Terms of Use

This document is an electronic record in terms of the laws of United States of America and is generated by a computer system and does not require any physical or digital signatures.

ComplyGlobal Pte. Ltd. is a New York corporation with its registered office at 10 East 33rd Street, 6th Floor, New York, NY 10016 and provides its Services to You subject to the notices, terms and conditions as set forth in these Terms of Use ("Terms of Use").

The domain name www.complyglobal.com (hereinafter referred to as the "Website") is owned by ComplyGlobal Pte. Ltd. Your use of the Website and the Services are governed by the following terms and conditions of usage as applicable to the Website including the applicable policies which are incorporated herein by way of reference. For the purpose of these Terms of Use, wherever the context so requires "You", "Registered User" or "Your" shall mean and refer to any natural or legal person who has agreed to become a registered user on the Website by providing registration data in order to avail the Services provided by Us through the Website. The term "Account" as referred to in these Terms of Use shall mean and include the Account held by You with ComplyGlobal™ (administered by a password) on the Website for using the Services.

You acknowledge and agree that You shall be subject to the policies that are applicable to the Website and by registering on the Website, or by using the Website, platform, services, or other information provided as part of the services (collectively the "Services"), You are entering into a legally binding agreement with ComplyGlobal Pte. Ltd. (hereinafter collectively referred to as "ComplyGlobal™" "We", "Us", "Our", which expression shall mean and include its affiliates, successors and permitted assigns). When You use any of the Services provided by Us through the Website, You will be subject to the rules, guidelines, policies, terms, and conditions applicable to the Services, and the same shall be deemed to be incorporated into this Terms of Use and be considered as part and parcel of this Terms of Use. If You are using the Website on behalf of a company or other legal entity, You are nevertheless individually bound by this Agreement even if Your company has a separate agreement with Us.

It is Your responsibility to review these Terms of Use periodically for updates / changes. Your continued use of the Website following the posting of changes will mean that You accept and agree to the revisions. As long as You comply with these Terms of Use, We grant You a personal, non-exclusive, non-transferable, non-assignable, limited privilege to access, enter and use the Website and the Services provided thereunder.

ACCESSING, BROWSING OR OTHERWISE USING THE WEBSITE INDICATES YOUR ACCEPTANCE OF ALL THE TERMS AND CONDITIONS IN THESE TERMS OF USE. PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE PROCEEDING. YOU DECLARE YOUR ACCEPTANCE TO ABIDE AND BE BOUND BY THESE TERMS OF USE BY CHECKING THE "I HAVE READ AND ACCEPTED THE TERMS OF USE" BOX AT THE TIME OF CREATING THE ACCOUNT. IF YOU DO NOT AGREE WITH THE TERMS OF USE, PLEASE DO NOT USE THIS WEBSITE.

These Terms of Use will be effective immediately upon Your acceptance of Our terms and conditions, the creation of Your Account on Our Website being indicative of such acceptance. These Terms of Use shall be enforceable against You in the same manner as any other written agreement.

1. Services

ComplyGlobal™ is a cloud based software solution to manage and track your compliances. This platform helps your organization to conform to various legal statutes, regulations, government directives and guidelines that bring full transparency and visibility to you and your organization. ComplyGlobal™ gives you state of the art reporting and dashboards on multiple parameters including jurisdiction, entity and by regulatory bodies. With a strong task and alert management backbone, users can leverage systems advanced default tasks and alert management capabilities or create customized alerts. The task management function allows assigning tasks to the right resource groups within your organization.

2. Account

Prior to using the Website or any part of the Services, You shall be required to register with ComplyGlobal™ through the Website by setting up an Account and selecting a desired password and user ID. You agree that at the time of creating Your Account, You will not (1) select or use as a user ID the name of another person; or (2) use as a user ID, a name that is otherwise offensive, vulgar or obscene. We reserve the right to refuse registration of, or cancel a user ID and password at Our sole discretion. You are solely responsible for any and all activity that takes place on Your Account and for maintaining the confidentiality of Your Account details. You may never use another registered user's account without obtaining the prior written consent of such other registered user. In the event that You discover any unauthorized use of Your Account or other Account-related security breach, You must immediately notify Us in writing of such unauthorized use.

During the process of registration, You may be prompted with registration forms on the Website or You may be asked to provide documentation necessary to complete the registration process. By initiating the process of registration with Us, You agree to (1) provide accurate, complete, and updated registration information; (2) maintain the security of Your password and identification; (3) maintain and promptly update Your registration information and any other information that You provide to Us; (4) ensure, at all times, the accuracy, currency and completeness of such information; and (5) accept all risks of unauthorized access to and use of Your Account and related information as well as any other information You provide to Us. Failure to submit the required registration information to Us within such time period as prescribed by Us will constitute a breach of these Terms of Use, which may result in immediate termination of Your Account.

If You provide any information that is untrue, inaccurate, not current or incomplete, We have the right, at Our sole discretion, to suspend or terminate Your Account and to refuse any and all current or future use of the Services and / or the Website (or any portion thereof). We shall use and protect Your proprietary information in accordance with the terms of Our Privacy Policy incorporated into these Terms of Use by reference.

In order to reduce the risk of unauthorized access, all accounts maintained with Us through the Website are locked after five (5) consecutive incorrect login attempts. In the event of such lockout, You can email the administrator at support@complyglobal.com and the Account shall be unlocked upon receipt of Your email. You can also request for a password reset on our website through the 'forgot password' option on the website.

You may be required to upload certain information about You, including information that may be reasonably considered to be confidential, and to designate which users may have access to that information. We will make best efforts to ensure that only such users identified by You have access to the said information. However, We have no control and assume no responsibility arising out of any user's viewing / using / distributing such information.

If You do not want to register an account, DO NOT click "Register Now" / "Sign Up" and do not access, view, download or otherwise use any webpage, information or Services available under the Website. By clicking "Register Now" / "Sign Up" you acknowledge that you have read and understood the terms and conditions of this Agreement and that you agree to be bound by all of its provisions. You may decline to submit certain information through the Website, in which case You may not be allowed to access certain features / parts of the Website.

Further, You can choose to de-activate Your Account with ComplyGlobal™ maintained on the Website. However, in the event subscription to Our Website is pre-paid, any cancellation of Your Account will be made effective only on the last day of Your payment term. In the event You de-activate Your Account with Us, these Terms of Use, as applicable to You, will be deemed to have been terminated save and except such obligations that shall by their nature or specific mention herein, survive the termination of these Terms of Use. You acknowledge and agree that notwithstanding Your de-activating the Account, We shall have the right to store and maintain all information provided by You as part of our records for such time and for such purposes as permitted or may be required under any applicable law for the time being in force.

