Regulatory DataCorp, Inc., its affiliates and subsidiaries (“RDC”, “we”, “us”, or “our”) respect your privacy. RDC is committed to safeguarding the Personal Data it receives from its Subscribers, Business Partners and Vendors; as well as what is on our website (www.rdc.com) and in publicly available sources which are incorporated into our product database (“GRID”) as well as our regulatory compliance services (altogether “Services”).
1. Personal Data We May Collect
2. How We May Use Your Personal Data
3. How We Share Your Personal Data
4. Your Rights and Choices
5. How We Protect Your Personal Data
6. Data Transfers & Privacy Shield
7. Features and Links to Other Websites
9. How to Contact Us
1. PERSONAL DATA WE MAY COLLECT
Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
- Personal Data Provided by You: You may provide us with your Personal Data (e.g. your name and address as part of a request for information) via our website www.rdc.com.
- Personal Data Provided in the Context of our Contractual Relationship: We may receive contact information (e.g., name, professional email address) of employees of Subscribers, Business Partners and Vendors in the context of our contractual relationship with such entities. Our Business Partners may also provide us with Personal Data from their customers. For example, some of our Business Partners resell our Services as part of their own products. In those situations, our Business Partners may provide us with Personal Data (i.e., name, address, date of birth). We also maintain the emails or other communications that our Subscribers may send us, such as customer support inquiries, and their content.
- Personal Data Obtained from Subscribers: Subscribers provide us with Personal Data (i.e., name, address, date of birth) of individuals who we check against our Services, upon our Subscribers’ requests.
- Personal Data Obtained from Public Source: RDC may collect Personal Data from public records databases (“Public Records”) and reputable publicly available sources (“Publicly Available Data”), and from third parties, in order to build out GRID and make our Services available to the requesting Subscriber. This includes individuals’ names and information relating to their jobs, companies, political affiliations, religious beliefs, sanctions, political exposure, and unlawful activities including terrorism and other criminal activities. Subscribers use such Personal Data as part of their compliance with their legal and regulatory obligations related to preventing and detecting money laundering, terrorism, and other criminal activity.
2. HOW WE MAY USE YOUR PERSONAL DATA
We may use the Personal Data we obtain about you to:
- Create and manage subscription agreements, provide our Services, and respond to inquiries from Subscribers.
- Communicate with you, including by periodically emailing you service-related announcements.
- Promote our Services and send you marketing communications about products, services, offers, programs and promotions of RDC, and partners.
- Aggregate or anonymize your Personal Data for the purpose of analyzing and reporting the effectiveness of and any trends in corporate ethics and compliance programs according to industry, company size, country, geographic region or other relevant classification or for other uses as RDC may decide (as permitted by our subscription agreements, where relevant, and as permitted by applicable law).
- Operate, evaluate and improve our business (including by developing new products and services; managing our communications; determining the effectiveness of our advertising; analyzing how the Services are being accessed and used; tracking performance of the Services; facilitating the use of our Services).
- Ensure the security of our Services.
- Manage our vendor and partner relationships.
- Enforce our subscription agreements and our other legal rights.
- Comply with applicable legal requirements, industry standards and our policies.
- Perform auditing, research and analysis in order to maintain, protect and improve our Services.
We may process your Personal Data for the above purposes when:
- We or a third party (e.g, Business Partners or Subscribers) have a legitimate interest in using your Personal Data. In particular, in line with the EU General Data Protection Regulation which recognizes fraud prevention as a legitimate interest, our Subscribers have a legitimate interest in the processing of your Personal Data for managing their financial risks, protecting against fraud, knowing who they are doing business with, and meeting compliance and regulatory obligations. Also, we have a legitimate interest in using your Personal Data to ensure and improve the safety, security, and performance of our Services and better understand organisations, industries, and markets.
- You have consented to the use of your Personal Data;
- We need your Personal Data to provide you with services and products requested by you, or to respond to your inquiries;
- We have a legal obligation to use your Personal Data.
3. HOW WE SHARE YOUR PERSONAL DATA
- Affiliates and Business Partners (e.g., reseller). We may share the Personal Data we collect or receive with our headquarters and affiliates, and Business Partners to whom it is reasonably necessary or desirable for us to disclose your Personal Data to operate our business and to perform Services for our Subscribers or for our Business Partners or their customers.
We do not share marketing data gathered via our website or through our subscriber agreements with anyone.
- Following the Law. We may disclose your Personal Data to third parties if we determine that such disclosure is reasonably necessary to comply with the law, respond to valid legal process, establish, assert or defend our legal rights, or prevent fraud or abuse of RDC or our users. In particular, we may disclose your Personal Data in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
4. YOUR RIGHTS AND CHOICES
In certain jurisdictions you have the right to request access and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict or object to the processing of your Personal Data, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer information to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority, including in your country of residence, place of work or where an incident took place, subject to applicable law.
