Privacy Policy

1. What Is the Purpose of This Privacy Policy?

This Privacy Policy explains how Kyros AML (“Kyros”, “We”, “Us”) collects, uses, shares, and protects personal data from individuals interacting with our website, using our products and services, and engaging with us in other ways. We gather data from:

• Visitors: Individuals who browse our website or communicate with us.
• Customers: Individuals who register to use our cloud-based AML software on behalf of a company or organization.
• Attendees: Individuals who participate in our events, webinars, or receive our marketing communications.
• Job Applicants: Individuals who apply for career opportunities at Kyros AML.

Our platform and services are specifically designed for businesses and their representatives, not for personal or household use. Therefore, all personal data we collect is considered to relate to individuals in their business capacity rather than their personal capacity. We value your privacy and are committed to safeguarding your personal data in compliance with GDPR and other applicable data protection laws.

2. How Does Kyros AML Handle Customer Data?

Kyros AML as a Data Processor

When customers use Kyros AML’s products and services, they may submit personal data for processing. Our security and privacy practices for storing, processing, transmitting, and disclosing customer data are defined and governed by our service contracts with customers. If a customer submits personal data of European individuals (including those in the United Kingdom and Switzerland) or others protected by similar data privacy laws, Kyros AML processes this data as a data processor or sub-processor.

Customers are responsible for creating policies that ensure compliance with all applicable laws related to collecting and submitting personal data to our services. This Privacy Policy does not cover personal data provided to us by customers. An individual wanting to access, correct, amend, or delete their data processed by Kyros AML should contact the customer (i.e., the data controller). Any request regarding personal data processed on behalf of a customer will be forwarded to that customer.

3. When Does Kyros AML Act as a Data Controller?

Kyros AML acts as a data controller when we determine the purpose and means of processing personal data, primarily for managing our business and delivering our services. Our legal basis for processing personal data includes:

• Consent: For example, when users voluntarily provide their contact details to receive marketing communications or sign up for a webinar.
• Contractual Necessity: When processing personal data is required to fulfill a contract, such as delivering our AML software to customers.
• Legitimate Interests: For purposes such as fraud prevention, IT security, and improving our services, provided these interests are not overridden by individual rights and interests.

The types of personal data we collect and handle include:

• Contact Information: Names, email addresses, phone numbers, and postal addresses.
• Professional Information: Job titles, company names, and department details.
• Technical Data: IP addresses, browser types, and activity on our website.

Examples of how we use personal data:

• To provide access to our AML software and customer support.
• To send product updates, newsletters, and marketing communications.
• To conduct surveys and gather feedback for improving our products.

4. Will My Data Be Transferred Internationally?

Kyros AML is committed to protecting your personal data according to EU data protection laws, particularly the General Data Protection Regulation (GDPR). Here’s how we ensure your data is handled securely:

Compliance with EU Data Protection Laws

Under the GDPR, international data transfers are regulated to ensure that data is adequately protected when transferred outside of the European Economic Area (EEA). Kyros AML ensures that all international data transfers comply with these requirements:

• Adequate Jurisdiction: Data is transferred to countries deemed to have an adequate level of protection by the European Commission, meaning they have laws that provide similar protection to the GDPR.
• Standard Contractual Clauses (SCCs): If data is transferred to countries without an adequacy decision, Kyros AML uses SCCs approved by the European Commission to ensure an equivalent level of protection for personal data.
• Binding Corporate Rules (BCRs): For intra-group data transfers, we may use BCRs approved by EU data protection authorities, ensuring a consistent level of protection across all our entities.
• Data Subject Rights: Regardless of the transfer mechanism, individuals have rights over their personal data, such as access, correction, and erasure, which Kyros AML respects and ensures are maintained.

Secure Data Handling

Kyros AML employs technical and organizational measures to secure personal data during transfers, such as:

• Encryption: Using encryption protocols to secure data during transfer.
• Access Controls: Ensuring only authorized personnel have access to data.
• Data Minimization: Limiting data transfers to only the essential information required for processing.

Our practices aim to provide the highest levels of data protection, ensuring your personal data is safely and lawfully transferred according to GDPR and other applicable EU regulations.