3. Payment

If You purchase any Services that We offer for a fee, either on a one-time or subscription basis, you agree to ComplyGlobal™ storing your payment information. You also agree to pay the fees for the Services as they become due plus all related taxes, and to reimburse Us for all collection costs and interest for any amount that may be overdue. Failure to pay may result in the termination of your subscription. Depending on where you transact with us, the type of payment method used and where your payment method was issued, your transaction with us may be subject to foreign exchange fees or differences in prices, including because of exchange rates. ComplyGlobal™ does not support all payment methods, currencies or locations for payment. If the payment method You use with Us, such as a credit card, reaches its expiration date and You do not edit Your payment method information or cancel Your account or such Services, You authorize Us to continue billing that payment method and You remain responsible for any uncollected amounts. Your obligation to pay fees continues through the end of the subscription period during which you cancel Your subscription. All applicable taxes are calculated based on the billing information You provide Us at the time of purchase. We do not guarantee refunds for lack of usage or dissatisfaction. You also acknowledge that ComplyGlobal™'s Services are subject to this Agreement and any additional terms related to the provision of the Services. Additionally, if You require a printed invoice for Your transaction with Us, You may access it through Your ComplyGlobal™ account settings under "Purchase History" or request one by contacting Our Customer Support.

4. Types of Services:

Subscription Based

Subscription to Our Website shall be in accordance with the business model displayed on the Website. Usage of Our Website and Services shall be based on a non-refundable pricing model. Pricing shall be determined based upon Your choice of the Services made available on the Website. In consideration for the Services rendered by Us, You agree to pay the applicable subscription fees at the time of registration on the Website. This subscription fee shall be subject to applicable taxes.

5. Intellectual Property

This Website is operated by and is the sole property of ComplyGlobal™ or its affiliates. Any and all material on this Website, including images, illustrations, audio and video clips are protected by copyrights, trademarks, and other intellectual property rights that are owned by Us or by other parties that have licensed such material to Us or such parties having ownership of content uploaded on the Website. You agree that any and all material displayed on the Website is solely for Your personal use and You shall not, whether directly or indirectly, copy, reproduce, republish, post, upload, transmit or distribute such material in any manner and through any media including by way of e-mail or other electronic means and You shall not assist any other person in doing so. Modification of the said materials or use of the materials on any other website or networked computer environment or use of the materials for any purpose other than personal use is a violation of the said copyrights, trademarks and other intellectual proprietary rights, and is expressly prohibited. Unless otherwise specified, when any content is downloaded to Your computer, You do not obtain any ownership interest in such content or any use of the content for any other purpose. We reserve all rights not expressly granted to You.

ComplyGlobal™ shall have no obligation to monitor or enforce any intellectual property rights that may be associated with the content provided by You on the Website.

6. Prohibited Uses

The Website may be used only for lawful purposes. ComplyGlobal™ specifically prohibits any use of the Website for, and You further agree not to use the Website for, any of the following purposes:

• You shall not host, display, upload, modify, publish, transmit, update or share any information which:
  • is misleading in any way;
  • infringes upon or violates any third party's rights including, but not limited to, intellectual property rights, rights of privacy (including without limitation unauthorized disclosure of a person's name, email address, physical address or phone number) or rights of publicity;
  • contains restricted or password-only access pages, or hidden pages or images (those not linked to or from another accessible page);
  • tries to gain unauthorized access or exceeds the scope of authorized access to the Website or to profiles, blogs, communities, account information, bulletins, or other areas of the Website or solicits passwords or personal identifying information for commercial or unlawful purposes from other users;
  • engages in commercial activities and/or sales without Our prior written consent such as advertising and offers, or the buying or selling of "virtual" products related to the Website. Throughout this Terms of Use, ComplyGlobal™'s prior written consent means a communication coming from ComplyGlobal™, specifically in response to Your request, and specifically addressing the activity or conduct for which You seek authorization;
  • interferes with another User's use and enjoyment of the Website or any other individual's User and enjoyment of similar services;
  • violates any law for the time being in force;
  • contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; or contains any trojan horses, worms, time bombs, cancelbots, easter eggs or other computer programming routines that may damage, detrimentally interfere with, diminish value of, surreptitiously intercept or expropriate any system, data or personal information;
  • shall not be false, inaccurate or misleading;
  • shall not create liability for Us or cause Us to lose (in whole or in part) the services of Our internet service provider ("ISPs") or other suppliers;
• You shall not use any "deep-link", "page-scrape", "robot", "spider" or other automatic device, program, algorithm or methodology, or any similar or equivalent manual process, to access, acquire, copy or monitor any portion of the Website or any Content, or in any way reproduce or circumvent the navigational structure or presentation of the Website or any Content, to obtain or attempt to obtain any materials, documents or information through any means not purposely made available through the Website. We reserve Our right to bar any such activity.
• You shall not attempt to gain unauthorized access to any portion or feature of the Website, or any other systems or networks connected to the Website or to any server, computer, network, or to any of the services offered on or through the Website, by hacking, password "mining" or any other illegitimate means.
• You shall not probe, scan or test the vulnerability of the Website or any network connected to the Website nor breach the security or authentication measures on the Website or any network connected to the Website. You may not reverse look-up, trace or seek to trace any information of any other User or visitor to the Website, or any other customer, including any account on the Website not owned by You, to its source, or exploit the Website or any service or information made available or offered by or through the Website, in any way where the purpose is to reveal any information, including but not limited to personal identification or information, other than Your own information, as provided for by the Website.
• You shall not make any negative, denigrating or defamatory statement(s) or comment(s) about Us or the brand name or domain name used by Us including but not limited to the terms ComplyGlobal™, or otherwise engage in any conduct or action that might tarnish the image or reputation, of ComplyGlobal™, ComplyGlobal™, or its Partners or otherwise tarnish or dilute any ComplyGlobal™'s trade or service marks, trade name and/or goodwill associated with such trade or service marks, trade name as may be owned or used by us. You agree that You will not take any action that imposes any unreasonable or disproportionately large load on the infrastructure of the Website or ComplyGlobal™'s systems or networks, or any systems or networks connected to ComplyGlobal™.
• You agree not to use any device, software or routine to interfere or attempt to interfere with the proper working of the Website or any transaction being conducted on the Website, or with any other person's use of the Website.
• You may not forge headers or otherwise manipulate identifiers in order to disguise the origin of any message or transmittal You send to Us on or through the Website or any service offered on or through the Website. You may not pretend that You are, or that You represent, someone else, or impersonate any other individual or entity.
• You may not use the Website or any content for any purpose that is unlawful or prohibited by these Terms of Use, or to solicit the performance of any illegal activity or other activity which infringes the rights of ComplyGlobal™ and / or others.

7. Modifications

We reserve the right at any time and from time to time, in Our sole discretion, to modify or discontinue, temporarily or permanently, the Services or any part thereof, including the transmission of any related materials or documentation, with prior notice to You, through publication on the Website. You agree that ComplyGlobal™ shall not be liable to You or to any third party claiming through You, for any modification, suspension, or discontinuance of the Services, content, or features provided on the Website.

8. System Limitations and Failures

We use internally developed systems for providing the Services to You. These systems may encounter technical or other limitations, and computer and communications hardware systems might experience interruptions. Further, We continually enhance and improve these systems in order to accommodate the level of use of the Website. We may also add additional features and functionality to the Services that might result in the need to develop or license additional technologies. Increased utilization of the Website or providing new features or functionality may cause unanticipated system disruptions, slower response times, degradation in levels of customer service, and delays in reporting accurate financial information. You agree that We shall not be liable to You or to any third party claiming through You, for any such failures contemplated herein.

