Privacy Policy

Last updated April 3, 2026

This Privacy Notice for KYC Genie FZC LLC (doing business as KYC Genie) ("we," "us," or "our"), describes how and why we may access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@kycgenie.com.

SUMMARY OF KEY POINTS

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. SPECIAL NOTICE FOR B2B KYC DOCUMENT PROCESSING
  5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
  8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  9. HOW LONG DO WE KEEP YOUR INFORMATION?
  10. HOW DO WE KEEP YOUR INFORMATION SAFE?
  11. DO WE COLLECT INFORMATION FROM MINORS?
  12. WHAT ARE YOUR PRIVACY RIGHTS?
  13. CONTROLS FOR DO-NOT-TRACK FEATURES
  14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
  16. DO WE MAKE UPDATES TO THIS NOTICE?
  17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

We process personal data for two distinct groups of individuals:

Platform users (dashboard accounts)

If you use the KYC Genie dashboard as a client employee or team member, we collect:

  • Name, email address, and job title
  • Role and permissions within your organisation
  • Login activity, IP address, device and browser information
  • Account preferences and settings

KYC subjects (individuals and companies undergoing due diligence)

If you are an individual or company submitting information through a KYC or due diligence process on our platform — whether via a questionnaire, verification link, or document upload — the information collected may include:

For individuals:

  • Full name (including former names), date of birth, nationality, gender, country of birth
  • Email address, phone number, and physical address (street, city, state/county, postal code, country)
  • Identity document details (passport number, national ID number, driver's licence number, document expiry date)
  • Government identifiers where applicable to your jurisdiction: Social Security Number (SSN), Social Insurance Number (SIN), Emirates ID, NRIC, tax identification number, or equivalent
  • AML/sanctions screening results (PEP status, sanctions list matches, adverse media findings), risk score, and KYC review history
  • Questionnaire responses and uploaded supporting documents

For companies and legal entities:

  • Legal name, trading name, company registration number, and jurisdiction and date of incorporation
  • Registered and principal place of business address
  • Beneficial ownership and UBO information (linked to the individual data above)
  • Corporate structure documents (certificates of incorporation, articles of association, shareholder registers, etc.)
  • AML/sanctions screening results and risk classification
  • Questionnaire responses and uploaded supporting documents

Processing of KYC subject data is carried out on behalf of our clients (the data controllers) who instruct us to collect it. See Section 3B for full details of legal bases, retention, and your rights.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not specifically reveal your (or your company's) identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

Specifically, we collect your Internet Protocol (IP) address to identify the company or organisation from which you are accessing our site. This helps us understand our business audience and identify potential business leads. We also collect data on your browsing activity on our website (e.g., pages visited, time spent, specific interactions), which may be associated with the identified company.

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes, including for business development and targeted marketing efforts as further described in this Privacy Notice.

Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • Financial data and financial statements
  • Government-issued identifiers (Social Security Numbers, national ID numbers, Social Insurance Numbers, tax IDs, or equivalent)
  • Identity document details (passport numbers, national ID card numbers, driver's licence numbers)
  • Biometric data — facial images and liveness video collected during identity verification checks, processed solely by our sub-processor ComplyCube; KYC Genie does not store biometric data on its own systems

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts.
  • To deliver and facilitate delivery of services to the user.
  • To respond to user inquiries and offer support.
  • To send administrative information to you.
  • To identify potential business leads and for targeted marketing. We process IP addresses and related browsing data to identify the companies visiting our website. This allows us to understand our business audience, personalise our sales and marketing outreach, and develop more relevant products and services.
  • To conduct AML, sanctions, and PEP screening on behalf of our clients and to process the results of such checks for compliance and risk assessment purposes.
  • To verify the identity of individuals undergoing KYC checks, including processing identity documents and facilitating biometric liveness checks via our identity verification sub-processor.
  • To use AI to analyse documents and automate the completion and quality-checking of due diligence questionnaires on behalf of our clients.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we rely on our legitimate interests to process your IP address and the derived company information for understanding our website audience, identifying potential business-to-business (B2B) leads, and improving the effectiveness of our sales and marketing efforts. We have assessed our interests against your rights and freedoms and consider this processing proportionate.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the "data controller" under European data protection laws of the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform. This Privacy Notice does not apply to the personal information we process as a "data processor" on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the "data controller" responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

3B. SPECIAL NOTICE FOR B2B KYC DOCUMENT PROCESSING

In Short: If you submit company documents through our platform for KYC (Know Your Customer) verification, your data is processed based on legal obligation and contractual necessity, not consent. This means you have limited deletion rights due to mandatory regulatory retention requirements.

