Privacy Policy
1. Introduction
This privacy policy tells you about the information we collect from you when you use our website. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.
1.1 Who are we?
We are AML RightSource, LLC. Our address is 1300 E. 9th Street STE 200, Cleveland, OH 44114. You can contact us by post at the above address, by email at: [email protected] or by telephone on 877.577.5463.
The contact details of our Privacy Officer are:
Annmarie Corrigan
1300 E. 9th Street STE 200, Cleveland, OH 44114
877.577.5463
The contact details of our Data Protection Officer are:
E.Rigter, Director, Privacy Company
Friedrichstraße 68, 10117 Berlin
+49 176 860 81 534
2. How we use your information
2.1 When you use our website
When you use our website to browse our products and services and view the information we make available, a number of cookies are used by us and by third parties to allow the website to function, to collect useful information about visitors and to help to make your user experience better. Some of the cookies we use are strictly necessary for our website to function, and we do not ask for your consent to place these on your computer. These cookies are shown below.
Our website is based on HubSpot CMS. To understand more about cookies in HubSpot CMS, please visit https://knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser.
In the following table you can find essential cookies and their purposes:
|
COOKIE NAME |
PURPOSE |
|
__hs_opt_out |
|
|
__hs_do_not_track |
|
|
__hs_initial_opt_in |
|
|
__hs_cookie_cat_pref |
|
|
hs_ab_test |
|
|
<id>_key |
|
|
__cfruid |
This cookie is set by HubSpot’s CDN provider because of their rate limiting policies. It expires at the end of the session. Learn more about Cloudflare cookies. |
|
__cf_bm |
This cookie is set by HubSpot's CDN provider and is a necessary cookie for bot protection. It expires in 30 minutes. Learn more about Cloudflare cookies. |
Table 1: Cookies (strictly necessary)
However, for following cookies that are useful but not strictly necessary we will always ask for your consent before placing them. These are:
|
COOKIE NAME |
PURPOSE |
|
__hstc |
|
|
hubspotutk |
|
|
__hssc |
|
|
__hssrc |
|
Table 2: Cookies (ask for consent)
As well as the cookies we use, various third parties also place them on your computer, again with your consent. These are shown below:
|
COOKIE NAME |
PURPOSE |
FURTHER INFORMATION |
|
Google Analytics |
We use Google Analytics to understand how our media campaigns work and how you interact with our website in order to improve the user experience. |
|
|
|
The LinkedIn insight tag allows us to perform campaign reporting and unlock valuable insights about website visitors that may come via the campaigns we run on LinkedIn. |
|
|
|
The Facebook insight tag allows us to perform campaign reporting and unlock valuable insights about website visitors that may come via the campaigns we run on Facebook. |
|
|
|
The Twitter insight tag allows us to perform campaign reporting and unlock valuable insights about website visitors that may come via the campaigns we run on Twitter. |
Table 3: Cookies (third parties)
2.2 Links to third party sites
The Web Site may include links to third party web sites whose privacy practices may differ from those of AML RightSource. Please be aware that those third-party web sites are outside of our control and are not covered by this Privacy Statement. If you submit personal information to any of those sites, your information is governed by their privacy policies. If you have questions about how another site uses your information, consult that site’s privacy statement.
2.3 When you submit an enquiry via our website
When you submit an enquiry via our website, we ask you for your name, contact telephone number, email address, job title, company.
We use this information to respond to your query, including providing you with any requested information about our products and services. We may also email you several times after your enquiry in order to follow up on your interest and ensure that we have answered it to your satisfaction. We will do this based on our legitimate interest in providing accurate information prior to a sale.
Your enquiry is stored and processed through our CRM. The information supplied is shared with the relevant department who can answer your enquiry and if you have selected to receive marketing content it will be shared with marketing.
We do not use the information you provide to make any automated decisions that might affect you.
We keep enquiry emails for two years, after which they are securely archived and kept for seven years, when we delete them. CRM records are kept for three years after the last contact with you.
3. How To Unsubscribe
You may cancel or modify the email communications you have chosen to receive from AML RightSource by following the instructions contained in emails from us. Alternatively, you may email AML RightSource at [email protected] with your request, stating ‘Unsubscribe’ in the header and what email addresses you wish not to receive AML RightSource emails. Within a reasonable period, we shall ensure that such email addresses are unsubscribed.
4. Policy Regarding Children
AML RightSource does not offer services to children under the age of 18 and this Web Site is not directed to or intended for use by children under the age of 18. AML RightSource does not intend to collect information about children under the age of 18 through the Web Site.
5. California Online Privacy Protection Act Compliance/Your California Privacy Rights
California residents who use the Web Site may request that we provide certain information regarding our disclosure of your personal data to third parties for their direct marketing purposes. You can make such a request by email to [email protected].
6. Information Specific to EEA and Swiss Users
The information in this section, which should be read together with the rest of this Privacy Statement applies solely to users in the European Economic Area and Switzerland (collectively, the “EEA”) and solely with respect to personal data we collect as a controller.
