Kinectify Privacy Policy
Effective Date: May 5, 2021
Overview
This Privacy Policy describes how Kinectify (“Kinectify”, “we,” “us,” or “our”) collects, uses, and discloses personal information about individuals (“you”) who visit our websites, interact with our content, or otherwise engage with our products and services. This Privacy Policy is reviewed periodically and updated based on changes to data practices, regulatory, and legal requirements. The current version of this Privacy Policy is always available on the Kinectify website. If we make material changes, we will update the “Effective Date” above and, where required by law, provide additional notice.
This Privacy Policy also provides notices and rights required under applicable U.S. state privacy laws and explains the legal bases for processing personal information for users in the European Economic Area (EEA) and the United Kingdom in accordance with GDPR requirements.
For any questions or comments, please contact our Privacy Officer at legal@kinectify.com.
Scope
All Kinectify employees and all contractors with access to sensitive systems and information are required to comply with our privacy and security policies as a condition of employment. Kinectify employees and contractors are required to sign Kinectify’s code of conduct acknowledging that they have been trained and will adhere to these standards as a condition of employment. Kinectify employees and contractors undergo regular security training.
This Privacy Policy does not apply to the personal information of our employees.
Personal information collected by Kinectify
In this Privacy Policy, “personal information” means information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable.
The personal information collected by Kinectify may include:
- names;
- identification and contact information (including copies of identification documents that are provided to us);
- employment and professional information;
- records maintained by our clients, including bank account details and transaction and wagering history;
- records of interactions with Kinectify; and
- IP address(es) and information about the devices and systems used to access Kinectify content and services.
In respect of job applicants, Kinectify may also collect the following personal information:
- employment history and qualifications;
- academic records;
- references;
- medical information;
- personal alternative contact details;
- tax file number;
- superannuation fund details; and
- criminal history record.
For U.S. users, personal information may include any categories of information necessary to provide services or respond to inquiries, including identifiers, commercial information, and internet or electronic network activity information, as defined under U.S. state privacy laws.
For EU/UK users, personal information may also include data reasonably necessary to fulfill contractual obligations, legitimate interests, or legal obligations under GDPR.
Methods by which Kinectify collects personal information
Kinectify collects personal information through a variety of methods, including:
- from public sources of information, including government watchlists, media reports, litigation records, corporate records, and regulatory filings;
- from data aggregators;
- from our clients or prospective clients about their employees and other users of Kinectify services;
- from direct communications with individuals, including helpdesk tickets, email, and telephone conversations;
- via indirect communications with individuals, including demonstration requests, webinar registrations, and requests to access Kinectify content;
- in the course of an individual’s use of Kinectify websites or services, including through website cookies and other technical monitoring tools; and
- from trusted partners or third parties in accordance with applicable privacy and marketing laws.
We may also collect information through automated tools such as analytics, tracking pixels, and cookies, and through our partners or service providers acting on our behalf, in accordance with GDPR, U.S., and Australian privacy laws.
Kinectify implements reasonable technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction.
You may control or disable cookies through your browser settings. Certain cookies are necessary for the proper functioning of our websites and services. For EU/UK users, consent will be obtained where required.
For U.S. users, collection may occur to fulfill business or contractual obligations, for legitimate interests, or where consent has been provided, in compliance with applicable state privacy laws.
Purposes for which Kinectify collects, holds, uses and discloses personal information
Kinectify collects, holds, uses and discloses personal information for a number of purposes, including the following:
- to facilitate clients’ ability to access their provided data;
- to display certain publicly available information related to data provided by clients;
- to establish and maintain business relationships;
- to support and improve Kinectify services, including Kinectify’s website and AML platform;
- to invoice and communicate with current or potential clients;
- to create pseudonymised, de-identified and/or aggregated datasets;
- for sales and marketing purposes related to Kinectify services and events;
- to consider job applicant's suitability for employment with us; and
- to comply with our legal obligations, resolve any disputes and enforce our agreement and rights with third parties.
Kinectify retains personal information only as long as necessary to provide services, comply with legal obligations, resolve disputes, and enforce agreements.
For U.S. users, personal information is collected, used, and disclosed to fulfill business or contractual obligations, for legitimate interests, for compliance with legal obligations, or based on consent where required by applicable state privacy laws (e.g., California, Virginia, Colorado, Connecticut, Utah). This includes rights under state privacy laws, such as access, correction, deletion, portability, and opt-out of sale/sharing.
