Privacy Policy

This privacy notice for ChatComply, Inc. ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://chatcomply.com, or any website of ours that links to this privacy notice;
• Engage with us in other related ways — including sales, marketing, demos, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. 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 support@chatcomply.com.

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below.

• →What personal information do we process? When you visit or use our Services, we may process personal information depending on how you interact with us, the choices you make, and the features you use. Learn more in Section 1.
• →Do we process any sensitive personal information? We do not solicit sensitive personal information through our website. ChatComply's Services may process sensitive information on behalf of our customers (for example, account numbers or other regulated data appearing in employee prompts), but in that capacity we act as a processor under our customer's direction. See Section 10.
• →Do we receive information from third parties? We may receive information from public databases, marketing partners, business-data providers, and other outside sources. Learn more in Section 1.
• →How do we process your information? We process your information to operate and improve our Services, respond to inquiries and provide pre-sales support, communicate with you, secure our systems, and comply with applicable law. Learn more in Section 2.
• →In what situations and with which parties do we share personal information? We may share information in specific situations and with specific categories of third parties. We do not sell personal information. Learn more in Section 4.
• →How do we keep your information safe? We maintain organizational and technical safeguards designed to protect your personal information. However, no electronic transmission or storage technology can be guaranteed 100% secure. Learn more in Section 7.
• →What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information. Learn more in Section 9.
• →How do you exercise your rights? The easiest way to exercise your rights is by contacting us at support@chatcomply.com. We will consider and act on any request in accordance with applicable data protection laws.

Want to learn more about what ChatComply does with the information we collect? Review the privacy notice in full below.

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you request a demo, participate in marketing programs, or otherwise contact us.

Personal information provided by you may include:

• Name
• Business email address
• Phone number
• Job title and department
• Employer name and details (firm type, approximate AUM, regulatory profile)
• Mailing or billing address (if you become a customer)
• Contact preferences
• Inquiry content (questions, use cases, or requirements you share with us)

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.

Sensitive personal information

We do not solicit sensitive personal information through our website or marketing channels. As described in Section 10, ChatComply's Services may process sensitive personal information on behalf of our customers (for example, financial account numbers, government identifiers, or other regulated data appearing in employee prompts that the Services are designed to detect and redact). In that capacity we act as a processor under the customer's direction.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information that is primarily used to maintain the security and operation of our Services and for our internal analytics and reporting.

The information we collect includes:

• Log and usage data — service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services. May include IP address, device information, browser type and settings, date/time stamps, pages and files viewed, and other actions you take on the Site.
• Device data — information about your computer, phone, tablet, or other device you use to access the Services, such as IP address (or proxy server), device and application identification numbers, browser type, hardware model, internet service provider, operating system, and system configuration.
• Approximate location data — geolocation derived from your IP address (city or region level). We do not collect precise geolocation.

Information collected from other sources

In order to enhance our ability to provide relevant marketing, offers, and Services to you and to keep our records current, we may obtain information about you from sources such as public databases, joint marketing partners, business-data providers, affiliate programs, and other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, intent data, IP addresses, social media profiles, social media URLs, and custom business profiles, for purposes of targeted advertising and event promotion.

2. How Do We Process Your Information?

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

• To respond to user inquiries and offer pre-sales support. We may process your information to respond to your demo requests, questions, and any potential issues with the Services.
• To deliver and facilitate delivery of the Services. We may process your information to provide you with requested Services or, where you are a customer, to operate the Services on your behalf.
• To send administrative information to you. We may process your information to send you details about our Services, changes to our terms and policies, security advisories, and other operational information.
• To send marketing communications. We may process your information to send you marketing and promotional communications, where permitted by law. You can opt out at any time.
• To improve and develop our Services. We may process information to analyze how the Services are used, identify trends, and develop new features.
• To secure our Services. We may process your information to monitor, prevent, and respond to fraud, abuse, security incidents, and unauthorized activity.
• To comply with legal and regulatory obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On to Process Your Information?

If you are located in the EEA 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 to process your personal information. As such, we may rely on the following:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including to provide our Services or at your request prior to entering into a contract.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests — such as marketing to business contacts, securing our systems, analyzing Site usage, and operating our business — and those interests do not override your interests and fundamental rights and freedoms.
• 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, or to exercise or defend our legal rights.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or those of a third party.

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

We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (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;
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
• If the information is publicly available and is specified by the regulations.

4. When and With Whom Do We Share Your Personal Information?

Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. They cannot do anything with your personal information unless we have instructed them to do it, and they will not share your personal information with any organization apart from us.

The categories of third parties we may share personal information with are as follows:

• Cloud computing and infrastructure providers
• Data storage service providers
• Customer relationship management (CRM) tools
• Email delivery and communication tools
• Sales and marketing tools
• Data analytics services
• Performance and error monitoring tools
• Website hosting service providers
• Payment processors (for customers)
• Finance and accounting tools
• Professional advisors (lawyers, accountants, auditors, insurers)
• Government entities (where required by law)

5. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific categories include:

• Strictly necessary cookies — required to operate the Site and provide its core functionality.
• Analytics cookies — help us understand how visitors interact with the Site so we can improve it.
• Marketing cookies — used (with consent where required) to deliver relevant advertising and measure campaign performance.