Individuals who reside in the EEA (“EEA Individuals”) are not required by statute or by contract to provide any personal data to us.
6.1 Transfers of Personal Information
The personal data collected by AML RightSource may be transferred to Hong Kong or other jurisdictions (which may include Germany and the United Kingdom (which are member states of the EEA), Canada, USA, Malaysia, Brazil and India). Canada is considered by the European Commission to offer an adequate level of protection for personal data as under GDPR. The European Commission has not issued a determination that Hong Kong, USA, Malaysia, Brazil or India ensure an adequate level of protection for personal data. For these countries, we have executed the European Commission’s standard contractual clauses to govern onward data transfers. To obtain a copy, you may email us at [email protected]
6.2 Legal Bases For Processing and Purposes
AML RightSource processes your personal data on the basis of your consent (where required by law), to provide you information about the products and services that we think might interest you; and to contact users who are not customers for marketing, advertising, and sales purposes.
AML RightSource also processes personal data as necessary for its legitimate interests in managing its business to increase its revenues and capitalize on opportunities while acting in compliance with law and managing risks. We rely on legitimate interests as the legal basis for processing personal data to share our Due Diligence Reports as part of our Databank Services; to operate, maintain and improve the Web Site; to aggregate information into non-identifiable information for benchmarking and other purposes; to conduct market research and analysis; to continuously evaluate and improve the online user experience; to try to ensure network and information security; to prevent fraud and to report suspected criminal acts; to manage or transfer our assets or liabilities, for example, in connection with an acquisition or merger, the provision of security for a credit facility, a corporate reorganization or the change of a supplier of products or services; and to protect the rights, property, or safety of AML RightSource, our users, or others in those cases where not required by law.
AML RightSource also processes personal data as necessary to perform a contract, such as to provide our contracted services to you; to operate AML RightSource’s business and provide and administer AML RightSource’s products and services; to set up client; to respond to your questions and requests for information; to respond to requests for service quotes; to respond to your inquiries about job postings; to provide newsletters and information about webinars and other events that you request; to register users for promotional materials and events at their request; to contact users with relevant information regarding system updates; to respond to questions and feedback; to investigate violations of AML RightSource’s terms of use; to maintain accurate customer records; and to collect debts owed to AML RightSource.
AML RightSource also processes personal data to comply with laws such as the UK Bribery Act, to protect the rights, property, or safety of AML RightSource, our users, or others where required by law; to respond to law enforcement; to conduct legal processes (such as in the case of litigation, which may involve the sharing of personal information with a judicial authority or parties to a lawsuit); and to respond to subpoenas and other legal requests.
6.3 Rights of EEA Residents
6.3.1 Right to Object to Processing for Direct Marketing or Legitimate Interests
EEA Individuals have the right to object to the processing of their personal data for purposes of AML RightSource’s direct marketing or, on grounds relating to the EEA Individual’s particular situation, for AML RightSource’s legitimate interests, by contacting AML RightSource at [email protected].
6.3.2 Other Individual Rights
Access, Correction, Deletion:
EEA Individuals have the right to access their personal data collected by AML RightSource and to request that AML RightSource update, correct, or delete their personal data as provided by applicable law. EEA Individuals also have the right to restrict AML RightSource’s processing of their personal data.
7. Data Portability
EEA Individuals have the right to data portability concerning their personal data. Subject to certain limitations, the right to data portability allows EEA Individuals to obtain from AML RightSource, or to ask AML RightSource to send to a third party a digital copy of the personal data that they provided to AML RightSource. EEA Individuals’ right to access their personal data includes their right to receive a copy of all, or a portion, of their personal data in AML RightSource’s possession as long as AML RightSource’s providing the personal data would not adversely affect the rights and freedoms of others.
8. Point of Contact/Complaints
EEA Individuals can exercise these rights by contacting [email protected]. AML RightSource will respond to such requests in accordance with applicable data protection law. If EEA Individuals believe that their personal data has been processed in violation of applicable data protection law, they have the right to lodge a complaint with the relevant data protection authority in the country where they reside, where they work, or where the alleged violation occurred.
9. Withdrawing Consent
EEA Individuals may use the contact information above, at any time, to withdraw their consent for the processing of their personal data where AML RightSource requires their consent as a legal basis for processing their personal data. Any withdrawal will apply only prospectively, and AML RightSource will continue to retain the personal data that EEA Individuals provided before they withdrew their consent for as long as allowed or required by applicable law.
9.1 Your rights as a data subject
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.
Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.
To submit a request regarding your personal data by email, post or telephone, please use the contact information provided above in the Who Are We section of this policy.
10. Your right to complain
If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. Please contact the Data Privacy Officer (preferably electronically) or via letter, clearly marked for the attention of the Data Privacy Officer, at this address:
The Data Privacy Company
Erwin Rigter, Director
Friedrichstraße 68, 10117 Berlin
+49 176 860 81 534
11. Updates to this privacy policy
We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.