Loading...

Privacy Policy

Home / Privacy Policy

 

Your privacy is important to GeoComply Solutions (“GeoComply”). This Privacy Policy explains how GeoComply collects, uses, discloses, retains and deletes personal information, including information collected by GeoComply through GeoComply’s website and GeoComply’s products, software and services.

Updated May 25, 2018

Application of this Privacy Policy

This Privacy Policy applies to personal information that GeoComply collects directly from individuals in connection with their interaction with GeoComply and their use of GeoComply products, software and services.

This Privacy Policy does not apply to personal information collected by a GeoComply customer and provided by the customer to GeoComply in connection with the customer’s use of GeoComply’s products, software and services. GeoComply relies on its customers to comply with all applicable laws, including obtaining all required consents and permissions, regarding the collection, use, disclosure, retention and deletion of personal information collected by the customer and provided to GeoComply. GeoComply has no control over, or responsibility or liability for, any GeoComply customer’s collection, use, disclosure, retention and deletion of personal information. Each GeoComply customer’s collection, use, disclosure, retention and deletion of personal information, and GeoComply’s use of that personal information in accordance with permissions granted by the customer, are governed by the customer’s own privacy policy (not this Privacy Policy).

Your Consent

By providing GeoComply with your personal information, you consent to the collection, use, disclosure, retention and deletion of that information in accordance with this Privacy Policy and as otherwise permitted by applicable law.

Personal Information

In this Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name, postal address, telephone number or email address.

Information That GeoComply Collects

a)   Information You Provide to GeoComply

You may be asked to voluntarily give your personal information to GeoComply when you interact directly with GeoComply, including when you subscribe to a GeoComply newsletter, register to receive information from GeoComply or purchase or register to use a GeoComply product, software or service. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction with GeoComply or otherwise receive the full benefit of GeoComply products, software or services.

b)   Automated Collection

GeoComply may automatically collect certain information regarding your use of GeoComply’s website or services, such as the dates and times that you access a service, the browsers, operating systems, software and devices that you use to access a service and details of your use of a service.

If you connect a device or third-party product to GeoComply software (such as a mobile app) or a GeoComply service, then the software or service may automatically collect certain information regarding the product and your use of the product.

If you install GeoComply software (such as a mobile app) on your computer or mobile device, then the settings of the software and device may permit the automatic transmission to GeoComply of diagnostic information and other information regarding your computer or mobile device and your use of the software.

GeoComply’s website, online services, email messages and advertisements may use “cookies” and other similar technologies to assist GeoComply to improve products, software and services and customer communications. GeoComply may use information collected through technological means to recognize you as a user of GeoComply’s website or services and to facilitate and improve your use of GeoComply’s website and services. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of GeoComply’s website, products, software and services.

Much of the information that is automatically collected by technological means is non-personal information (because the information does not identify you), and GeoComply will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

How GeoComply Uses Personal Information

GeoComply uses your personal information collected by GeoComply for purposes relating to or arising from your relationship and transactions with GeoComply and as otherwise set out in the Privacy Policy or permitted by applicable law, including:

  • to provide you with products, software and services (including to create and manage your accounts for GeoComply services) and to improve your experience;
  • to administer GeoComply’s relationship with you, including to contact and correspond with you regarding products and software you have purchased, downloaded or registered with GeoComply and GeoComply services for which you have registered;
  • to facilitate your transactions with GeoComply, including processing orders and payments;
  • to process and respond to your inquiries, requests and other communications with GeoComply;
  • to provide you with general information regarding GeoComply and its products, software and services, to the extent permitted by applicable law;
  • to administer and facilitate your participation in contests and promotions related to GeoComply products, software and services;
  • to maintain, protect and improve GeoComply products, software and services and to develop new products, software and services; and
  • to protect and enforce GeoComply’s legal rights, interests and remedies and to protect the business, operations and customers of GeoComply or other persons.

GeoComply may develop a confidential profile for you, which will be used by GeoComply to provide products, software and services to you and to facilitate your dealings with GeoComply.

How GeoComply Discloses Personal Information

GeoComply discloses your personal information for purposes relating to or arising from your relationship and transactions with GeoComply and as otherwise set out in this Privacy Policy or permitted by applicable law.

a)  GeoComply Customers

If you are authorized to use GeoComply products, software or services by or on behalf of a GeoComply customer, then GeoComply may disclose your personal information (including information regarding your use of GeoComply products, software and services) to the GeoComply customer and the GeoComply customer’s personnel.

b)  Suppliers and Service Providers

GeoComply may disclose your personal information to GeoComply’s suppliers and service providers (including payment processors) to assist GeoComply in the provision of products, software and services to you, to provide products and services to GeoComply, to assist GeoComply to use your personal information in accordance with this Privacy Policy, and as otherwise permitted by applicable law.