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. If you choose to remove or reject cookies, this could affect certain features of our Services. Where required by law (e.g., in the EEA or UK), we obtain your consent before placing non-essential cookies on your device.

6. How Long Do We Keep Your Information?

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).

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.

7. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process — including encryption in transit and at rest, access controls, network segmentation, vulnerability management, and personnel training. Our security program is designed against industry-recognized frameworks [reference SOC 2 / ISO 27001 / etc. as applicable].

However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

8. Do We Collect Information From Minors?

The Site and Services are intended for use by businesses and their representatives. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old. If we learn that personal information from users less than 18 years of age has been collected, we will 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, please contact us at support@chatcomply.com.

9. What Are Your Privacy Rights?

In some regions, you have certain rights under applicable data protection laws. These may include the right to:

• Request access to and obtain a copy of your personal information;
• Request rectification or erasure of your personal information;
• Restrict the processing of your personal information;
• If applicable, exercise data portability;
• Object to the processing of your personal information in certain circumstances;
• Withdraw consent where processing is based on consent.

You can make such a request by contacting us at support@chatcomply.com. 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 local data protection supervisory authority. Contact details are available at the European Commission's list of data protection authorities or the UK Information Commissioner's Office.

If you are located in Switzerland, the contact details for the data protection authority are available at the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the details below. However, this will not affect the lawfulness of the processing before its withdrawal nor, where applicable law allows, the processing of your personal information conducted in reliance on other lawful processing grounds.

Opting out of marketing communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us using the details below. You will then be removed from the marketing lists. However, we may still communicate with you to send service-related messages necessary for the administration of any contract or account, to respond to service requests, or for other non-marketing purposes.

10. ChatComply as a Processor / Service Provider

ChatComply's Services are designed to intercept, redact, and govern prompts submitted by a customer's employees to AI systems. In delivering this Service, ChatComply processes information on behalf of and under the direction of the customer (typically a regulated financial firm) — including potentially sensitive data such as account numbers, government identifiers, material non-public information, restricted-list references, or other regulated content that the Services are specifically designed to detect, redact, or block.

In this context:

• The customer is the "controller" (under GDPR), "business" (under California's CCPA/CPRA), or equivalent role under other applicable laws — they determine what data passes through ChatComply, how long it is retained, and who can access it.
• ChatComply is the "processor," "service provider," or equivalent — we process such data only on documented instructions from the customer and pursuant to our Data Processing Addendum (DPA).

11. 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.

12. Do California Residents Have Specific Privacy Rights?

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

1. Every individual who is in the State of California for other than a temporary or transitory purpose; and
2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We will use and retain the collected personal information as needed to provide the Services or for:

• Category B - As long as the user has an account with us
• Category I - As long as the user has an account with us
• Category L - As long as the user has an account with us

Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

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

• Receiving help through our customer support channels;
• Participation in customer surveys, webinars, or events;
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at support@chatcomply.com or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered "selling" of your personal information.

ChatComply, Inc. has not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. ChatComply has disclosed the categories of personal information identified above to third parties for a business or commercial purpose in the preceding twelve (12) months (see Section 4).

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law (such as our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities).

Right to be informed — Request to know. Depending on the circumstances, you have a right to know whether we collect and use your personal information, the categories of personal information that we collect, the purposes for which the collected personal information is used, whether we sell or share personal information to third parties, the categories of personal information that we sold, shared, or disclosed for a business purpose, the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose, the business or commercial purpose for collecting, selling, or sharing personal information, and the specific pieces of personal information we collected about you.

Right to non-discrimination for the exercise of a consumer's privacy rights. We will not discriminate against you if you exercise your privacy rights.

Right to limit use and disclosure of sensitive personal information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the Services.

Verification process. 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.

To exercise any of these rights, please email us at support@chatcomply.com.

13. Do Virginia Residents Have Specific Privacy Rights?

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data. The information we collect, use, and disclose about you will vary depending on how you interact with ChatComply, Inc. and our Services. To find out more, please visit the following links:

• Personal data we collect
• How we use your personal data
• When and with whom we share your personal data

Your rights with respect to your personal data

• Right to be informed 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 deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• 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")

ChatComply, Inc. has not sold any personal data to third parties for business or commercial purposes. ChatComply, Inc. will not sell personal data in the future belonging to website visitors, users, and other consumers.

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at support@chatcomply.com or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@chatcomply.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

14. International Data Transfers

ChatComply is headquartered in the United States. If you access the Services from outside the United States, your information will be transferred to, and processed in, the United States and other countries that may have data-protection laws different from those of your jurisdiction. Where required, we rely on appropriate safeguards (such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, and equivalent Swiss mechanisms) for international transfers of personal data.

15. Do We Make Updates to This Notice?

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last Updated" date and the updated version will be effective as soon as it is accessible. 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, you may email us at support@chatcomply.com.

17. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email us at support@chatcomply.com. We will respond to your request consistent with applicable law.

This Privacy Policy is provided for transparency about our data practices. It does not create a contract or any legal rights or obligations beyond those imposed by applicable law.