Where required by law, we obtain your consent for the processing of certain Personal Data collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
To update your preferences, ask us to remove your information from our mailing lists, delete your account or submit a request to exercise your rights under applicable law, please contact us as specified in the “How to Contact Us” section below. If you would like to alter your marketing communications subscription preferences, or opt out, you can do so at anytime by visiting our communications preference center.
For information about our processing of your Personal Data on behalf of your financial institution for its legal and regulatory compliance purposes, please contact your financial institution.
5. HOW WE PROTECT YOUR PERSONAL DATA
We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. In particular, RDC uses proven security methods and procedures designed to safeguard Personal Data during transmission and storage.
We also take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it in the context of the Services or when you request their deletion, unless we are required by law to keep the information for a longer period. RDC performs periodic reviews of our databases, and have established specific time limits for data retention, based on the criticality of the Personal Data and the purposes of the data processing. Personal Data that is collected through our website will be retained for 3 years. Personal Data obtained from our Subscribers and Business Partners will be maintained for the length of the associated agreement and the required time after the termination to meet any contractual audit or regulatory obligations or to otherwise comply with applicable law.
6. DATA TRANSFERS & PRIVACY SHIELD
Individuals Located in the EEA, UK or Switzerland
If you are located in the EEA, UK or Switzerland, we comply with applicable legal requirements for the transfer of Personal Data to countries outside of the EEA, UK or Switzerland. In particular, RDC has put in place a number of measures designed to protect Personal Data which is transferred from Europe (including Switzerland) or UK to the US, India, Bangladesh, South America, China, Canada and the Asia Pacific. RDC maintains a network of specific agreements to require contracting parties to observe data protection legislation, such as the European Commission’s Standard Contractual Clauses. You may contact us as specified in the “How to Contact Us” section below to obtain a copy of these agreements. We may also transfer Personal Data to countries for which the EU Commission has issued an adequacy decision, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable.
The Personal Data provided by RDC to its Subscribers consists exclusively of “public record information” within the meaning of the Privacy Shield Frameworks. You may obtain a copy of this information from its public source.
We take commercially reasonable steps to ensure that Personal Data is reliable, accurate, complete, and current for its intended purpose, primarily by accessing Public Records and Publicly Available Data from reputable sources only.
If you believe we maintain your Personal Data within the scope of the Privacy Shield Framework, you may direct any of your inquiries or concerns concerning our Privacy Shield compliance to firstname.lastname@example.org, or using the contact details in the “How to Contact Us” section below. We commit to resolve complaints about our collection or use of your Personal Data. We will respond within 30 days. In the unlikely event that we fail to respond within 30 days, or if our response does not address your concern, we will undertake to refer the concern to our Data Protection Officer who will investigate the matter and communicate with you within 14 days.
We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. You can also follow that link for a description of the range of potential remedies. There are more details on the arbitration requirements of the Privacy Shield Frameworks at https://www.privacyshield.gov/.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We will continue to adhere to the Privacy Shield Principles for as long as we retain your Personal Data. Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
7. FEATURES AND LINKS TO OTHER WEBSITES
You may choose to use certain features for which we partner with other entities, or click on links to other websites for your convenience and information. These features, which may include social networking sites or apps, such as LinkedIn and Twitter, may operate independently from RDC. They may have their own privacy notices or policies, which we strongly suggest you review. To the extent any features or linked websites you visit are not owned or operated by RDC, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.
9. HOW TO CONTACT US
Regulatory DataCorp, Inc
211 S. Gulph Road #125
King of Prussia, PA 19406
Regulatory Datacorp Limited is the entity responsible for the processing of Personal Information that is subject to EEA or Swiss data protection law. You can write to us at:
One Ropemaker Street, Level 16
KingLondon EC2Y 9AW United Kingdom
Attn: Data Protection Officer
GDPR: Any GDPR related requests for information on whether or not your personal data is available through RDC products and services as well as any request for deletion or corrections to that personal data must be made by submitting this Request Form via email to GDPRRequest@rdc.com, or mailed to:
Regulatory DataCorp, Inc
211 S. Gulph Road #125
King of Prussia, PA 19406
RDC will need to have the information required in the Request Form before we can begin our research. You should receive all the information that has been located and can be released in accordance with the law, along with an explanation for any information that cannot be provided within 30 days. RDC does not release information held about individuals without their consent, unless there is a legally supported reason to do so. Therefore if information held about you also contains information related to a third party, RDC will make every effort to anonymize the information. If this is not possible, and RDC has been unable to secure the relevant consent, RDC reserves the right not to release the information.
Where possible, RDC will act on requests from individuals including right to erasure and accuracy of data. However, if RDC determines that retaining such personal data is necessary for its intended business purposes, RDC will provide the information and reasoning for the retention.
Last updated March 2019