9. Privacy and Confidentiality

You acknowledge, consent and agree that We may access, preserve, and disclose Your registration and any other information You provide in accordance with the terms of the Privacy Policy if required to do so by law or in a good faith belief that such access preservation or disclosure is reasonably necessary in Our opinion to: (1) comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Agreement; (3) respond to claims of a violation of the rights of third parties, whether or not the third party is a Member, individual, or Government agency; (4) respond to customer service inquiries; or (5) protect the rights, property, or personal safety of ComplyGlobal™, Our Members or the public. Disclosures of Customer information to third parties other than those required to provide customer support, administer this agreement, or comply with legal requirements are addressed and governed by Our Privacy Policy. Please read Our Privacy Policy to understand Our information collection and usage practices and Our Privacy Policy is incorporated in these Terms of Use by reference.

10. Links from other Websites

This Website can be made accessible through a link created by other websites. Access to this Website through such links shall not mean or be deemed to mean that the objectives, aims, purposes, ideas, concepts of such other websites or their aim or purpose in establishing such links to this Website are necessarily the same or similar to the idea, concept, aim or purpose of Our Website or that such links have been authorized by Us. We are not responsible for any representations of such other websites while affording such link and no liability can arise upon ComplyGlobal™ consequent to such representation, its correctness or accuracy. In the event that any links afforded by any other websites derogatory in nature to the objectives, aims, purposes, ideas and concepts of this Website, is utilized to visit this Website and such event is brought to the notice or is within the knowledge of ComplyGlobal™, civil or criminal remedies as may be appropriate shall be invoked.

11. Monitoring

All electronic communications and content presented and / or passed to Us, including that presented and / or passed from remote access connections, may be monitored saved, read, transcribed, stored, or retransmitted in the course of daily operations by any duly authorized employee or agent of ComplyGlobal™, in the exercise of their duties, or by law enforcement authorities who may be assisting ComplyGlobal™ in investigating possible contravention / non-compliance with applicable law. Electronic communications and content may be examined by automated means. Further, ComplyGlobal™ has the right to reject, at its sole discretion, from the Website any electronic communications or content deemed not to be in compliance with the corporate policies and procedures of ComplyGlobal™.

12. Termination

In the event it is determined by Us that You have violated any of these Terms of Use, We shall have the right, at Our sole discretion, to suspend or terminate Your Account and prohibit access to the Services and the Website forthwith. Any such suspension or termination of access to the Services and the Website, and any deletion of Account information, may be effected by Us without providing You with a prior written notice in this regard. Upon such termination of access to the Services and the Website, these Terms of Use, as applicable to You, will be deemed to have been terminated.

Further, these Terms of Use, as applicable to You, will be deemed to have been terminated in the event of You de-activating Your Account in accordance with Clause 2 of these Terms of Use.

You acknowledge and agree that, upon termination, You shall immediately destroy any copies made of any portion of the content contained on the Website. You acknowledge and agree that ComplyGlobal™ shall not be liable to You or any third party claiming through You, for any suspension or termination of access to the Services and the Website or for any deletion of Account information.

13. Disclaimer of Warranties and Limitation of Liability

The Website, including any content or information contained on it in connection with the Services, is provided on an "as is" basis. We hereby expressly disclaim all warranties and representations of any kind with respect to the Services or content contained on the Website, including but not limited to (a) warranties as to veracity of any information that is provided on the Website, or (b) warranties as to any results to be obtained from any use of the Services or ComplyGlobal™ content or information derived from the Services.

ComplyGlobal™ content, including the Services, shall not be construed as advice by ComplyGlobal™ or an opinion provided by ComplyGlobal™ regarding any compliance requirements by You or as legal opinion. ComplyGlobal™ shall have no liability for Compliance decisions based upon, or the results obtained from ComplyGlobal™ content, including the Services. ComplyGlobal™ content is intended for general information purposes only and should not be relied or acted on without obtaining business and/or legal advice.

ComplyGlobal™ does not endorse or act on behalf of any third party. In the event You engage the services of / interact with any third party, through the Website, ComplyGlobal™ will not be liable to You for any act or omission by such third party in relation thereto.

ComplyGlobal™ shall have no liability for any losses, special, punitive, incidental, direct or indirect, in contract, tort, or otherwise, incurred in connection with the Services or ComplyGlobal™ content, including but not limited to penalty levied by regulatory authorities, loss of revenue or profit or any other commercial or economic loss or for any decision made or action taken by any third party in reliance upon the Services or ComplyGlobal™ content.

You agree to indemnify and hold ComplyGlobal™ harmless from any claim or demand, including reasonable attorney's fees and expenses, made by any third party due to or arising out of Your use of the Website, the violation of the terms of this Terms of Use by You, or Your unauthorized use of any other registered user's account or Your infringement of any intellectual property or other right of any person or entity, or as a result of any threatening, libelous, obscene, harassing or offensive material posted / transmitted by You on the Website .

Your obligations under this Clause 13 shall survive the termination of these Terms of Use in accordance with Clause 12 above.

14. Governing Law and Dispute Resolution

These Terms of Use shall be governed by and construed in accordance with the laws of United States of America and subject to the provisions of arbitration set out herein, the courts at New York according to the prevailing Commercial Arbitration Rules of the American Arbitration Association shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with these Terms of Use.

15. Severability

If any term, provision, covenant or restriction of these Terms of Use is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remainder of the terms, provisions, covenants and restrictions of these Terms of Use shall remain in full force and effect and shall in no way be affected, impaired or invalidated.

16. Assignment

You may not assign or delegate any rights or obligations under the Terms of Use. Any purported assignment and delegation shall be ineffective. However, ComplyGlobal™ reserves the right to freely assign or delegate all rights and obligations under the Terms of Use, fully or partially without notice to you. We may also substitute, by way of unilateral novation, effective upon notice to you, ComplyGlobal™ for any third party that assumes our rights and obligations under this Terms of Use.

17. No Waiver

The rights and remedies available under this Terms of Use may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

18. General

These Terms of Use comprise the full and complete agreement between the You and ComplyGlobal™ with respect to the use of the Services and the Website and supersedes and cancels all prior communications, understandings and agreements between You and ComplyGlobal™, whether written or oral, expressed or implied with respect thereto.

19. Contact

Please address any questions or any grievances that You may have about the Terms of Use associated with the Website by writing to Us at legal@complyglobal.com.

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Terms of Use

This document is an electronic record in terms of the laws of India and is generated by a computer system and does not require any physical or digital signatures.

ComplyGlobal Pvt. Ltd. is a company incorporated in Bangalore, India with its registered office at Sri Vinayaka Motor Service Building, No. 21/3, T.S.P. Road, Kalasipalyam, Bangalore – 560002 and provides its Services to You subject to the notices, terms and conditions as set forth in these Terms of Use ("Terms of Use").

