Last Updated: 2/25/2021
1. CONTACT US; RIGHTS AND CHOICES; JURISDICTION-SPECIFIC TERMS
3. INFORMATION THAT GEOCOMPLY COLLECTS
3.1 Information that You Provide
We and/our Service Providers collect information about you when you directly provide information to GeoComply or our Service Providers, such as when you use our Services, communicate with us (including through social media), apply for a job, enter a drawing or contest, subscribe to a newsletter, request or register to receive information, or purchase or register to use a Service. In certain circumstances, you can choose not to provide certain requested information, but then you might not be able to proceed or otherwise receive the full benefit of Services. You may also choose to voluntarily submit other information to us that we do not request, and, in such instances, you are solely responsible for such information. You may opt out of receiving marketing or informational emails from us by clicking on the unsubscribe link at the bottom of those emails. Please note you cannot opt-out of certain non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations. If you have opted-in to receive push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app. You opt-out is limited to the email address or device used and will not affect subsequent subscriptions.
The categories of personal information we collect, including information we have collected in the last 12 months, include:
• identifiers and contact information, including your first and last name, telephone number, email address, and postal address;
• customer records, including your employer and title, billing address, and credit or debit card information;
• characteristics or protected classifications under California or federal law, including gender and country;
• commercial information, including content data, including the content of the messages you send to us;
• Professional or employment history and education information, including education, employment history, references, and other data related to an employment application or contract engagement; and
• inferences, including regarding user preferences and potentially fraudulent activity.
3.2 Information We Collect Automatically
GeoComply, our Service Providers, or Third-Party Services may automatically collect information from you during your use of GeoComply’s Services. The categories of personal information we automatically collect, including information we have collected in the last 12 months, include identifiers such as IP address, internet or other electronic network activity information, and geolocation data.
3.2.2 Other Tracking Technologies. Cookies are not the only way to recognize or track visitors to a website. We and other parties use other, similar technologies from time to time, such as:
18.104.22.168 IP Address. Internet Protocol addresses (IP Address) can be used to identify your devices connected to the Internet and to connect your activities across multiple devices. IP addresses are used to determine your general location including region, city, state, and country, the Internet service provider (ISP) you use, and with your consent, precise location data (such as latitude/longitude data).
22.214.171.124 Mobile Device IDs. Mobile device IDs uniquely identify your mobile device and can be used for analytics on our Services and advertising on third-party apps and websites that serve our ads.
3.3 Information GeoComply Receives from Other Sources
The categories of other sources from which we receive and have received information over the prior 12 months include: you, your Device, services offered via the operating system, our business partners; our Service Providers; Third-Party Services; and publicly available sources such as open government databases or other data in the public domain.
4. HOW GEOCOMPLY USES INFORMATION
• to facilitate your transactions with GeoComply, Third-Party Services or business customers of GeoComply with whom you have a relationship, including processing orders and payments;
• to identify your precise location, verify your identity, or prevent fraud or illegal activity, as requested by you, a Third-Party Service, or one of our business customers with whom you have a relationship;
• to provide you with Services (including to create and manage your accounts for GeoComply Services) and to improve your experience;
• to administer GeoComply’s relationship with you, such as to contact and correspond with you regarding Services you have purchased, downloaded or registered with GeoComply, or regarding your job or contract application or employment;
• to communicate with you regarding your use of the Services or for marketing and promotional purposes
• to process and respond to your inquiries, requests and other communications with GeoComply;
• to provide you with general information regarding GeoComply and its Services;
• to prevent and address fraud, breach of policies or terms, and threats or harm;
• to administer and facilitate your participation in contests and promotions related to GeoComply Services;
• to conduct research, including focus groups and surveys;
• to provide, maintain, protect and improve GeoComply Services and to develop new products, software and services;
• to protect and enforce GeoComply’s legal rights, interests and remedies and to protect the business, operations and customers of GeoComply or other persons. If you are a business customer, GeoComply may develop a confidential profile for you, which will be used by GeoComply to provide Services to you and to facilitate your dealings with GeoComply;
• to fulfill any other purpose at your direction; and
• with notice to you and your consent, in each case as required by applicable law .
Some of our lawful bases for processing your information stem from our customers on whose behalf we provide services. In addition, GeoComply uses information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
4.1.1 Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of our Services will not then work.
4.1.2 Performance Cookies. These cookies allow us and others to count visits and traffic sources so we can measure and improve the performance of the Services and our marketing. They help us to know which pages are the most and least popular and see how visitors move around the Services and interact with our marketing in emails and on other websites. If you do not allow these cookies, we will not know when you have visited the website and will not be able to monitor its performance or the effectiveness of our marketing.
4.1.5 App Technologies. These technologies are included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising off the Services, and provide you with additional functionality.
4.1.6 Location-Identifying Technologies. These technologies are used to collect your location. For example, GPS, Wi-Fi, wireless services, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data, which includes but is not limited to your country, state/province, latitude/longitude, and Wi-Fi AP and Bluetooth beacon strength, may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
4.1.8 Cookie and Tracking Controls. You can disable or block cookies by changing your browser settings so that cookies from our websites cannot be placed on your device (usually found in a ‘settings’ menu in your particular browser). If you choose to delete or reject cookies through your browser settings, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. If you access our website from other browsers, you must change settings in each browser to ensure your choice applies to the data collected when you use those browsers. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad ID at any time through your device settings, which is designed to allow you limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings. You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
5. HOW GEOCOMPLY DISCLOSES INFORMATION
5.1 GeoComply Customers
Some GeoComply Customers require you to utilize our Services as part of your use of their products or services. In doing so, we process your information and disclose it to those Customers.
