Privacy Policy
Published August 28, 2023 · Last updated March 4, 2024
We collect, use, and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as "controller" of that personal information for the purposes of those laws.
Key Terms
Personal Information We Collect About You
We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
| Categories of Personal Information | Specific Types Collected |
|---|---|
| Identifiers (name, alias, postal address, IP address, email, account name, etc.) | Real name, alias, work postal address, unique personal identifier, IP address, work email address, or similar identifiers. |
| Individual information (name, address, phone, employment, financial information, etc.) | Work address, work phone number, work email address, education, employment, and/or employment history. |
| Protected classification characteristics | None. |
| Commercial information (records of products or services purchased, considered, etc.) | Records of products or services considered or inquired about. |
| Biometric information | None. |
| Internet or electronic network activity (browsing history, search history, site interaction) | Information regarding your interaction with a website, application, or advertisement. |
| Geolocation data | None. |
| Audio, electronic, visual, thermal, olfactory, or similar information | None. |
| Professional or employment-related information | Publicly available information regarding your profession, current employer, and past employers. |
| Education information (non-public per FERPA) | None. |
| Inferences drawn from above to create a consumer profile | Inferences reflecting your interest in certain products or services. |
This personal information is required to provide products and/or services to you and/or to connect you with products or services in which you have indicated interest. If you do not provide personal information we ask for, it may delay or prevent us from providing such products and/or services.
How Your Personal Information is Collected
- From publicly accessible sources (e.g., social media);
- Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From a third party with your consent (e.g., companies you do business with);
- From cookies and similar technologies on our website or through direct email communications with you.
How and Why We Use Your Personal Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, including: to comply with legal obligations, for the performance of our contract with you, for our legitimate interests, or where you have given consent.
| What we use your personal information for | Our reasons |
|---|---|
| To provide products and/or services to you or connect you with products or services you've indicated interest in | Performance of our contract with you and/or our clients. |
| Gathering information required by audits, enquiries, or investigations by regulatory bodies | To comply with legal and regulatory obligations. |
| Ensuring business policies are adhered to (security, internet use, etc.) | Legitimate interests — to follow internal procedures and deliver the best service. |
| Operational reasons such as improving efficiency, training, and quality control | Legitimate interests — to be as efficient as possible to deliver the best service at the best price. |
| Ensuring confidentiality of commercially sensitive information | Legitimate interests and legal/regulatory obligations. |
| Statistical analysis to help manage our business | Legitimate interests — to operate efficiently and deliver the best service. |
| Updating and enhancing customer records | Legal/regulatory obligations and legitimate interests. |
| Statutory returns | To comply with legal and regulatory obligations. |
| Marketing our services and selected third parties to existing and former customers | Legitimate interests — to promote our business to existing and former customers. |
| External audits and quality checks | Legitimate interests and legal/regulatory obligations. |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Promotional Communications
We may use your personal information to send you updates (by email, text, telephone, or post) about our products and/or services, including exclusive offers, promotions, or new products. We have a legitimate interest in processing your personal information for promotional purposes and do not usually need your consent to send you promotional communications.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at [email protected];
- Using the "unsubscribe" link in emails or "STOP" in texts.
Who We Share Your Personal Information With
We routinely share personal information with:
- Our affiliates;
- Service providers we use to help deliver our products and/or services, such as payment service providers and delivery companies;
- Other third parties we use to help run our business, such as marketing agencies or website hosts;
- Third parties approved by you, including social media sites you choose to link your account to;
- Our customers in whom you indicate or demonstrate interest in their products and/or services.
We may also share personal information with external auditors, law enforcement agencies, and regulatory bodies to comply with our legal and regulatory obligations. We may disclose information to potential buyers during a restructuring; recipients will be bound by confidentiality obligations.
Personal Information Sold or Disclosed for a Business Purpose
In the preceding 12 months, we have not sold the following categories of personal information: protected classification characteristics, biometric data, geolocation data, audio/visual/thermal information, education information, or inferences about psychological trends, financial information, or health data.
In the preceding 12 months, we have sold, subject to the permission controls described in this Policy, the following categories: identifiers, name/address/phone/employment information, internet activity, commercial information, professional/employment information, and inferences about consumer preferences.
In the preceding 12 months, we have disclosed for a business purpose: identifiers, individual information (work contact details, education, employment history), commercial information, internet activity information, professional information, and consumer preference inferences.
Where Your Personal Information is Held
Information may be held at our offices and at third party agencies, service providers, representatives, and agents as described above. Some of these third parties may be based outside the European Economic Area — see "Transferring Your Personal Information Out of the EEA" below.
How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep it as long as necessary to respond to questions or complaints, to show we treated you fairly, or to keep records required by law. We will not retain your personal information for longer than necessary.
Transferring Your Personal Information Out of the EEA
To deliver services to you, it is sometimes necessary to share your personal information outside the European Economic Area (EEA) — with our offices outside the EEA, with service providers located outside the EEA, or where there is an international dimension to the services we provide. These transfers are subject to special rules under European and UK data protection law, and we ensure all transfers comply with applicable law and that your personal information remains secure.
Your Rights Under the GDPR
Your Rights Under the CCPA
You have the right under the California Consumer Privacy Act of 2018 (CCPA) to exercise, free of charge:
Disclosure of Personal Information We Collect
You have the right to know the categories of personal information we have collected, the sources from which it was collected, our business purpose for collecting or selling it, the third parties with whom we share it, and the specific pieces of personal information collected about you.
Personal Information Sold or Used for a Business Purpose
You have the right to know the categories of personal information we sold and to whom, and the categories disclosed for a business purpose. You also have the right to opt out of the sale of your personal information — visit our homepage and click the "Do Not Sell My Personal Information" link.
Right to Deletion
On receipt of a verifiable request, we will delete your personal information and direct our service providers to do the same, except where retention is required to complete a transaction, detect security incidents, comply with a legal obligation, or other permitted purposes under the CCPA.
Protection Against Discrimination
You have the right not to be discriminated against for exercising any of your CCPA rights. We cannot deny you goods or services, charge different prices, or provide a different level of quality because you exercised your privacy rights.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to those who have a genuine business need, and we have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected breach where legally required to do so.
How to Exercise Your Rights
To exercise any of your rights as described in this Privacy Policy:
- Complete a data subject request form at relevantsystems.io;
- Call us toll-free at 888-853-8057; or
- Email us at [email protected].
You may only make a CCPA-related data access or data portability request twice within a 12-month period. When contacting us directly, please provide enough information to identify you, proof of your identity and address, and a description of what right you want to exercise.
How to File a GDPR Complaint
We hope that we can resolve any query or concern you raise about our use of your information. The GDPR also gives you the right to lodge a complaint with a supervisory authority in the EU/EEA state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Children Under the Age of 13
Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn we have collected personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us immediately.
Changes to This Privacy Notice
We may change this privacy notice from time to time — please visit this page periodically to review for updates.