The domain name www.complyglobal.com (hereinafter referred to as the "Website") is owned by ComplyGlobal Labs Pte. Ltd­­­­. Your use of the Website and the Services are governed by the following terms and conditions of usage as applicable to the Website including the applicable policies which are incorporated herein by way of reference. For the purpose of these Terms of Use, wherever the context so requires "You", "Registered User" or "Your" shall mean and refer to any natural or legal person who has agreed to become a registered user on the Website by providing registration data in order to avail the Services provided by Us through the Website. The term "Account" as referred to in these Terms of Use shall mean and include the Account held by You with ComplyGlobal™ (administered by a password) on the Website for using the Services.

You acknowledge and agree that You shall be subject to the policies that are applicable to the Website and by registering on the Website, or by using the Website, platform, services, or other information provided as part of the services (collectively the "Services"), You are entering into a legally binding agreement with ComplyGlobal Pvt. Ltd.  (hereinafter collectively referred to as "ComplyGlobal™" "We", "Us",  "Our", which expression shall mean and include its affiliates, successors and permitted assigns). When You use any of the Services provided by Us through the Website, You will be subject to the rules, guidelines, policies, terms, and conditions applicable to the Services, and the same shall be deemed to be incorporated into this Terms of Use and be considered as part and parcel of this Terms of Use. If You are using the Website on behalf of a company or other legal entity, You are nevertheless individually bound by this Agreement even if Your company has a separate agreement with Us.

It is Your responsibility to review these Terms of Use periodically for updates / changes. Your continued use of the Website following the posting of changes will mean that You accept and agree to the revisions. As long as You comply with these Terms of Use, We grant You a personal, non-exclusive, non-transferable, non-assignable, limited privilege to access, enter and use the Website and the Services provided thereunder.

ACCESSING, BROWSING OR OTHERWISE USING THE WEBSITE INDICATES YOUR ACCEPTANCE OF ALL THE TERMS AND CONDITIONS IN THESE TERMS OF USE. PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE PROCEEDING. YOU DECLARE YOUR ACCEPTANCE TO ABIDE AND BE BOUND BY THESE TERMS OF USE BY CHECKING THE "I HAVE READ AND ACCEPTED THE TERMS OF USE" BOX AT THE TIME OF CREATING THE ACCOUNT. IF YOU DO NOT AGREE WITH THE TERMS OF USE, PLEASE DO NOT USE THIS WEBSITE.

These Terms of Use will be effective immediately upon Your acceptance of Our terms and conditions, the creation of Your Account on Our Website being indicative of such acceptance. These Terms of Use shall be enforceable against You in the same manner as any other written agreement.

1 Services

 

ComplyGlobal™ is a cloud based software solution to manage and track your compliances. This platform helps your organization to conform to various legal statutes, regulations, government directives and guidelines that bring full transparency and visibility to you and your organization. ComplyGlobal™ gives you state of the art reporting and dashboards on multiple parameters including jurisdiction, entity and by regulatory bodies. With a strong task and alert management backbone, users can leverage systems advanced default tasks and alert management capabilities or create customized alerts. The task management function allows assigning tasks to the right resource groups within your organization.

2 Account

Prior to using the Website or any part of the Services, You shall be required to register with ComplyGlobal™ through the Website by setting up an Account and selecting a desired password and user ID. You agree that at the time of creating Your Account, You will not (1) select or use as a user ID the name of another person; or (2) use as a user ID, a name that is otherwise offensive, vulgar or obscene. We reserve the right to refuse registration of, or cancel a user ID and password at Our sole discretion. You are solely responsible for any and all activity that takes place on Your Account and for maintaining the confidentiality of Your Account details. You may never use another registered user's account without obtaining the prior written consent of such other registered user. In the event that You discover any unauthorized use of Your Account or other Account-related security breach, You must immediately notify Us in writing of such unauthorized use.

During the process of registration, You may be prompted with registration forms on the Website or You may be asked to provide documentation necessary to complete the registration process. By initiating the process of registration with Us, You agree to (1) provide accurate, complete, and updated registration information; (2) maintain the security of Your password and identification; (3) maintain and promptly update Your registration information and any other information that You provide to Us; (4) ensure, at all times, the accuracy, currency and completeness of such information; and (5) accept all risks of unauthorized access to and use of Your Account and related information as well as any other information You provide to Us. Failure to submit the required registration information to Us within such time period as prescribed by Us will constitute a breach of these Terms of Use, which may result in immediate termination of Your Account.

If You provide any information that is untrue, inaccurate, not current or incomplete, We have the right, at Our sole discretion, to suspend or terminate Your Account and to refuse any and all current or future use of the Services and / or the Website (or any portion thereof). We shall use and protect Your proprietary information in accordance with the terms of Our Privacy Policy incorporated into these Terms of Use by reference.

In order to reduce the risk of unauthorized access, all accounts maintained with Us through the Website are locked after five (5) consecutive incorrect login attempts. In the event of such lockout, You can email the administrator at support@complyglobal.com and the Account shall be unlocked upon receipt of Your email. You can also request for a password reset on our website through the 'forgot password' option on the website.

You may be required to upload certain information about You, including information that may be reasonably considered to be confidential, and to designate which users may have access to that information. We will make best efforts to ensure that only such users identified by You have access to the said information. However, We have no control and assume no responsibility arising out of any user's viewing / using / distributing such information.

If You do not want to register an account, DO NOT click "Register Now" / "Sign Up" and do not access, view, download or otherwise use any webpage, information or Services available under the Website. By clicking "Register Now" / "Sign Up" you acknowledge that you have read and understood the terms and conditions of this Agreement and that you agree to be bound by all of its provisions. You may decline to submit certain information through the Website, in which case You may not be allowed to access certain features / parts of the Website.

Further, You can choose to de-activate Your Account with ComplyGlobal™ maintained on the Website. However, in the event subscription to Our Website is pre-paid, any cancellation of Your Account will be made effective only on the last day of Your payment term. In the event You de-activate Your Account with Us, these Terms of Use, as applicable to You, will be deemed to have been terminated save and except such obligations that shall by their nature or specific mention herein, survive the termination of these Terms of Use. You acknowledge and agree that notwithstanding Your de-activating the Account, We shall have the right to store and maintain all information provided by You as part of our  records for such time and for such purposes as permitted or may be required under any applicable law for the time being in force.

3 Payment

 

If You purchase any Services that We offer for a fee, either on a one-time or subscription basis, you agree to ComplyGlobal™ storing your payment information. You also agree to pay the fees for the Services as they become due plus all related taxes, and to reimburse Us for all collection costs and interest for any amount that may be overdue. Failure to pay may result in the termination of your subscription. Depending on where you transact with us, the type of payment method used and where your payment method was issued, your transaction with us may be subject to foreign exchange fees or differences in prices, including because of exchange rates. ComplyGlobal™ does not support all payment methods, currencies or locations for payment. If the payment method You use with Us, such as a credit card, reaches its expiration date and You do not edit Your payment method information or cancel Your account or such Services, You authorize Us to continue billing that payment method and You remain responsible for any uncollected amounts. Your obligation to pay fees continues through the end of the subscription period during which you cancel Your subscription. All applicable taxes are calculated based on the billing information You provide Us at the time of purchase. We do not guarantee refunds for lack of usage or dissatisfaction. You also acknowledge that ComplyGlobal™'s Services are subject to this Agreement and any additional terms related to the provision of the Services. Additionally, if You require a printed invoice for Your transaction with Us, You may access it through Your ComplyGlobal™ account settings under "Purchase History" or request one by contacting Our Customer Support.

