Data Privacy

Introduction Complix (“COMPLIX”), is committed to protecting your privacy.

In this Data Privacy Statement, the terms “Controller”, “Processor”, “Personal Data” and “Processing” shall have the meaning given to these terms in the EU General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) (“EU Data Protection Law”).

This Data Privacy Statement explains how your Personal Data is processed by COMPLIX, as data Controller for the data Processing activities described in this Data Privacy Statement.

It applies to data collected through our website or collected during interactions you may have with us (e.g. when you call us or send us emails, or use our developer portal or services). COMPLIX will process all your Personal Data in compliance with the EU General DataProtection Regulation (Regulation (EU) 2016/679).

This Data Privacy Statement does not apply to any Personal Data Processing by COMPLIX when providing its InteliList and FCGuard production services to its clients or partners. Such Personal Data Processing - where COMPLIX acts as data Processor - is covered through the specific Data Processing Agreements separately signed with each of our clients and partners.

COMPLIX may modify this Data Privacy Statement from time to time. This Data Privacy Statement was last updated on 14 Febuary 2024.

COMPLIX purposes COMPLIX processes Personal Data collected on our website or through the interactions you have with us for the following purposes:

The operation and improvement of our website; The provision of COMPLIX services, including its developer portal; The analysis of end users’ usage data for product development and customer experience improvement; Sending commercial or operational communications, newsletters, new software release updates and other customer communications; The management of contacts and relationships with our customers, partners, prospects and suppliers; and Talent recruitment and HR management. Data collected For the above-mentioned purposes, COMPLIX will generally process the following data pertaining to you (depending on communication channel you use and type of activity): identification and contact information (e.g. last name, first name, job title, company name, contact details - such as mobile, landline, e-mail or post address), IP address, login and password, the history of your interactions with COMPLIX (e.g., connection logs, meetings), and any other messages (e.g. content of e-mails or web-forms) you would exchange with us.

For recruitment and subsequent HR management, we may also process additional Personal Data such as date of birth, CV, Educational training, national id number, nationality, immigration status, marital status, employment history, diplomas and bank account number.

Ways of collecting your data You directly provide COMPLIX with most of the data we collect. We collect data and process data when you:

Register to our developer portal; Place an order for or register to any of our products or services; Register to our operational notifications or newsletters; Communicate with us via e-mail, video conference or phone or through our website’s contact forms; Provide feedback on any of our products or services or complete a customer survey; Provide your Personal Data during the recruitment process; or View our website via your browser’s cookies. For recruitment and subsequent possible HR management, we may also indirectly receive Personal Data information from the external HR Management companies we may use.

Operation and improvement of our website COMPLIX has a legitimate interest to process your Personal Data for the operation and improvement of its website as detailed below:

IP addresses. For our internal purposes, we may use IP addresses (the Internet address of your computer) stored in web logs to generate aggregate statistics on the usage of our website, such as navigation path, volumes or time spent on a page. Cookies. Our website uses cookies. The information stored in cookies may include your name, first name, navigation behaviour, login ID, and IP addresses. In addition, our website uses Google Analytics. Our related Cookie Policy provides a detailed description on the use and purposes of cookies via COMPLIX’s website. Your Personal Data will be kept until the information is no longer necessary for the purposes for which we process it. This typically means no longer than three years after your last interaction with COMPLIX.

Operation, improvement and safeguard of our developer portal and infrastructures When you submit your Personal Data through our developer portal or with regard to your company accessing our production environment, COMPLIX has a legitimate interest to process your Personal Data (for example, your personal identification data) to get in contact with you in order to obtain additional information or take specific actions related to possible vulnerabilities or malicious activity.

Analysis of end users’ usage data for product development and customer experience improvement COMPLIX has a legitimate interest to analyse and produce reports about the usage of its products and services for the following purposes:

Create internal reporting about the individual or aggregated usage of the products, services, and use it to improve the quality of our products or services; Resolve product/service support cases that you may have; Provide specific training or awareness communication to our customers and partners; Produce aggregated statistics about the usage of our products, services or website. Your Personal Data will be kept until the information is no longer necessary for the purposes for which we process it. This typically means no longer than three years after your last interaction with COMPLIX.

Marketing and operational communications and management of our relationships with our customers, partners, prospects and suppliers COMPLIX has a legitimate interest to process Personal Data that you submit on our website or during your interactions with us (for example, subscription to our developer portal, purchase or use of our products), to provide you with commercial or operational communications related to COMPLIX products and services. In this respect, if you or your company are a COMPLIX customer or partner, we might send you communications related to the COMPLIX products or services that you use or purchased.

From time to time, COMPLIX may send you invitations to participate in market research or surveys in order to gather feedback on existing products and services or on future product developments. It is both COMPLIX’s and its customers’ legitimate interest to identify how to improve the quality of COMPLIX services and products through surveys, in compliance with the recipients’ preferences. If you do not wish to receive such surveys or market research, you may choose to opt out from these.

COMPLIX would also like to send you information about our products and services that we think you might like. If you have agreed to receive marketing communications, you may always opt out at a later date. You have the right at any time to stop COMPLIX from contacting you for marketing purposes.

Your Personal Data will be kept until the information is no longer necessary for the purposes for which we process it. This typically means no longer than three years after your last interaction with COMPLIX. COMPLIX may however keep the information for a longer period of time if we are required by law or to defend our rights.

Talent recruitment and HR management When you send us a spontaneous application or interact with our staff, you provide us with Personal Data in order