Kinectify Privacy Policy

Privacy Policy

This Privacy Policy describes how personal information is collected and used by Kinectify (“we,” “us,” “our”). This Privacy Policy is reviewed at least annually and updated based on regulatory requirements, client feedback, and best practices. This current version of this Privacy Policy is posted on the Kinectify website and users may contact the Privacy Officer for further questions or comments. Future updates to this Privacy Policy will be posted on the Kinectify website.

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.

Personal Information Obtained by Kinectify

"Personal information" is defined as any information about or linked to an identifiable individual. The personal information collected by Kinectify with respect to an individual includes:

- The individual’s name;

- The individual’s identification and contact information;

- The individual’s employment and professional information;

- Records on the individual as maintained by our clients;

- Information available in public sources regarding the individual including government watch lists, media, litigation, corporate records, and regulatory filings;

- Records of interactions between the individual and Kinectify; and

- IP address(es) and information about the devices and systems the individual uses to access Kinectify content and services.

Methods by which Kinectify Obtains Personal Information

Kinectify obtains personal information through a variety of methods, including:

- Receiving information from our clients or prospective clients about their employees and users of Kinectify services;

- Receiving information via direct communications with individuals, including helpdesk tickets, email, and telephone conversations;

- Receiving information via indirect communications with individuals, including demonstration requests, webinar registrations, and requests to access Kinectify content;

- Receiving and generating information in the course of an individual’s use of Kinectify websites or services, including through website cookies and other technical monitoring tools; and

- Receiving information from trusted partners or third parties in accordance with applicable privacy and marketing laws.

Kinectify’s Use of Personal Information

Kinectify uses personal information only for purposes consistent with the reasons for which it was initially obtained, including:

- To facilitate its clients’ ability to access to their provided data;

- To display additional publicly available information related to the data provided by clients;

- To establish and maintain business relationships;

- To support and improve Kinectify services;

- To invoice and communicate with its current or potential clients; and

- For sales and marketing purposes related to Kinectify services and events.

Kinectify may share personal information with its partners, affiliates, and those contracted to perform service on its behalf.

Kinectify does not sell personal information to third parties. Kinectify stores all personal information in the United States.

Accessing your personal information

Applicable privacy laws may provide you with additional rights with respect to your personal information. Any requests pertaining to such rights should be submitted to Kinectify’s Privacy Officer:

Privacy Officer – Kinectify Inc.

(725) 210-6538

legal@kinectify.com

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 responsible client.

Kinectify has appointed a Privacy Officer responsible for ensuring compliance with this Privacy Policy and applicable privacy laws. Any requests related to personal information or privacy rights can be addressed to:

Privacy Officer – Kinectify Inc.

(725) 210-6538

legal@kinectify.com

Last update: May 5, 2021

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