Who This Applies To

This section applies if you are:

  • A company director, officer, or authorized signatory
  • A beneficial owner (UBO) of a company
  • An individual submitting identity or verification documents for a company undergoing KYC

What Documents We Process

For B2B KYC purposes, we may process:

  • Company registration documents (certificates of incorporation, articles of association)
  • Beneficial ownership declarations and UBO information
  • Director and officer identity documents (passports, national IDs, driver's licenses)
  • Proof of address documents
  • Financial statements and audit reports
  • Business licenses and regulatory permits
  • Questionnaire responses and due diligence information

Legal Basis for KYC Processing

We process your KYC documents based on:

  • GDPR Article 6(1)(c) - Legal Obligation: Our clients (financial institutions, fund managers, regulated entities) are legally required to perform KYC and AML (Anti-Money Laundering) due diligence under:
    • 5th EU Anti-Money Laundering Directive (5AMLD)
    • UK Money Laundering Regulations 2017
    • Other applicable financial services regulations
  • GDPR Article 6(1)(b) - Contract: Processing is necessary to fulfill our service agreement with our clients and to enable the business relationship between our client and your company.

Please note: Because KYC processing is based on legal obligation, your submission of documents is not considered GDPR "consent". This means you cannot "withdraw consent" to stop processing, as the processing is required by law, not based on consent.

Mandatory Data Retention

Important: We retain KYC documents and associated personal data for 7 years from the end of the business relationship between our client and your company. This satisfies the minimum 5-year requirement under EU and UK AML legislation (5AMLD, UK MLR 2017) and aligns with the 7-year commercial record retention requirements applicable under UAE law and other international standards.

This retention period:

  • Is mandatory under law - we cannot delete earlier even if you request it
  • Starts from the end of the business relationship, not from document submission
  • May be extended if documents are subject to legal hold, regulatory investigation, or litigation
  • Applies even after your company ceases to exist or changes ownership

Limited Right to Erasure

Under GDPR Article 17(3)(b), the right to erasure does not apply when processing is necessary for compliance with a legal obligation.

This means:

  • We are unable to comply with deletion requests for KYC documents during the mandatory 7-year retention period.
  • If you submit a deletion request, we will:
    • Acknowledge your request within 30 days, as required by GDPR
    • Explain why we are unable to comply (legal obligation exemption)
    • Inform you of the applicable retention period
    • Confirm that you retain other rights (access, rectification, restriction)
  • Your data will be securely deleted after the retention period expires, unless extended by legal hold or regulatory requirement.

Your Rights for KYC Data

While deletion rights are limited, you retain these rights:

  • Right of Access (Article 15) — Available. You may request a copy of all documents and data we hold about you. We will respond within 30 days.
  • Right to Rectification (Article 16) — Available. If any information is incorrect or incomplete, you may request corrections. We will update records within 30 days.
  • Right to Restriction (Article 18) — Available. You may request that we restrict processing in limited circumstances (for example, while disputing accuracy). We may, however, still need to retain and store the data for regulatory compliance.
  • Right to Erasure (Article 17) — Limited. This right cannot be exercised during the mandatory 7-year retention period, as processing is required by legal obligation under GDPR Article 17(3)(b).
  • Right to Data Portability (Article 20) — Not applicable. Portability applies only to consent-based or contract-based processing, not processing carried out under legal obligation.
  • Right to Object (Article 21) — Not applicable. You cannot object to processing that is required by law.

Who We Share KYC Data With

Your KYC data is shared on a need-to-know basis with:

  • Our client — your data controller (the financial institution, fund manager, or regulated entity instructing the KYC process)
  • Microsoft Azure — encrypted document and data storage, user authentication, AI processing, and session management (EU), under Microsoft's standard Data Processing Agreement
  • ComplyAdvantage — AML, sanctions, PEP, and adverse media screening and ongoing monitoring (EU data centre)
  • ComplyCube — identity document verification and biometric liveness checks; biometric data is retained solely within ComplyCube's systems and is not stored by KYC Genie
  • SendGrid (by Twilio) — transactional email delivery of notifications and verification links only; no KYC document content is shared
  • Regulators and law enforcement if legally required or pursuant to a valid legal request

How to Exercise Your Rights

To exercise your rights regarding KYC data, please contact us at:

Please include: Your full name, company name, date of document submission (if known), and specific request type (access, rectification, restriction, or erasure).