For EU/UK users, personal information is collected, held, used, and disclosed based on the following legal bases under GDPR: contract performance, legitimate interests, legal obligations, and consent where required (e.g., marketing communication).
How Kinectify may share personal information
Kinectify may share personal information with:
- its partners, affiliates, and persons contracted to perform service on its behalf;
- anyone to whom part or all of our assets or business are transferred or sold;
- its professional advisors, including lawyers, accountants and auditors; and
- government agencies, regulatory bodies and law enforcement agencies.
Kinectify currently does not sell personal information to third parties but may from time to time license or sell aggregated, de-identified data to third parties. For U.S. users, sharing personal information with service providers or partners to perform business operations, provide services, or process data on our behalf does not constitute a “sale” under California or other applicable state privacy laws.
Kinectify stores all personal information in the United States.
For U.S. users, if any personal information is shared or sold as defined under state privacy laws, you will be provided an opt-out mechanism (e.g., for California residents under CPRA).
Personal information may also be transferred to other countries for processing, in accordance with GDPR, Australian APP 8, and U.S. privacy laws, using appropriate safeguards to protect your information.
Our services are not directed to children under 13 years of age (or 16 in the EEA). We do not knowingly collect personal information from minors. If we become aware we have collected information from a minor, we will delete it.
Direct marketing
Kinectify may, from time to time, use your personal information to identify products or services in which you may be interested. We may, with your consent, use the personal information to contact you from time to time, whether by phone, email or SMS, to tell you about new products or services and special offers that Kinectify believes may be of interest to you.
You withdraw your consent to receiving direct marketing communications from Kinectify at any time by unsubscribing from the mailing list by clicking on the link in the marketing communication or contacting the Privacy Officer.
For U.S. users, you have the right to opt out of targeted marketing or the sale/sharing of personal information under applicable state privacy laws.
For EU/UK users, marketing communications are sent only on the basis of consent or legitimate interests, and you may withdraw consent at any time without affecting other services.
Subscriber Data
Kinectify provides anti-money laundering and financial crime compliance software for use in a variety of industries. Data uploaded or generated by clients through their use of Kinectify software and services (Subscriber Data) is governed by contractual arrangements between Kinectify and each client. Kinectify receives Subscriber Data as a data processor or service provider. Subscriber Data is owned by the respective clients. Any questions or requests related to Subscriber Data should be directed to the relevant client.
Subscriber Data is not personal information collected directly by Kinectify and is subject to the contractual terms agreed with each client. Kinectify processes Subscriber Data solely as a service provider in accordance with applicable privacy laws.
Accessing your personal information or raising a complaint
Applicable privacy laws may provide you with additional rights with respect to your personal information. Any requests relating to such rights should be submitted to Kinectify’s Privacy Officer:
Privacy Officer – Kinectify Inc.
(725) 210-6538
legal@kinectify.com
- Kinectify will need to verify your identity before responding to your request. Subject to any applicable exceptions or requirements, Kinectify will provide you with access to the personal information you request within a reasonable time (usually within 28 days). If we decide to refuse your request, we will tell you why in writing.
- If you are dissatisfied with how we have managed your personal information, you can make a complaint in writing to the Privacy Officer. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
For U.S. users, you may also submit complaints to your applicable state privacy regulator. You also have the right to: access, correct, delete, or receive a copy of your personal information; opt out of the sale/sharing of personal information; and exercise any other rights granted under state privacy laws such as CPRA, VCDPA, CPA, CTDPA, or UCPA.
If you are in Australia, and you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au.
Privacy Officer
Kinectify has appointed a Privacy Officer responsible for ensuring compliance with this Privacy Policy and applicable privacy laws. Any other requests related to personal information or privacy rights can be addressed to:
Privacy Officer – Kinectify Inc.
(725) 210-6538
legal@kinectify.com
Last update: October 28, 2025
This Privacy Policy may be updated from time to time. The “Last update” date above indicates when the latest version took effect.
Continued use of our websites or services constitutes acknowledgment of the updated policy.
For U.S. users, this Privacy Policy provides notice of your rights under applicable state privacy laws, including the right to access, delete, correct, or opt out of sharing personal information.
