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Privacy Policy

1. Introduction

1.1 This data protection and privacy policy (the “Policy”) describes how ComplyTeq AG (“us”, ”we” or ”our”) collects and processes personal data relating to the purchase of services, membership, products or general use of our website and mobile applications.

1.2 The Policy is prepared and made available to comply with the general data protection regulation act (2016/679 of 27 April 2016) (the ”GDPR”) and the rules included herein on information to be provided to you (”user”, “data subject” or “person”).

2. Collecting personal data with cookies

2.1 By visiting and using our website(s), cookies are collected and used on the basis of consent. Information in these cookies include IP address, location at login. (hereinafter "Cookiedata").

2.2 Cookiedata is used for to perform targeted marketing, improvement of the website(s) and the user experience.

2.3 Use of cookies for the purpose of collecting personal data is in accordance with the Cookie Order (No. 1148 of 9 December 2011), section 3.

2.4 If you wish to limit or decline the cookies placed on your computer when visiting our website you can do so at any time by changing your browser settings. However, you should be aware that if you decline or reject cookies it will impact the functionality of the website which means that there are features on the website that you will not be able to see (such as but not limited to videos, pictures etc.). Any browser allows you to delete cookies collectively or individually. How this is done depends on the browser used. Remember to delete the cookies in all browsers, if you use several different browsers.

2.5 We disclose and/or share Cookie Data with Information collected with cookies is passed on to Google LLC, as these cookies are placed by Google LLC (’Google Analytics’). If you watch a YouTube video on our website or elsewhere, information collected with cookies will also be passed on to YouTube. We do not actively disclose information collected with cookies.


3. Types of personal data processed

3.1 We process personal data about you when necessary and in accordance with the applicable legislation. Depending on the specific circumstances, the processed personal data include the following types of personal data: first name, middle name(s), last name(s), title, address(es), telephone number(s), username, email(s), citizenship(s), tax residency, Identity documents and data included herein (passports, driver licenses, national ID cards, health cards), country of birth, greencard status.

3.2 Personal data is either collected directly from you or from external sources. Personal information from external sources is collected either from publicly available registers and service providers with APIs for public registers or from paid private third party suppliers.

3.3 If we need to collect more personal data than what is specified above, we will inform about this. Such information may be provided by our updating of this Policy.

3.4 We sometimes hosts webinars which are recorded and will be made available online. The names of the webinar participants may appear in the recording.

You can read more about our Data Processing Agreements here: https://www.complyteq.com/dpa

4. Purposes for processing the personal data

4.1 We only process personal data for legitimate purposes in accordance with the GDPR. Depending on the circumstances, the personal data is processed for the following purposes:

a) To deliver products or services to a user, customer or member.

b) To process the data on behalf of companies ‘subscribing’ to your personal data through ‘connections’.

c) To answer enquiries or complaints from users, customers or members.

d) To provide service messages and information to users, customers or members.

e) To store personal data to comply with applicable legislation requirements such as bookkeeping acts.

f) To send newsletters via e-mail.

g) To give support and service messages, including answering questions and complaints and send updates about our products and services.

4.2 External companies (”subscriber”) can subscribe to your data through us and you will then allow us to pass your personal data to them for their specific use-case as per §4.1.a upon you accepting such a (“connection or “subscription”) request from the subscriber.

4.3 You may at any point request a termination of a connection and §7 will enact

5. Legal basis for processing personal data

5.1 We only process your personal data when we have a legal basis to do so in accordance with the GDPR. Depending on the specific circumstances, the processing of personal data is done on the following legal basis:

a) The processing is necessary for the performance of a contract to which the data subject is party, cf. the GDPR, article 6(1)(b), the first indent.

b) The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract, cf. the GDPR, article 6(1)(b), last indent.

c) The processing is necessary for compliance with applicable legislation, cf. the GDPR, article 6(1)(c).

d) The processing is necessary for the purposes of the legitimate interests where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, cf. the GDPR, article 6(1)(f).

6. Disclosure and transfer of personal data

6.1 We only pass on personal data to others and ‘connections’ when the law allows it or requires it, including when relevant and asked to do so by you or a data controller when applicable.


7. Erasure and retention of personal data

7.1 We ensure that the personal data is deleted when it is no longer relevant for the processing purposes as described above. We also retain personal data to the extent that it is an obligation from applicable law, as is the case with for example accounting and bookkeeping materials and records.

7.2 We also enable you to terminate any data connections you have with any subscriber at any point in time but the terms of which they subscribe to your data thus specific terms on their end will determine specific obligations from applicable law similar to the example in 7.1

If you have any questions about our retention of personal data, please contact the email mentioned in section 10 of this Policy.

8. Data subject rights

8.1 Data subjects have a number of rights that we can assist with. If a data subject wants to make use of his or her rights, he or she can contact us. The rights include the following:

8.1.1 The right of access: Data subjects have a right to ask for copies of the information that we process about them, including relevant additional information.

8.1.2 The right to rectification: Data subjects have a right to ask for rectification of inaccurate personal data concerning him or her.

8.1.3 The right to erasure: In certain circumstances data subjects have a right to obtain the erasure of personal data concerning him or her before the time when erasure would normally occur.

8.1.4 The right to restrict processing: Data subjects have, in certain situations, a right to have the processing of his or her personal data restricted. If a data subject has the right to have the processing of his or her personal data restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest in the European Union or of a European member state.

8.1.5 The right to object: Data subjects have, in certain situations, a right to object to the legal processing of his or her personal data.

8.1.5 The right to object: Data subjects have, in certain situations, a right to object to the legal processing of his or her personal data.

8.2 More information about data subject rights can be found in the guidelines of the national data protection authorities. If a data subject wishes to make use of his or her rights as described above, the data subject is asked to use the contact details provided at the end of this Policy. We strive to do everything to meet wishes regarding our processing of personal data and the rights of data subjects. If you or others despite our endeavours wish to file a complaint, this can be done by contacting the national data protection authorities.

9. Changes to this Policy

9.1 We reserve the right to update and amend this Policy. If we do, we correct the date and the version at the bottom of this Policy. In case of significant changes, we will provide notification in the form of a visible notice, for example on our website or by direct message.

10. Contact

10.1 If you have questions or comments to this Policy or if you would like to invoke one or more data subject rights, please contact us at eg@complyteq.com.