Identity verification required: To protect your data, we will verify your identity before processing any request. This may involve requesting government-issued ID or other verification documents.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Internal Sharing. We may share the company information identified from IP addresses and related browsing data internally with our sales, marketing, and business development teams to facilitate targeted outreach, lead management, and to improve our understanding of business interests.
  • Service Providers and Third-Party Tools. We may share your information with third-party service providers who perform services on our behalf, such as hosting, data analysis, payment processing, email delivery, customer service, and marketing assistance. This includes integrating data, such as identified company information, into our Customer Relationship Management (CRM) systems (e.g., HubSpot) and marketing automation platforms to manage leads and facilitate targeted communications.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services for so long as such content remains accessible. You may contact us to request removal of your content from public areas of the Services.

Our sub-processors and key service providers

We use the following third-party sub-processors to deliver our services. Each processes personal data only as instructed and under contractual data protection obligations:

Sub-processor Purpose Data location
Microsoft Azure (Blob Storage, B2C, OpenAI, Redis Cache) Document storage, user authentication, AI processing, session caching EU
ComplyAdvantage AML, sanctions, PEP, and adverse media screening; ongoing monitoring alerts EU
ComplyCube Identity document verification, liveness/selfie checks, multi-bureau database checks (50+ countries). Biometric data is held solely on ComplyCube’s systems. UK / EU
SendGrid (Twilio) Transactional email delivery (verification links, questionnaire notifications). No KYC document content is shared. United States
HubSpot CRM and sales lead management. Receives website visitor IP and company data only — no KYC subject data. United States

For transfers to US-based providers (SendGrid, HubSpot), we rely on Standard Contractual Clauses (EU SCCs) and equivalent UK safeguards. For an up-to-date sub-processor list, contact privacy@kycgenie.com.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also collect your IP address to identify the company or organization from which you are accessing our site. This information is used to help us understand our business audience, identify potential business leads, and to inform our targeted sales and marketing efforts.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" under applicable US state laws, you can opt out by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.kycgenie.com/cookies.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including Microsoft Azure OpenAI Service. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

  • AI automation
  • AI document analysis
  • AI search
  • Image analysis
  • Text analysis

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

International Transfers for AI Processing

All AI processing is performed using Microsoft Azure OpenAI Service, with data processed within the European Economic Area. Processing is governed by Microsoft's Data Processing Agreement, which is incorporated into its standard service terms. Copies are available upon request by contacting privacy@kycgenie.com.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our infrastructure is hosted on Microsoft Azure. Our primary data centre is within the European Economic Area, and we may also utilise additional Azure regions to improve service performance for clients in other geographies. If you are accessing our Services from outside the EEA, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), and in other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

For transfers of personal information originating from the United Kingdom, we rely on the International Data Transfer Agreement (IDTA) issued by the UK Information Commissioner's Office (ICO), or the Addendum to the European Commission's Standard Contractual Clauses approved by Parliament under section 119A of the Data Protection Act 2018, as applicable. Copies of these transfer agreements are available upon request by emailing privacy@kycgenie.com.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Specifically, for data collected automatically, such as IP addresses and derived company identification information, we retain this data for a period necessary to fulfill our legitimate business interests in lead generation and targeted marketing, or as long as the identified company remains a qualified prospect in our systems. In our own systems, this does not exceed 12 months from your last visit to our website, unless a longer retention is legally required or permitted.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Special Retention for KYC Documents: Documents submitted for Know Your Customer (KYC) verification are subject to mandatory regulatory retention requirements. We retain KYC documents and associated personal data for 7 years from the end of the business relationship between our client and your company. This satisfies the 5-year minimum under EU/UK AML legislation (5AMLD, UK MLR 2017) and aligns with the 7-year commercial record retention requirements applicable under UAE law and other international standards. This period may be extended if documents are subject to a legal hold, regulatory investigation, or litigation. After the retention period expires, data will be securely deleted unless otherwise required by law.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through robust organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, and we cannot guarantee that unauthorised third parties will never be able to defeat those measures. You should take care to access the Services only within a secure environment and to keep your account credentials confidential.