5.2 Suppliers and Service Providers
5.3 Analytics and Advertising Vendors
GeoComply discloses information to Service Providers for analytics and advertising related purposes. See the “Cookies and Tracking Controls” section above to exercise your choice as to certain analytics and advertising activities..
We may disclose information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
We may disclose information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing efforts.
Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we may disclose information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
5.7 Law Enforcement/Legal Disclosures
5.8 Business Transactions
6. LOCATION OF YOUR INFORMATION
GeoComply and our affiliated companies and service providers process, store and use your information at facilities located in various countries other than your country of residence, including Canada, the United States of America and one or more countries in Europe or Asia. The 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 information without notice. By using the Services, you consent to the transfer of your information to facilities located in other countries and the processing and storage of your information at those facilities. For personal data transferred from the European Union, the United Kingdom, or Switzerland, we will provide appropriate safeguards, such as through the use of standard contractual clauses.
7. RETENTION OF INFORMATION
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 backup or archival systems for a reasonable period.
8. PROTECTION OF INFORMATION
GeoComply uses reasonable safeguards – including administrative, physical, and technical security and safeguarding measures – appropriate to the sensitivity of the 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.
9. ACCURACY AND ACCESS TO INFORMATION
GeoComply will rely on you to ensure that the information that you provide to GeoComply is as accurate, complete, and up to date as necessary for the purposes for which GeoComply uses the information. You will promptly notify GeoComply of any changes to your information using the procedures made available for that purpose by GeoComply.
In certain jurisdictions, you may have the right to 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 as set forth in the “Contact Us” section 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.
10. AGGREGATED OR DE-IDENTIFIED INFORMATION
The Services are intended for general audiences, and are not directed at children. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, contact us at privacy@GeoComply.com. We will remove the personal information in accordance with COPPA.
12. YOUR CALIFORNIA PRIVACY RIGHTS
In California, you may have additional rights. This Section 12 only applies to you if you are a California resident. The California Consumer Privacy Act (CCPA) provides the right to opt-out and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
If the information that we collected about you is within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor (“HR Data”); or (ii) in the context of a business transaction or communication with GeoComply, this “Your California Privacy Rights” section does not apply to you, except that the “Notice at Collection” section below does apply to HR Data.
12.1 Notice at Collection
The categories of personal information enumerated in the CCPA we have collected from individuals in the past twelve (12) months are described in Section 3, “Information that GeoComply Collects.”
For more information on our disclosure practices, please see Section 5, “How GeoComply Discloses Information.” For more information on our collection practices, as well as the sources and purposes for which we collect this information, please see Section 3, “Information that GeoComply Collects” and Section 4, “How GeoComply Uses Information.”
12.2 CCPA Privacy Rights
California “Consumers” (as defined in the CCPA) have the right to exercise certain privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.
In general, we begin the identity verification process by confirming that you are the owner of the email address with which you made the request and that it matches up with an email in our system. However, we reserve the right to ask you to provide additional information in order to help verify your identity.
Some personal information we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
In order to make a request, please contact us below as described in the “Contact Us” section. We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.
If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.
a. The Right to Know
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
The categories of PI we have collected about you.
The categories of sources from which we collected your PI.
The business or commercial purposes for our collecting or selling your PI.
The categories of third parties to whom we have shared your PI.
A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
ii. Specific Pieces
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
b. The Right to Deletion
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.
You may alternatively exercise more limited control of your PI by instead by canceling or modifying our email marketing communications you receive from us. You can do so by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
c. The Right to Opt Out of Sale of PI
GeoComply does not knowingly ”sell,” as that term is defined under the CCPA, the personal information of minors under 16 years of age who are California residents.
We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute GeoComply as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.
d. The Right to Non-Discrimination
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.
12.3 Shine the Light Law
Under California Civil Code Section 1798.83, also known as the “Shine the Light” law, if you are a California resident, you may request information about whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of such a request, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California residents may request further information about our compliance with this law by contacting us at the address in the Contact Us below, with “Shine the Light” in the subject line. We are not responsible for notices that are not labeled or sent properly or do not have complete information. Non-affiliated third parties are independent from GeoComply; if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
13. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE AND THE UNITED KINGDOM
Data protection laws in the European Economic Area and the United Kingdom distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). GeoComply acts as a controller with respect to personal data collected as you interact with our Services. In some instances, GeoComply acts a processor on behalf of a GeoComply customer, which is the controller. Any questions that you have relating to the processing of personal data by GeoComply as a processor should be directed to the relevant GeoComply customer.
13.2 Lawful Basis for Processing
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to service providers, partners, or GeoComply customers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
13.3 Your Data Subject Rights
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section below and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request. If personal data about you has been processed by us as a processor on behalf of a client and you wish to exercise any rights you have with such personal data, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal data. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you may contact our Chief Privacy Officer using the contact information available in the “Contact Us” form below. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.
14. ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact our Chief Privacy Officer at set out in the “Contact Us” section below.
15. OTHER MATTERS
15.1 Changes to this Policy
15.2 Contacting Us