5. What Personal Information Does Kyros AML Collect and How Is It Used?

Categories of Personal Data Collected

Kyros AML collects the following categories of personal data:

Why Do We Collect This Data and Our Legal Basis?

We collect personal data to provide, improve, and secure our services while ensuring compliance with GDPR. The legal basis for processing personal data includes:

• Consent: For example, if you opt in to receive marketing emails or provide your data for a webinar.
• Contractual Necessity: For delivering services under a contract, such as providing access to our AML software and customer support.
• Legitimate Interests: When it’s necessary to process data for legitimate business purposes, such as ensuring network security, preventing fraud, and enhancing our services. We only rely on legitimate interests if they do not override your rights and interests.

How We Use Your Personal Data?

• Identification and Contact Information: To deliver services, send account notifications, and respond to inquiries.
• Professional Information: To provide personalized support and understand customer needs.
• Technical Data: To analyze website usage, improve security, and enhance the user experience.
• Marketing and Communications Data: To send marketing communications and respond to user feedback.
• Behavioral Data: To improve website functionality and tailor content based on user preferences.

All data is collected and used in compliance with GDPR and other applicable laws to provide a safe and efficient experience with Kyros AML’s services.

6. How Does Kyros AML Collect My Personal Data?

Kyros AML collects personal data both actively and passively when you interact with our website or contact us directly. We collect personal data in the following ways:

• Active Collection:
  • When you complete forms on our website, such as requesting a demo or applying for a job.
  • When you perform search queries on our website.
  • When you contact us via email or social media.
  • When you request assistance from our support team.
  • When you respond to surveys or provide feedback.
  • When you register for or attend our marketing activities.
  • When you participate in contests or giveaways.
• Passive Collection:
  • Automatically, as you navigate our website through cookies and similar technologies.
  • When you use our website, IP addresses, browser types, operating systems, and browsing activity are collected to understand your usage patterns and improve our services.

Does Kyros AML Collect Personal Data Automatically?

Kyros AML automatically collects certain information about your device and usage through cookies and other tracking technologies:

• IP Address: To understand geographical location and improve our services.
• Browser Type and Operating System: To optimize our website’s compatibility.
• Referring and Exit Pages: To analyze user journeys and improve navigation.
• Timestamp Data: To understand usage patterns and peak traffic times.
• Clickstream Data: To analyze trends and administer the site.

This data helps us improve user experience and analyze trends. Users can control cookie usage at the browser level but disabling cookies may limit access to certain website features.

How Does Kyros AML Use My Personal Data?

We use personal data to enhance your experience with our services:

• To display website content and provide secure access to our services.
• To fulfill service requests, including providing technical instructions and customer support.
• To notify you about account and subscription details, including renewals.
• To send you promotional material about our services and events.
• To plan and host marketing activities and communicate corporate events.
• To process contest or giveaway entries and distribute rewards.
• To carry out obligations and enforce rights under contracts, including billing and collections.
• To comply with legal and regulatory requirements.
• For any other purpose with your consent.

How Long Does Kyros AML Retain My Information?

Kyros AML retains personal data for as long as necessary to provide services or fulfill contractual obligations. Generally, data is retained for the duration of the business relationship plus 5 years, or longer if required by law or necessary for legitimate business interests, such as maintaining records of preferences, conducting audits, resolving disputes, and enforcing agreements.

7. Does Kyros AML Share Data with Third Parties?

As a general rule, Kyros AML does not sell, trade, or otherwise transfer your personal data to third parties. However, we may share your data with third-party service providers to support our business operations.

Third-Party Service Providers

We engage third-party service providers to support the operation of our business. These service providers may include cloud storage services, payment processors, security tools, and customer relations management tools, among others. Kyros AML shares personal data with these service providers solely for providing their contracted services to us. The service providers are not authorized to process personal data for any other purpose than what is necessary to deliver their services to Kyros AML. Kyros AML carefully vets all data processors to ensure they can uphold our standards for security and confidentiality. We enter into data protection agreements with each provider, which require them to maintain the privacy and security of any personal data they process.

Affiliates

Kyros AML and its affiliates share data to facilitate global business operations. This may include providing services, managing customer relationships, and fulfilling contractual obligations. Affiliates are also bound by our data protection standards to ensure consistency and security.