Personal Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to individuals' rights and freedoms, we will notify the relevant supervisory authorities within 72 hours of becoming aware of the breach, where feasible, as required by GDPR Article 33 and UK GDPR Article 33. Where a breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, in accordance with GDPR Article 34 and UK GDPR Article 34, unless one of the exemptions under Article 34(3) applies (for example, where the data was encrypted and remains unintelligible). We will notify affected individuals by appropriate means.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at info@kycgenie.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information, particularly when it is processed for direct marketing purposes or based on our legitimate interests (such as the company identification from your IP address). You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent by emailing us at privacy@kycgenie.com with the subject line "Withdraw Consent", or by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. We will action your withdrawal without undue delay.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, please contact us using the details in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies, though this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://www.kycgenie.com/cookies.

If you have questions or comments about your privacy rights, you may email us at privacy@kycgenie.com.

Note for B2B KYC Document Submitters: If you submitted documents for KYC verification, your deletion rights are limited due to mandatory 7-year regulatory retention requirements. See Section 3B for details.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of the US, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name YES
B. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data YES — for KYC subjects only, where required for identity verification
C. Commercial information Transaction information, purchase history, financial details, and payment information NO
D. Biometric information Fingerprints and voiceprints YES — facial images and liveness video are collected during identity verification, processed solely by our sub-processor ComplyCube. KYC Genie does not store biometric data on its own systems.
E. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements YES
F. Geolocation data Device location NO
G. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities NO
H. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us NO
I. Education Information Student records and directory information NO
J. Inferences drawn from collected personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics YES
K. Sensitive personal Information Account login information, passport numbers, state id card numbers, national origin, citizenship or immigration status and financial information including account access details YES

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels
  • Facilitation in the delivery of our Services and to respond to your inquiries

We will use and retain the collected personal information as needed to provide the Services. KYC subject data (Category K) is retained for 7 years from the end of the business relationship, as required by applicable AML regulations.

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@kycgenie.com, or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill its applicable purpose, it may affect our ability to provide our services, in particular:

  • offer you the products or services that you want
  • respond to or help with your requests
  • manage your account with us
  • confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

Kingdom of Saudi Arabia

If you are located in the Kingdom of Saudi Arabia, the Personal Data Protection Law (PDPL) and its implementing regulations may apply to the processing of your personal information.

Under the PDPL, you may have the following rights:

  • The right to be informed about how your personal data is collected and used
  • The right to access a copy of your personal data
  • The right to correct incomplete or inaccurate personal data
  • The right to request destruction of your personal data once the retention period has expired and there is no longer a legitimate legal basis for retention
  • The right to object to processing of your personal data in certain circumstances

We process personal data of Saudi residents on the following bases under the PDPL: (a) where processing is necessary for the performance of a contract to which you are a party or to take pre-contractual steps; (b) where you have given your explicit consent; (c) where processing is required to fulfill a legal obligation under Saudi or international AML/KYC regulations; or (d) where processing serves our legitimate interests, provided those interests do not override your rights and interests.

Sensitive data (including identity documents and financial information processed for KYC purposes) is processed on the basis of legal obligation and, where applicable, with your explicit consent.

If you wish to exercise your rights under the PDPL or have any concerns about our processing of your personal data, please contact us at privacy@kycgenie.com. You may also lodge a complaint with the Saudi Data and Artificial Intelligence Authority (SDAIA) at www.sdaia.gov.sa.

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, please email us at privacy@kycgenie.com. For formal correspondence, you may also write to us at:

KYC Genie FZC LLC
Amber Gem Tower, Al Rashidiya 3
Ajman, United Arab Emirates

EEA Representative (GDPR Article 27)

For enquiries from residents of the European Economic Area, we have appointed an EU representative under GDPR Article 27. You may contact our representative at: privacy@kycgenie.com.

Note: Full Article 27 representative details (name and address of appointed representative service) will be updated here shortly. In the meantime, all EEA data protection enquiries can be directed to privacy@kycgenie.com.

United Kingdom

For UK data protection enquiries, please contact us at privacy@kycgenie.com. You also have the right to raise concerns directly with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, including your IP address data and any associated company identification information, please submit a data subject access request to privacy@kycgenie.com.