4 Types of Services:

Subscription Based

Subscription to Our Website shall be in accordance with the business model displayed on the Website. Usage of Our Website and Services shall be based on a non-refundable pricing model. Pricing shall be determined based upon Your choice of the Services made available on the Website. In consideration for the Services rendered by Us, You agree to pay the applicable subscription fees at the time of registration on the Website. This subscription fee shall be subject to applicable taxes.

5 Intellectual Property

This Website is operated by and is the sole property of ComplyGlobal™ and its affiliates. Any and all material on this Website, including images, illustrations, audio and video clips are protected by copyrights, trademarks, and other intellectual property rights that are owned by Us or by other parties that have licensed such material to Us or such parties having ownership of content uploaded on the Website. You agree that any and all material displayed on the Website is solely for Your personal use and You shall not, whether directly or indirectly, copy, reproduce, republish, post, upload, transmit or distribute such material in any manner and through any media including by way of e-mail or other electronic means and You shall not assist any other person in doing so. Modification of the said materials or use of the materials on any other website or networked computer environment or use of the materials for any purpose other than personal use is a violation of the said copyrights, trademarks and other intellectual proprietary rights, and is expressly prohibited. Unless otherwise specified, when any content is downloaded to Your computer, You do not obtain any ownership interest in such content or any use of the content for any other purpose. We reserve all rights not expressly granted to You.

ComplyGlobal™ shall have no obligation to monitor or enforce any intellectual property rights that may be associated with the content provided by You on the Website.

6 Prohibited Uses

The Website may be used only for lawful purposes. ComplyGlobal™ specifically prohibits any use of the Website for, and You further agree not to use the Website for, any of the following purposes:

1. You shall not host, display, upload, modify, publish, transmit, update or share any information which:
1. is misleading in any way;
2. infringes upon or violates any third party's rights [including, but not limited to, intellectual property rights, rights of privacy (including without limitation unauthorized disclosure of a person's name, email address, physical address or phone number) or rights of publicity];
3. contains restricted or password-only access pages, or hidden pages or images (those not linked to or from another accessible page);
4. tries to gain unauthorized access or exceeds the scope of authorized access to the Website or to profiles, blogs, communities, account information, bulletins, or other areas of the Website or solicits passwords or personal identifying information for commercial or unlawful purposes from other users;
5. engages in commercial activities and/or sales without Our prior written consent such as advertising and offers, or the buying or selling of "virtual" products related to the Website. Throughout this Terms of Use, ComplyGlobal™'s prior written consent means a communication coming from ComplyGlobal™, specifically in response to Your request, and specifically addressing the activity or conduct for which You seek authorization;
6. interferes with another User's use and enjoyment of the Website or any other individual's User and enjoyment of similar services;
7. violates any law for the time being in force;
8. contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; or contains any trojan horses, worms, time bombs, cancelbots, easter eggs or other computer programming routines that may damage, detrimentally interfere with, diminish value of, surreptitiously intercept or expropriate any system, data or personal information;
9. shall not be false, inaccurate or misleading;
10. shall not create liability for Us or cause Us to lose (in whole or in part) the services of Our internet service provider ("ISPs") or other suppliers;
2. You shall not use any "deep-link", "page-scrape", "robot", "spider" or other automatic device, program, algorithm or methodology, or any similar or equivalent manual process, to access, acquire, copy or monitor any portion of the Website or any Content, or in any way reproduce or circumvent the navigational structure or presentation of the Website or any Content, to obtain or attempt to obtain any materials, documents or information through any means not purposely made available through the Website. We reserve Our right to bar any such activity.
3. You shall not attempt to gain unauthorized access to any portion or feature of the Website, or any other systems or networks connected to the Website or to any server, computer, network, or to any of the services offered on or through the Website, by hacking, password "mining" or any other illegitimate means.
4. You shall not probe, scan or test the vulnerability of the Website or any network connected to the Website nor breach the security or authentication measures on the Website or any network connected to the Website. You may not reverse look-up, trace or seek to trace any information of any other User or visitor to the Website, or any other customer, including any account on the Website not owned by You, to its source, or exploit the Website or any service or information made available or offered by or through the Website, in any way where the purpose is to reveal any information, including but not limited to personal identification or information, other than Your own information, as provided for by the Website.
5. You shall not make any negative, denigrating or defamatory statement(s) or comment(s) about Us or the brand name or domain name used by Us including but not limited to the terms ComplyGlobal™, ComplyGlobal™, or otherwise engage in any conduct or action that might tarnish the image or reputation, of  ComplyGlobal™ or its Partners or otherwise tarnish or dilute any ComplyGlobal™'s trade or service marks, trade name and/or goodwill associated with such trade or service marks, trade name as may be owned or used by us. You agree that You will not take any action that imposes any unreasonable or disproportionately large load on the infrastructure of the Website or ComplyGlobal™'s systems or networks, or any systems or networks connected to ComplyGlobal™.
6. You agree not to use any device, software or routine to interfere or attempt to interfere with the proper working of the Website or any transaction being conducted on the Website, or with any other person's use of the Website.
7. You may not forge headers or otherwise manipulate identifiers in order to disguise the origin of any message or transmittal You send to Us on or through the Website or any service offered on or through the Website. You may not pretend that You are, or that You represent, someone else, or impersonate any other individual or entity.
8. You may not use the Website or any content for any purpose that is unlawful or prohibited by these Terms of Use, or to solicit the performance of any illegal activity or other activity which infringes the rights of  ComplyGlobal™ and / or others.

7 Modifications

We reserve the right at any time and from time to time, in Our sole discretion, to modify or discontinue, temporarily or permanently, the Services or any part thereof, including the transmission of any related materials or documentation, with prior notice to You, through publication on the Website. You agree that ComplyGlobal™ shall not be liable to You or to any third party claiming through You, for any modification, suspension, or discontinuance of the Services, content, or features provided on the Website.

8 System Limitations and Failures

We use internally developed systems for providing the Services to You. These systems may encounter technical or other limitations, and computer and communications hardware systems might experience interruptions. Further, We continually enhance and improve these systems in order to accommodate the level of use of the Website. We may also add additional features and functionality to the Services that might result in the need to develop or license additional technologies. Increased utilization of the Website or providing new features or functionality may cause unanticipated system disruptions, slower response times, degradation in levels of customer service, and delays in reporting accurate financial information. You agree that We shall not be liable to You or to any third party claiming through You, for any such failures contemplated herein.

