran status	None	None	N/A
Commercial information	Records of personal property.	None	None/td>	N/A
Biometric information	None	None	Yes	N/A
Internet or other similar network activity	Interaction with our Services	Interaction with our Services and our Customers’ Services	Interaction with our Services and our Customers’ Services	Our customers, our affiliated entities, and trusted third-party service providers
Geolocation data	Approximate location	Precise location	Precise location	Our customers, our affiliated entities, and trusted third-party service providers
Audio / visual information	None/td>	None	None	N/A
Professional or employment-related information	Organization name, job title, and business unit or department	None	None	Our customers, our affiliated entities, and trusted third-party service providers
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R Part 99))	None	None	None	N/A
Inferences drawn from personal information listed above to create a profile	None	Identifying devices that are masking their location on the request of the Customer or by individuals accessing product demonstrations.	None	N/A
Sensitive Personal Information	Citizenship and immigration status, Social Security number, driver’s license or state identification card number, racial or ethnic origin	None	Social Security Number , driver’s license, government identification	Our customers, our affiliated entities, and trusted third-party service providers

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Sources of Personal Information

We collect Personal Information from:

• Our interactions with you, such as through our Services, websites, surveys and questionnaires, emails, social media, and any other online or offline interactions, such as when you contact us via phone or attend one of our events;
• When you apply for a job, including through our Careers Site; and
• Our affiliates and publicly available online sources.

Purposes for the Collection and Use of Personal Information

We collect, use, or share Personal Information for the purposes of operating, managing, and maintaining our business, providing our Services, and accomplishing our business purposes and objectives, including:

• Providing and securing our Services;
• Evaluating candidates for job openings, deciding whether to make an employment offer, and keeping records related to recruiting;
• Communicating with you;
• Improving our websites, applications, and Services;
• Internal business purposes;
• Carrying out corporate transactions, such as mergers, joint ventures or acquisitions;
• Complying with law, legal process, and internal policies, and exercising and defending legal claims; and
• Investigating, preventing, or taking action on illegal activities, fraud, or threats to or abuse of rights, property, personal safety, the security of our Services, the Services infrastructure, or the Internet.

Purposes for the Collection and Use of Sensitive Personal Information

We may use Sensitive Personal Information for purposes of performing services for our business, performing Services as requested by you, ensuring security and integrity, short term transient use such as displaying first party non-personalized advertising, servicing accounts, providing customer service, verifying customer information, conducting pre-employment checks on candidates for employment with us, and activities relating to quality and safety control or product improvement.

We do not sell Personal Information, including Sensitive Personal Information, or share it with third parties for cross-context behavioral advertising, and we have not sold or shared it for cross-context behavioral advertising in the preceding 12 months. This includes the Personal Information of minors under 16 years of age.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you continue to be a customer of our Services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Individual Rights and Requests

If you are a California resident, you may make the following requests:

1. You may request that we disclose to you the following information covering the 12 months preceding your request:
   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   2. The business or commercial purpose for collecting Personal Information about you; and
   3. The categories of Personal Information about you that we have disclosed, and the categories of third parties to whom we disclosed such Personal Information.
2. You may request to correct inaccuracies in your Personal Information.
3. You may request to have your Personal Information deleted.
4. You may request to receive the specific pieces of your Personal Information, including a copy of the Personal Information you provided to us in a portable format.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Where GeoComply acts as a “Service Provider” or “Processor” under applicable data protection and privacy laws, you are required to direct your request to our Customers.

Where GeoComply has collected your information directly without the involvement of our Customers, to make a privacy request, please contact us at privacy@geocomply.com. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests.  If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.  If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.”  As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent.  In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

Changes to this Privacy Notice

We may change or update this Privacy Notice from time to time.  When we do, we will post the revised Privacy Notice on this page with a new “Last Updated” date.

Contact Us

If you have any questions regarding this Privacy Policy, please contact us at privacy@geocomply.com

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