c)  Law Enforcement/Legal Disclosures

GeoComply may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. GeoComply may disclose your personal information to law enforcement agencies or other organizations if GeoComply reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if GeoComply reasonably believes the disclosure is necessary or appropriate to protect and enforce GeoComply’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of GeoComply or other persons (including to enforce any of the terms of use, terms of service or other agreements that govern access to or use of any GeoComply products, software and services). GeoComply has no control over, or responsibility or liability for, the use, disclosure, retention and deletion of your personal information by the agencies, organizations or other persons to whom GeoComply discloses the information in the foregoing circumstances, and the use, disclosure, retention and deletion of the disclosed information by those agencies, organizations or other persons is not subject to this Privacy Policy.

d)  Business Transactions

GeoComply may disclose your personal information in connection with a proposed or actual business transaction in which GeoComply is involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of GeoComply’s business or assets), but GeoComply will require the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

Location of Personal Information

GeoComply may process, store and use your personal information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing GeoComply with your personal information, you consent to the transfer of your personal information to facilities located in other countries and the processing and storage of your personal information at those facilities.

Retention of Personal Information

GeoComply retains your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and as necessary to comply with GeoComply’s legal obligations or enforce or protect GeoComply’s legal rights, or a longer period required or permitted by applicable law. GeoComply will delete or dispose of your personal information when GeoComply is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy or for legal compliance purposes.

Some of GeoComply’s services may be designed to protect certain information from accidental or malicious destruction. Because of that, if you delete your information from those GeoComply services residual copies of the information may be retained in GeoComply’s systems for a reasonable period.

Protection of Personal Information

GeoComply uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in GeoComply’s possession or under GeoComply’s control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be eliminated and GeoComply cannot guarantee that your personal information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

Accuracy and Access to Personal Information

GeoComply will rely on you to ensure that your personal information that you provide to GeoComply is as accurate, complete and up to date as necessary for the purposes for which GeoComply uses the personal information. You will promptly notify GeoComply of any changes to your personal information using the procedures made available for that purpose by GeoComply.

You may reasonably request access to your personal information collected by GeoComply and information about GeoComply’s use, disclosure, retention and deletion of that personal information by submitting a written request to GeoComply’s Chief Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information amended as appropriate. You may be required to pay a reasonable fee for access to your personal information. GeoComply may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for which access is not required by applicable law.

Non-Personal Information

GeoComply creates and collects non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized, so that it no longer relates to an identifiable individual. GeoComply may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then GeoComply will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined.

Other Matters

a)  App Store Operators:If you wish to obtain a copy of a GeoComply mobile app from an online app store operated by an unaffiliated third party (such as Apple and Google), then you will be required to disclose your personal information to the app store operator in order to download a copy of the mobile app. GeoComply has no control over, or responsibility or liability for, the collection, use, disclosure, retention and deletion of your personal information by any app store operator. Each app store operator’s use, disclosure, retention and deletion of your personal information are governed by the app store operator’s own privacy policy (not this Privacy Policy).

b)  Business Contact Information:To the extent permitted by applicable law, the provisions of this Privacy Policy concerning personal information do not apply to business contact information (such as your name, position or title, business address, business telephone number, business fax number and business email address) that enables you to be contacted at a place of business or is used for the purpose of communicating or facilitating communication with you in relation to your employment or business.

c)  Other GeoComply Agreements:The agreements (including any subscription agreement, license agreement, end user agreement, terms of service or use) that you accept when you order, register or use GeoComply products, software or services contain important provisions, including provisions disclaiming, limiting or excluding GeoComply’s liability and provisions determining the applicable law and exclusive jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or GeoComply’s collection, use, disclosure, retention and deletion of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

d)  Changes to this Policy:GeoComply may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on GeoComply’s website. GeoComply’s collection, use, disclosure, retention and deletion of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with GeoComply subsequent to any changes to this Privacy Policy will signify your consent to the collection, use, disclosure, retention and deletion of your personal information in accordance with the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

e)  English Language:  You and GeoComply have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressement que cette Politique de Confidentialité et tous les documents qui s’y rapportent soient rédigés en anglais.

d)  Contacting GeoComply’s Chief Privacy Officer:If you have any comments or questions about this Privacy Policy or how GeoComply deals with your personal information collected by GeoComply, please contact GeoComply’s Chief Privacy Officer by mail or email at: GeoComply – Chief Privacy Officer, Suite 1530, 666 Burrard St, Vancouver, BC, Canada, V6C 2X8 or

email: privacy@GeoComply.com. If you have questions about how a GeoComply customer collects, uses, discloses, retains or deletes personal information, please contact the GeoComply customer directly.