9 Privacy and Confidentiality

You acknowledge, consent and agree that We may access, preserve, and disclose Your registration and any other information You provide in accordance with the terms of the Privacy Policy if required to do so by law or in a good faith belief that such access preservation or disclosure is reasonably necessary in Our opinion to: (1) comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Agreement; (3) respond to claims of a violation of the rights of third parties, whether or not the third party is a Member, individual, or Government agency; (4) respond to customer service inquiries; or (5) protect the rights, property, or personal safety of ComplyGlobal™, Our Members or the public. Disclosures of Customer information to third parties other than those required to provide customer support, administer this agreement, or comply with legal requirements are addressed and governed by Our Privacy Policy. Please read Our Privacy Policy to understand Our information collection and usage practices and Our Privacy Policy is incorporated in these Terms of Use by reference.

10 Links from other Websites

This Website can be made accessible through a link created by other websites. Access to this Website through such links shall not mean or be deemed to mean that the objectives, aims, purposes, ideas, concepts of such other websites or their aim or purpose in establishing such links to this Website are necessarily the same or similar to the idea, concept, aim or purpose of Our Website or that such links have been authorized by Us. We are not responsible for any representations of such other websites while affording such link and no liability can arise upon ComplyGlobal™ consequent to such representation, its correctness or accuracy. In the event that any links afforded by any other websites derogatory in nature to the objectives, aims, purposes, ideas and concepts of this Website, is utilized to visit this Website and such event is brought to the notice or is within the knowledge of ComplyGlobal™, civil or criminal remedies as may be appropriate shall be invoked.

11 Monitoring

All electronic communications and content presented and / or passed to Us, including that presented and / or passed from remote access connections, may be monitored saved, read, transcribed, stored, or retransmitted in the course of daily operations by any duly authorized employee or agent of ComplyGlobal™, in the exercise of their duties, or by law enforcement authorities who may be assisting ComplyGlobal™ in investigating possible contravention / non-compliance with applicable law. Electronic communications and content may be examined by automated means. Further, ComplyGlobal™ has the right to reject, at its sole discretion, from the Website any electronic communications or content deemed not to be in compliance with the corporate policies and procedures of ComplyGlobal™.

12 Termination

In the event it is determined by Us that You have violated any of these Terms of Use, We shall have the right, at Our sole discretion, to suspend or terminate Your Account and prohibit access to the Services and the Website forthwith. Any such suspension or termination of access to the Services and the Website, and any deletion of Account information, may be effected by Us without providing You with a prior written notice in this regard. Upon such termination of access to the Services and the Website, these Terms of Use, as applicable to You, will be deemed to have been terminated.

Further, these Terms of Use, as applicable to You, will be deemed to have been terminated in the event of You de-activating Your Account in accordance with Clause 2 of these Terms of Use.

You acknowledge and agree that, upon termination, You shall immediately destroy any copies made of any portion of the content contained on the Website. You acknowledge and agree that ComplyGlobal™ shall not be liable to You or any third party claiming through You, for any suspension or termination of access to the Services and the Website or for any deletion of Account information.

13 Disclaimer of Warranties and Limitation of Liability

The Website, including any content or information contained on it in connection with the Services, is provided on an "as is" basis. We hereby expressly disclaim all warranties and representations of any kind with respect to the Services or content contained on the Website, including but not limited to (a) warranties as to veracity of any information that is provided on the Website, or (b) warranties as to any results to be obtained from any use of the Services or ComplyGlobal™ content or information derived from the Services.

ComplyGlobal™ content, including the Services, shall not be construed as advice by ComplyGlobal™ or an opinion provided by ComplyGlobal™ regarding any compliance requirements by You or as legal opinion. ComplyGlobal™ shall have no liability for Compliance decisions based upon, or the results obtained from ComplyGlobal™ content, including the Services. ComplyGlobal™ content is intended for general information purposes only and should not be relied or acted on without obtaining business and/or legal advice.

ComplyGlobal™ does not endorse or act on behalf of any third party. In the event You engage the services of / interact with any third party, through the Website, ComplyGlobal™ will not be liable to You for any act or omission by such third party in relation thereto.

ComplyGlobal™ shall have no liability for any losses, special, punitive, incidental, direct or indirect, in contract, tort, or otherwise, incurred in connection with the Services or ComplyGlobal™ content, including but not limited to penalty levied by regulatory authorities, loss of revenue or profit or any other commercial or economic loss or for any decision made or action taken by any third party in reliance upon the Services or ComplyGlobal™ content.

You agree to indemnify and hold ComplyGlobal™ harmless from any claim or demand, including reasonable attorney's fees and expenses, made by any third party due to or arising out of Your use of the Website, the violation of the terms of this Terms of Use by You, or Your unauthorized use of any other registered user's account or Your infringement of any intellectual property or other right of any person or entity, or as a result of any threatening, libelous, obscene, harassing or offensive material posted / transmitted by You on the Website .

Your obligations under this Clause 13 shall survive the termination of these Terms of Use in accordance with Clause 12 above.

14 Governing Law and Dispute Resolution

These Terms of Use shall be governed by and construed in accordance with the laws of India and subject to the provisions of arbitration set out herein, the courts at Bangalore, India, shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with these Terms of Use.

15 Severability

If any term, provision, covenant or restriction of these Terms of Use is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remainder of the terms, provisions, covenants and restrictions of these Terms of Use shall remain in full force and effect and shall in no way be affected, impaired or invalidated.

16 Assignment

You may not assign or delegate any rights or obligations under the Terms of Use. Any purported assignment and delegation shall be ineffective. However, ComplyGlobal™ reserves the right to freely assign or delegate all rights and obligations under the Terms of Use, fully or partially without notice to you. We may also substitute, by way of unilateral novation, effective upon notice to you, ComplyGlobal™ for any third party that assumes our rights and obligations under this Terms of Use.

17 No Waiver

The rights and remedies available under this Terms of Use may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

18 General

These Terms of Use comprise the full and complete agreement between the You and ComplyGlobal™ with respect to the use of the Services and the Website and supersedes and cancels all prior communications, understandings and agreements between You and ComplyGlobal™, whether written or oral, expressed or implied with respect thereto.

19 Contact

Please address any questions or any grievances that You may have about the Terms of Use associated with the Website by writing to Us at legal@complyglobal.com.

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Last Updated On: April 15, 2014

ComplyGlobal Pte. Limited, is a company engaged in the business of providing a cloud based software solution to manage and track legal, regulatory and internal Company compliances. Protecting consumer privacy is important to the Company. The Company and its affiliates in the United States and across other countries (hereinafter collectively referred to as the "ComplyGlobal™" "Company", "We", "Us" or "Our" which expression shall mean and include its affiliates, successors and permitted assigns) adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce ("Principles") with respect to that data. If there is any conflict between this Privacy Policy (the "Policy") and the Principles, the Principles shall prevail. This Policy describes Your privacy rights regarding Our collection, use, storage, sharing, and protection of Your Personal Information that You may provide via this Website and the policies adopted by Us to that effect. It applies to the www.complyglobal.com Website (the "Website") and all related sites, applications, Services (as defined under the Terms of Use) and tools where this policy is referenced, regardless of how you access or use them. Please be sure to read this entire Policy before using or submitting information to this site.

