Privacy Policy

1. Information We Collect

Information You Provide

• Account and identity information: name, email address, organization name, role, and contact details provided during onboarding.
• Corporate and personal documentation: certificates of formation, proof of address, tax forms, passports, ownership declarations, and other materials uploaded for KYB submissions.
• Entity information: legal entity structure, ownership graphs, control relationships, and business interview responses.
• Communications: messages, support requests, and feedback you send to us.

Information Collected Automatically

• Device and browser information: IP address, browser type, operating system, and device identifiers.
• Usage data: pages visited, features used, transaction history, and interaction patterns.
• Log data: server logs, error reports, and performance metrics.

Submission Data

• Counterparty submission records, including which documents and answers were shared with which counterparties.
• AI-generated answers, confidence scores, and source attributions.
• Access grant records, including who accessed shared documents and when.

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Platform.
• Process KYB submissions and facilitate document sharing with counterparties.
• Generate submission audit trails, compliance reports, and refresh alerts.
• Classify documents, extract structured data, and generate AI-powered answers using third-party AI providers.
• Communicate with you about your account, platform updates, and support inquiries.
• Detect, prevent, and address fraud, security issues, and technical problems.
• Comply with legal obligations and respond to lawful requests from authorities.

3. Data Sharing and Disclosure

We may share your information with:

• AI providers: such as Anthropic or OpenAI, to process document classification, data extraction, and answer generation. AI providers operate under data processing agreements with zero-training guarantees.
• Cloud infrastructure providers: for document storage, database hosting, and application deployment.
• Counterparties: documents and answers are shared with counterparties only when you explicitly submit them. Archway does not share your data with counterparties without your action.
• Service providers: including hosting, analytics, and communication services that assist in operating the Platform.
• Legal and regulatory authorities: when required by law, regulation, or legal process.

We do not sell your personal information to third parties.

4. Security Measures

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit and at rest.
• Multi-factor authentication and role-based access controls.
• Regular security audits and vulnerability assessments.
• Tenant isolation: each organization's data is strictly separated at the database level.

While we take reasonable steps to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. When data is no longer needed, we will securely delete or anonymize it.

Immutable submission snapshots (records of what was submitted to counterparties) are retained as part of the audit trail and cannot be modified or deleted, even upon account termination.

6. Cookies and Tracking Technologies

We may use cookies and similar tracking technologies to collect usage information and improve the Platform. These may include:

• Essential cookies: required for the Platform to function properly, including authentication and session management.
• Analytics cookies: used to understand how visitors interact with the Platform and to improve performance.

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

7. Third-Party Services

The Platform integrates with third-party services including AI providers, cloud infrastructure, and email services. These services have their own privacy policies and data practices. We encourage you to review their policies.

We are not responsible for the privacy practices of third-party services. Your interactions with these services are governed by their respective terms and policies.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: request a copy of the personal information we hold about you.
• Correction: request correction of inaccurate or incomplete information.
• Deletion: request deletion of your personal information, subject to legal retention requirements.
• Portability: request your data in a structured, machine-readable format.
• Objection: object to processing of your personal information for certain purposes.

To exercise these rights, contact us at [email protected]. Note that immutable submission snapshots in the audit trail cannot be modified or deleted.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We take steps to ensure that your data is treated securely and in accordance with this policy regardless of where it is processed.

10. Children's Privacy

The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Platform or via email. Your continued use of the Platform after changes constitutes acceptance of the updated policy.

12. Contact

If you have questions about this Privacy Policy, please contact us at: [email protected]