What information do we collect?
We collect personal information from you when you provide it to us directly and through your use of an iProov Site. This information may include:
- information you provide to us, including when you use an iProov Site, such as your name, contact details and details about your interactions on IProov Sites;
- records of your interactions with us (for example if you contact a member of our team or interact with us through social media);
- information collected automatically, using cookies and other tracking technologies, such as which pages you viewed and your movement around iProov Sites; and
- preferences for the marketing you wish to receive from us and your communication preferences concerning that marketing.
We may also receive personal information about you from third parties, such as information provided by businesses with which we partner to market iProov or its services.
When we refer to personal information, we mean personal data (as it is defined under the United Kingdom’s data protection laws).
What do we do with your personal information?
Depending on how you use the iProov Sites and your interactions with us, the purposes for which we use your personal information include:
- to provide a personalised experience on the iProov Sites;
- to manage and respond to any queries you may raise with our customer service team;
- to improve and maintain the iProov Sites, and monitor their usage;
- for market research – for example, we may contact you for your opinions and comments;
- to send you marketing messages and show you targeted content or advertising; and
- to comply with our legal and regulatory obligations.
We will only use your personal information for the above purposes, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our legal basis for processing your personal information?
We rely on the following legal bases, under data protection law, to process your Personal Information:
- because the processing is necessary to take steps prior to entering into a contract with you or a business you represent.
- because it is in our legitimate interests in conducting our business, including:
- to market and promote iProov and its services;
- to tailor that marketing and your use of iProov Sites;
- to correspond with you about your or your business’s actual or potential use of iProov’s services;
- to research the use that is made of iProov Sites or the issues that are raised by people who correspond with us; and
- to increase our understanding of those people and the businesses they represent.
- otherwise because we have your consent or are legally permitted to do so.
Whom will we share your personal information with?
We may engage third parties to process your personal information for the purposes mentioned above, such as:
- website and app hosting services;
- messaging and SMS push communications services;
- online and offline marketing services;
- our professional and legal advisers;
If we sell our business or assets, your personal information may be provided to the prospective purchaser’s advisers with appropriate legal protections and will be passed to the new owners of the business.
We may also share your personal information with others where to do so is mandated by applicable law.
How long will we keep your personal information for?
We will keep your personal information for as long as we need it for the purposes set out above: this period will vary depending on your interactions with us and the nature of the personal information concerned.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of that data, the purposes for which we process it, whether we can achieve those purposes through other means, as well as legal, taxation and accounting requirements.
When the need to keep your personal information ends, we either delete or anonymise it.
How do we keep your personal information secure?
We have put in place appropriate security measures intended to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your legal rights
Under the law, you have the right to:
- Request access to your personal information (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 your personal information 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.
- Object to processing of your personal information where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. The right to object to processing does not apply where our basis for processing your personal information is something other than legitimate interests – such as where we have your consent to the relevant processing.
- 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 information (where consent is the basis upon which we process your personal information), or to profiling by means of your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You will not have to pay a fee to exercise any of your legal rights as specified above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive; alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the relevant personal information (or to exercise any of your other legal rights). This is a security measure we take to help avoid your personal information being disclosed to a person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to help speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Transferring your personal information from the EU to third countries
The Personal Information iProov collects from you may be transferred and processed outside of the EU / EEA on our sub processor platforms. iProov relies on Article 49 of the GDPR as the basis for such transfers. iProov collects and transfers Personal Information outside of the EU / EEA only with your consent, to perform a contract with you or to fulfil a legitimate interest in a manner that does not outweigh your privacy rights. Where transfers of Personal Information are made, the mechanisms are in place to ensure that Personal Information is treated appropriately with legal requirements for compliance being met.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so would request that you contact us in the first instance.
We are registered with the Information Commissioner's Office (ICO) under number ZA441165.
iProov Limited (we, us or iProov) 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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