If you reside in the United States or the EU, then the Personal Information provided to or gathered by ComplyGlobal™ is controlled by ComplyGlobal Pte. Ltd.. If you reside outside the United States or the EU, then the Personal Information provided to or gathered by ComplyGlobal™ is controlled by ComplyGlobal Pte. Limited, Singapore. If you have any concern about providing information to Us or having such information displayed on the ComplyGlobal™ services or otherwise used in any manner permitted in this Privacy Policy and the Terms of Use, you should not become a customer of ComplyGlobal™ or visit Our Website. If You have already registered, You should close Your account.

ComplyGlobal™ reserves the right to modify the Policy without prior consent of the Users. In case of any material changes to the Policy, the Users will be notified by email (sent to the email address specified in the User's account) or by means of a notice on this Website prior to the change becoming effective. The Users are encouraged to periodically review this page for the latest information on its privacy practices. The term "User(s)" shall mean and include all companies and private organizations that visit the Website and provide information to ComplyGlobal™ through any of the modes referred to in the clause on "Collection of Information" below.

YOUR CONSENT

Use of this site constitutes Your consent to application of such laws and regulations and to the terms of Our Policy. Whenever you submit information via this site, you consent to the collection, use, and disclosure of that information in accordance with this Policy.

COLLECTION OF INFORMATION

We collect Your Personal Information in the following ways:

The term "Personal Information" or "Information" shall mean information that (i) is transferred from the EU to the United States of America; (ii) is transferred from any other country (other than the EU and the United States of America) to Singapore (ii) is recorded in any form; and (iii) is transferred from Switzerland to the United States of America; is recorded in any form; and (iv) is about, pertains to, or can be associated with a specific person and could be used to identify that person.

We do not consider Personal Information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person. If You are using the Website on behalf of a company or other legal entity, You are nevertheless, jointly and severally, bound by this Policy even if Your company has a separate arrangement with Us.

This site actively collects information from its visitors both by asking You specific questions and by permitting You to communicate directly with Us via e-mail. During the use of the Website, We may collect and process such information from the Users, including but not limited to the below mentioned:

i. Information that the Users provide to ComplyGlobal™ by filling in forms on the Website. This includes contact information such as name, email address, mailing address, phone number, financial information including but without limitation, if any, unique identifiers such as user name, account number, password and preferences information such as favorite lists and transaction history;

ii. Information that the Users provide when the Users write directly to ComplyGlobal™ (including by way of e-mail);

iii. Information that the Users provide to ComplyGlobal™ over telephone. ComplyGlobal™ may make and keep a record of the information shared by the Users with ComplyGlobal™;

iv. Information that the Users provide to ComplyGlobal™ by completing surveys, questionnaire, etc.;

v. Information relating to logs is automatically reported by the User's browser each time the User accesses a web page. When the User uses the Website, ComplyGlobal™ servers automatically record certain information that the User's web browser sends whenever the User visits any website. These server logs may include information such as the User's web request, Internet Protocol (IP) address, browser type, referring/ exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. ComplyGlobal™ uses this information, which does not identify Users, to analyze trends, to administer the website, to track Users' movements around the Website and to gather demographic information about the User base as a whole. ComplyGlobal™ does not link this automatically-collected data to personally identifiable information.

vi. When You visit the Website or use ComplyGlobal™ Services, We collect information sent to Us by Your computer or other access device. The information sent to Us includes data on the pages You access, Your computer IP address, device identifiers, and the type of operating system You are using, Your location, mobile network information, standard web log data and other information. Web log data includes the browser type You are using and traffic to and from Our site. When You visit the Website or use C Suit Services, We also collect information about Your transactions and Your activities.

Some of the information that you submit may be personally identifiable information (that is, information that can be uniquely identified with you such as Your full name, address, e-mail address, phone number, and so on).

You may also choose to provide Us with access to certain Personal Information stored by third parties such as social media sites (e.g., Facebook and Twitter). The information We may receive varies by site and is controlled by that site. By associating an account managed by a third party with Your ComplyGlobal™ account and authorizing ComplyGlobal™ to have access to this information, You agree that ComplyGlobal™ may collect, store and use this information in accordance with this Policy.

ComplyGlobal™ complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. ComplyGlobal™ has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ComplyGlobal™'s certification, please visit http://www.export.gov/safeharbor/

NOTICE OF USE OF INFORMATION

At ComplyGlobal™, We use the information We obtain about Our customers for the following activities:

a. To provide, deliver and assist Us in providing and delivering any products and services to You and to help Us improve and develop these services;

b. To send You and keep You informed about commercial communications, subject to any choices You have made, about ComplyGlobal™ or third party products and services, loyalty programmes or other updates;

c. To verify any of the information You provide in order to effect, administer and enforce transactions, to manage Our customer relationships, to provide the requested products and services, to sign up agents, to ensure Your eligibility for any services, or products You apply for, and to maintain accuracy of Our records;

d. To allow You to change web pages during Your visit without having to re-enter Your password;

e. To store Your preferences and other information and to track activity on Our Website;

f. To better understand the effectiveness of Our promotional campaigns;

g. To deliver Information specific to Your interests on additional websites;

Except as otherwise stated, We may use Your information to improve the content of Our site, to customize the site to Your preferences, to communicate information to you (if you have requested it), for Our marketing and research purposes, and for the purposes specified in this Policy.

In the event the Information is collected for a purpose other than that stated herein, the Company shall inform You of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. Company shall provide You with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when You are asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected for.

CHOICE TO OPT OUT

In connection with our services, products and/or promotions, we may disclose Your Information to non-agent partners from time to time. If you wish that Your Information is not disclosed to non-agent partners, then we may not be able to provide services, products and promotions to You.

If you need additional information on how Your Information may be disclosed to non-agent partners, please write to info@complyglobal.com

SHARING OF PERSONAL INFORMATION

We may share Personal Information with Our other corporate entities and affiliates, non-agent partners who represent Us across various jurisdictions, and who would be assisting Us in providing the services as sought by You. While ComplyGlobal™ strives to ensure that the Personal Information shared with other corporate entities, affiliates and partners are not subject to misappropriation or misuse, and that the third-party subscribes to the Principles or are subject to applicable law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection. ComplyGlobal™ shall not be responsible for misappropriation or misuse of Personal Information that may be attributed to such corporate entities and affiliates, partners.

We may also share Personal Information with Our other corporate entities and affiliates, partners to help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of Our services; and to facilitate joint or co-branded services that you request where such services are provided by more than one corporate entity. Those entities and affiliates may not market to you as a result of such sharing unless you explicitly choose so.

We may disclose Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose personal information to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: enforce Our Terms of Use or Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of Our Users or the general public.

We and Our affiliates will share some or all of Your Personal Information with another business entity should We (or Our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business.

DATA SECURITY

Company shall take reasonable steps to protect the Information from loss, misuse and authorized access, disclosure, alteration and destruction. Company has ensured that appropriate physical, electronic and managerial procedures have been put it place whether personally or through a third party, to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. We cannot guarantee the security of Information on or transmitted via the internet.

Company shall only access Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by You.

COOKIES

The Website uses "cookies". A cookie is a small text file that's stored on Your computer, tablet, or phone when you visit a Website that helps the site remember information about you and Your preferences.