 Third-Party Cookies

Kyros AML utilizes third-party cookies and similar technologies, as detailed in our Cookie Policy. These tools may gather information about your activities on our website to enhance user experience, analyze website usage, and provide tailored content.

Consent

We may disclose personal data to third parties when explicitly authorized by you, provided that you receive appropriate notice and have the opportunity to consent to such sharing.

Compliance with Laws, Law Enforcement Requests, and Protection of Our Rights

Kyros AML may disclose personal data to public authorities or comply with legal processes, such as subpoenas or court orders. Disclosure may also occur to protect our rights, property, or safety or to prevent illegal activities and fraud.

Corporate Events

In the event of a merger, acquisition, restructuring, or other transfer of assets, personal data may be transferred as part of the transaction. We will inform users of any significant changes in ownership and provide options regarding data usage.

Referrals

If you refer someone to Kyros AML and provide their contact details, we may disclose you as the source of the referral while reaching out to the referred individual.

Data Supplementation

Kyros AML may receive additional information about you from public sources or third-party providers to enhance existing data. This helps us maintain accurate records and tailor services to your needs. We will only use personal data for the specific purposes for which it was originally provided, and if collected for marketing, we will offer the option to opt out of further communications.

How Is My Personal Data Handled by Third-Party Sites?

Our website may link to third-party sites with different privacy practices. If you submit personal data to those sites, their privacy policies apply. We encourage you to review their policies before submitting any data.

8. What Rights Do I Have Over My Data?

The following table outlines your rights regarding your personal data that Kyros AML controls:

If you have any concerns or need to report a violation, please contact us at post@kyrosaml.com.

9. How Does Kyros AML Protect My Data?

We prioritize the protection of your personal data and have implemented robust security measures to safeguard it from accidental loss, unauthorized access, misuse, alteration, and disclosure:

• Encryption: Sensitive information is encrypted using Transport Layer Security (TLS) to protect data during transmission.
• Secure Servers: Data is stored on secure servers with firewall protection to prevent unauthorized access.
• Access Controls: Only authorized personnel have access to your personal data, and their access is based on their job responsibilities.
• Security Protocols: Regular security audits, penetration testing, and adherence to industry standards help maintain high security standards.

While we work hard to protect your data, you also play a crucial role in keeping it safe:

• Password Protection: Ensure your account is protected by a strong password that is kept confidential.
• Sharing Information: Be cautious about sharing personal data in public forums, such as message boards, where others can access the information.

Data transmitted over the internet cannot be guaranteed to be completely secure. Kyros AML cannot be held responsible if users bypass any privacy settings or security measures on our websites.

Limiting Access to Personal Data

We limit access to personal data through the following measures:

• Role-Based Access: Access to data is restricted to authorized employees who require it for their roles.
• User Settings: Our platform allows you to control certain privacy settings via your account profile.
• Monitoring and Auditing: We monitor data access and conduct regular audits to ensure compliance with security protocols.

10. What Else Do I Need to Know About My Privacy?

Special Data Protection for Users Under 16

Our services are not intended for children under 16 years old. We do not knowingly collect personal data from individuals under 16. If you are under 16, do not provide any information on our website, register for our services, or submit any personal data to Kyros AML. If we discover that personal data from individuals under 16 has been collected, we will immediately delete it. If you suspect that we might have collected information from a child under 16, please contact us using the information provided below.

Your Privacy Rights as an EU Resident

As an EU resident, you have rights under the GDPR, including the right to:

• Access, correct, or delete your personal data.
• Restrict or object to the processing of your data.
• Withdraw consent for data processing.
• Port your data to another provider.
• These rights may be subject to certain limitations as per GDPR. Please refer to the “What Rights Do I Have Over My Data?” section for more details on how to exercise these rights.

11. How Do We Update and Revise Our Privacy Policy?

Kyros AML regularly reviews this Privacy Policy to ensure it reflects current practices and legal requirements. Any changes or updates will be posted on this page, and the revision date will be updated. Please review this page periodically to stay informed about any changes.

12. How Can I Contact Kyros AML About Privacy?

If you have any questions, comments, or concerns regarding this Privacy Policy and our data privacy practices, please reach out to us at post@kyrosaml.com.