iProov Privacy Policy for User Demonstration App (Survey)


  1. Introduction

This Privacy Policy provides information on how iProov Limited (“iProov”, “we” or “us”) collects, uses and shares your personal data when you interact with iProov through iProov’s demonstration app (“User Demonstration App”) that is made available to you for the purpose of our survey.

iProov is committed to protecting your privacy when we process User Demonstration App participant (“user”) data. This Privacy Notice explains what personal information we collect from the user, how we use it, and the user’s privacy rights.

 “Personal Data” means any information provided by you that relates to you as an identified or identifiable individual.

This Privacy Policy only applies where iProov, for data protection purposes, is the controller of your Personal Data.

When we refer to iProov in this Privacy Policy, we mean us and/or the iProov Service, according to the context.

  1. Scope

The objective is for you, as a user, to assess your experience of our User Demonstration App, and to provide us with the benefit of your assessment in a survey.

  1. Our Responsibilities

iProov is responsible for adhering to applicable laws that relate to controllers of Personal Data.

  1. What Personal Data do we Process?

Each time you give us permission to do so, such as by clicking to give your consent on the User Demonstration App, you authorise us:

  • to record and upload to iProov images of you (“User Images”)
  • to use a unique identifier that we associate with your User Images;
  • to collect other data (we refer to this as Associated Data) in connection with the device through which User Images are provided (your device), which we use to assist in authenticating you and profiling your device to reduce the risk of impersonation, namely:
    • a unique identifier that we associate with your User Images;
    • data from the gyros and accelerometers of your device;
    • device type, model, and identifier; and
    • the IP address of your device, and its network interfaces.


  • To collect your survey data – The survey responses are anonymised. There is no link between your User Images and your survey responses. The survey link contains a one time universally unique identifier (“Survey ID”). . 

Anonymised data could be derived from your Personal Data but does not itself constitute.

  1. How it works and how we use your Data

You, the user, will have been invited to provide your feedback on the iProov application through a business that you may have a relationship with (a “Participating Company”). You will then have the opportunity to experience the User Demonstration App’s end user journey (your “user journey”).

Once you have experienced the user journey, you will have access to a survey to complete. The user journey and survey are not linked to a common identifier. The Survey ID is solely generated so that a Participating Company can be informed that you have submitted a completed survey.  Any payment for completing a survey is owed to you by the Participating Company, and not by us.  All survey  responses are anonymous.

Each user journey consists of two User Demonstration App authentication attempts and an associated opportunity to complete a survey.

User Images are created when you use the User Demonstration App. These are passed through a series of biometric tests.  They are not used to match your User Images to any other images of your, or otherwise to identify you. 

Survey data provided by you is anonymized and aggregated with survey data provided by others, and the overall information aggregated data will be used to help us to improve people’s experience of iProov’s authentication services.

  1. What is our Lawful Basis for Processing your Data?

Our relevant legal basis (Our basis) for processing your personal data is:

Consent: We obtain consent to the processing of your User Images and Associated Data.

  1. How long do we keep your data?

We will retain your User Images for no longer than 24 hours after we collect them. They will be automatically deleted within before the end of that period. 

  1. Who do we share your personal data with and Is my Personal Data exported?

iProov hosts your Personal Data in the United Kingdom and in the European Economic Area. 

  1. How is my Personal Data Secured?

iProov has implemented relevant security and privacy policies, controls, and measures to adhere to and to meet the requirements of the Data Protection Act 2018. These include regular security tests and independent assessment and certification to certain international information security standards.
iProov ensures that the appropriate organisational, technical, and physical security measures are in place intended to protect your Personal Data against accidental, unlawful destruction or loss, damage alteration disclosure, access, or use.

iProov ensures that the appropriate organisational, technical, and physical security measures are in place intended to protect your Personal Data against accidental, unlawful destruction or loss, damage alteration disclosure, access, or use.

  1. What are Your Privacy Rights?

Under the law, you have the right to:

Request access to your Personal Data (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal information. This enables you to ask us to delete your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with a legal or regulatory obligation. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; or (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format.

Withdraw consent to the processing of your personal data, or to profiling by means of your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

When you make a request, iProov will try to respond to all requests within thirty (30) days. Where it is not possible to do so, we will write to you to inform you that it will take longer to meet the requirements of your request and we will aim to respond within ninety (90) days. Where we cannot respond within this time period, we will notify you of why and of your user’s rights.

11.Disputes or Filing a Complaint

You have the right to make a complaint at any time to a data protection Supervisory Authority in your jurisdiction. A list of EU Supervisory Authorities can be found here : https://edpb.europa.eu/about-edpb/about-edpb/members_en 

In the UK, the Supervisory Authority is the Information Commissioner’s Office (ICO) (www.ico.org.uk). 

If you are located outside of the EU or UK, please contact the Data Protection Supervisor within your state or region.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or another Supervisory Authority, and as such we would request that you contact us in the first instance.

We are registered with the ICO under number ZA441165.

12.Contacting Us

We have a Data Protection Officer; whose email address is DPO@iproov.com . If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our Data Protection Officer.

If you have any questions about this Privacy Policy or about any requests to exercise your legal rights, please send an email to this email address.

iProov has appointed an EU representative who can be contacted at:

iProov Netherlands B.V.

Siriusdreef 17 Transpolispa,



Email: eurepresentative@iproov.com

Company Number 74408259

13.iProov’s Registered Office

iProov Limited is a company incorporated in England & Wales under company number 07866563 whose registered office is at 14 Bank Chambers, 25 Jermyn Street, London SW1Y 6HR, England.

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