Some cookies are deleted when you close down Your browser. These are known as Session Cookies. Others remain on Your device until they expire or you delete them from Your cache. These are known as Persistent Cookies and enable Us to remember things about you as a returning visitor.

We use Session Cookies for the following purposes:

• To allow you to carry information across pages of the Website and avoid having to re-enter information.

• Within registration to allow you to access stored information.

• To compile anonymous, aggregated statistics that allow Us to understand how Users use Our Website and to help Us improve the structure of Our Website.

We use Persistent Cookies for the following purposes:

• To help Us recognize you as a unique visitor (just a number) when you return to Our Website and to allow Us to tailor content to match Your preferred interests.

• To compile anonymous, aggregated statistics that allow Us to understand how Users use Our Website and to help Us improve the structure of Our Website.

• To internally identify you by account name, email address, customer ID, and location (geographic and computer ID/IP address).

• To tailor content to Your preferences.

Third parties may also serve cookies via this Website. These Third Party Cookies are used for the following purposes:

• To serve content on Our site and track whether this content is clicked on by Users.

• To control how often you are shown particular content.

• To count the number of anonymous Users of Our site.

• For Website usage analysis.

You can set Your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it.

You can also set Your browser to block the placing of cookies at all, but you should realize that this can limit the use of Our Website or services.

LINKS TO OTHER SITES

Our Website links to other Websites that may collect personally identifiable information about you. Please be informed that ComplyGlobal™ does not control other websites and that, in any case, this Policy does not apply to those websites. We encourage you to read the privacy and cookie policy of every website that you visit.

E-MAIL ADDRESS

If you subscribe to Our e-mail alerts, We collect Your e-mail address. This address will only be used for keeping you informed as indicated. If you wish to unsubscribe from Our e-mail alert list, you can do so at any moment as indicated in every e-mail you receive or by contacting Us through ComplyGlobal™.

REFERRALS

If the User wishes to introduce ComplyGlobal™ / the Website to any other person / entity, the User will be asked to provide such person / entity's name and email address. ComplyGlobal™ will automatically send such person / entity an email inviting it or to visit the Website. ComplyGlobal™ stores this information for the purpose of sending this email and keeping a record of the number of persons / entities so referred by the Users. ComplyGlobal™ may send additional emails to the said person / entity in connection with services offered by ComplyGlobal™.

RIGHTS TO ACCESS, CORRECT, OR DELETE YOUR INFORMATION, AND CLOSING YOUR ACCOUNT

You have a right to (1) access, modify, correct, or delete Your Personal Information controlled by ComplyGlobal™; (2) change or remove Your content, and (3) close Your account. You can also contact Us for any account information which is not on Your profile or readily accessible to you. If You close Your account, Your information will generally be removed from the Service within Forty-Eight (48) hours. We generally delete closed account information and will de-personalize any logs or other backup information within Thirty (30) days of account closure, except as noted below.

DATA RETENTION

We retain the Personal Information You provide while Your account is in existence or as needed to provide You Services. ComplyGlobal™ may retain Your Personal Information even after You have closed Your account if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes that may come up, prevent fraud and abuse, or enforce this Policy and Our Terms of Use. We may retain Personal Information, for a limited period of time, if requested by legal or Governmental Authorities. ComplyGlobal™'s Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but We generally delete or de-personalize closed account data consistent with the above mentioned section, except in the case of Our plug-in impression data, which We will try to de-personalize at the time of collection, but in any event, We will de-personalize within seven (7) days.

SEVERABILITY

ComplyGlobal™ has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

NO WAIVER

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

ENFORCEMENT

The Company uses a self-assessment approach to ensure compliance with this privacy policy and periodically verifies that the policy is accurate and comprehensive for the information intended to be covered, prominently displayed, completely implemented and assessable and in conformity with the Principles. We encourage interested person to raise any concern using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal processes, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.

FOREIGN JURISDICTION

ComplyGlobal™ makes no representation that the content contained on the Website is appropriate to be used or accessed outside the United States of America. If the Users use or access the Website from outside the United States of America, they are requested to do an independent research on their compliance with the laws of the relevant jurisdiction wherein they are domiciled.

CONTACT

Any questions, grievances or concerns regarding the Company's Safe Harbor Policy or data collection and processing practices should be addressed to:

ComplyGlobal Pte. Ltd.
Attn: Legal Department
Address: 10 East 33rd Street, 6th Floor,
New York, NY 10016

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ComplyGlobal Pte. Ltd. GENERAL EEA SAFE HARBOR NOTICE

SCOPE OF SAFE HARBOR CERTIFICATION

ComplyGlobal Pte. Ltd. ("ComplyGlobal™" or "we") recognize that the European Community has established a data protection regime pursuant to Directive 95/46/EC, which applies to the European Economic Area ("EEA") and restricts companies in the EEA in transferring personal data about individuals in the EEA to the United States, unless there is "adequate protection" for such personal data when it is received in the United States. To create such "adequate protection" and allow our subsidiaries and business partners to overcome the restriction on international data transfers established by the Directive, we adhere to the Safe Harbor Privacy Principles published by US Department of Commerce ("Safe Harbor Principles") with respect to personal data about individuals in the EEA that we receive from our subsidiaries, customers and other business partners. More information on the Safe Harbor Principles and ComplyGlobal™'s scope of participation is available at http://safeharbor.export.gov/companyinfo.aspx?

SCOPE OF THIS NOTICE

This Notice does not apply to employees of ComplyGlobal™ or our subsidiaries; this Notice addresses other data subjects residing in the EEA ("EEA Persons") whose data we may receive.

PURPOSES

We collect and use EEA Data for purposes of providing products and services to our customers, communicating with corporate business partners about business matters, processing EEA Data on behalf of corporate customers, providing information on our services, and conducting related tasks for legitimate business purposes.

DISCLOSURE

We share EEA Data with our subsidiaries, affiliates and partners, who process EEA Data on behalf of ComplyGlobal™. We also share EEA Data with other third parties for the purposes for which we receive the EEA Data and we may also disclose EEA Data where we are legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law or the Safe Harbor Principles and we have a legitimate business interest in such disclosure. With respect to marketing emails, EEA Persons may opt-out of receiving further email marketing communications from ComplyGlobal™ by sending an email to sales@complyglobal.com, or by following opt-out instructions that are contained in each marketing email. EEA Persons may also send an email to this address to ask to opt-out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for us to provide the requested services.

ACCESS AND REVIEW

If you are an EEA Person about whom we hold EEA Data, you may request access to, and the opportunity to update, correct or delete, such EEA Data. To submit such requests or raise any other questions, please contact the business that provided your EEA Data to us. You can also contact our Safe Harbor Contact. We reserve the right to take appropriate steps to authenticate an applicant's identity, to charge an adequate fee before providing access and to deny requests, except as required by the Safe Harbor Principles.

SAFE HARBOR CONTACT

If you have questions, please contact ComplyGlobal™'s Head of Security at security@complyglobal.com. If you have a comment or concern that cannot be resolved with us directly, you may contact the competent local data protection authority.

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