Information You Provide To Us
When you register for an account with Verif-y and/or use our Services, we collect a wide range of PII that you provide directly to us, which may include name, physical address, email address, telephone number, state or national ID card number, passport number, other ID card number. In some cases, we may collect a visually scanned or photographed image of your identification card, and/or the photograph and information page of your passport.
Information We Collect Automatically When You Use Our Services
In addition to the PII described above, Verif-y may automatically collect, store and analyze data from your computer or mobile device. Verif-y automatically collect IP addresses and web site usage information when you access our Services, such information includes, the type of browser you use, access times, pages viewed, location, the page you visited before navigating to our platform, information about the computer or mobile device you use to access our platform, including the hardware model, operating system and version, unique device identifiers and mobile network information. This information helps us evaluate how our visitors and subscribers use and navigate our platform on an aggregate basis, including but not limited to the number and frequency of visitors and subscribers to each web page, and the length of their visits. Verif-y reserves the right to match your IP address (or any other data) with other data about you in any way permitted by applicable law.
Information We Collect From Other Sources
Information Through Other Services
You may give us permission to collect your information in other services. For example, you may connect a social networking service (“SNS”) such as Facebook or Twitter. When you do this, it allows us to obtain information derived from those accounts.
USE OF YOUR PERSONAL INFORMATION
We use PII collected for the following purposes:
- the purposes you specifically provided the information;
- to register you as a client and establish an account for you;
- to provide you with the Services you signed up for;
- to send you email notifications about our new or existing products and services, special offers, to request participation in surveys and/or other forms of market research to improve our products and services, or to otherwise contact you;
- to send emails to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- to enhance existing features or develop new features, products, and services;
- to provide advertisers and other third parties with aggregate information about our user base and usage patterns;
- to detect and prevent fraudulent transactions;
- to ensure internal quality control;
- to enforce our Terms;
- to perform accounting, auditing and other internal functions; and/or
- to carry out any other purpose for which the information was collected.
Retention Of PII
Verif-y retains the PII we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Our Legal Bases For Handling Of Your PII
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your PII. To the extent those laws apply, our legal grounds are as set forth below.
- To honor our contractual commitments to you: much of our processing of PII is to meet our contractual obligations to our users. For example, we handle PII on this basis to create your account and provide our Services.
- Legitimate interests: in many cases, we handle PII on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: this includes:
- providing a safe and enjoyable user experience;
- customer service;
- marketing, e.g. sending emails or other communications to let you know about new features;
- protecting our users, personnel, and property;
- analyzing and improving our business, e.g. collecting information about how you use our Services to optimize the design and placement of certain features; and
- Managing legal issues.
- Legal compliance: We need to use and disclose PII in certain ways to comply with our legal obligations.
- Consent: Where required by law, and in some other cases, we handle PII on the basis of your express or implied consent.
- To protect the vital interests of the individual or others.
Verif-y is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties, as set forth below:
Consent: We may share information about you with your consent or at your direction.
KYC: You understand and acknowledge that among the Services we perform are know your customer services (“KYC”).When performing KYC Services, we are hired by a third party to collect your PII for KYC purposes. When you submit PII for KYC purposes you hereby consent to Verif-y disclosing any portion of such PII submitted for KYC purposes, as permitted by applicable laws and regulations, to the third party who has hired us to perform KYC services.
Related Companies, Agents, Consultants and Related Third Parties: We may share information about you with Verif-y related companies as part of the delivery of our Services to you. We may share information about you with affiliates, consultants, and other service providers to enhance the Services and products we can provide to you or for legal and routine business reasons. The types of service providers to whom we entrust PII include service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; (iv) customer service activities; (v) fraud prevention; and (vi) in connection with the provision of the Services.
Legal Requirements: We may release personal information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order, or (2) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our system or network, or cases in which we believe it is reasonably necessary to investigate or prevent harm, fraud, abuse, or illegal conduct.
Business Transfers: If all or part of our company is sold, merged or otherwise transferred to another entity, the PII you have stored with us may be transferred as part of that transaction.
Aggregated Non-Personal Information: We may share aggregated non-personal information about you with third parties. This is information that is combined with the non-personal information of other Users and does not include PII. We also may not limit the third parties’ use of the aggregated information.
YOUR ABILITY TO SHARE YOUR PII
Some of our Services allow you to share your Verif-y profile and other PII you have disclosed on the Verif-y platform to third parties. You are the only one that can consent and request that your information be sent to a third party for viewing. Once you direct Verif-y to send your PII to a third party, Verif-y is not liable for any of such PII sent to the requested third party. We encourage you to read or discuss privacy policies and confidentiality issues with the third party you are sending your Verif-y profile to.
WHERE INFORMATION IS PROCESSED – YOUR CONSENT TO PROCESSING AND TRANSFERRING YOUR PII IN AND TO THE U.S. AND OTHER COUNTRIES
YOUR CONSENT TO VERIF-Y EMAILING YOU
By using the Services or providing your PII to us, you agree that we may communicate with you electronically regarding security, privacy, administrative issues and promotional matters relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on www.verif-y.com or sending an e-mail to you. You may have a legal right to receive this notice in writing.
You may provide us with ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
We take appropriate technical and organizational measures against unauthorized or unlawful processing of PII and other data and against accidental loss or destruction of, or damage to, PII and other data. Please accept however, no security measures are perfect or impenetrable, and Verif-y cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. Verif-y is not responsible for the circumvention of any privacy settings or security measures contained on the Verif-y platform by any users or third parties.
We will provide reasonable opportunity for individuals to access, update, or delete PII about them that we have in our possession. We will not use PII provided to us for purposes incompatible with the purpose for which it was provided without obtaining authorization from the subject of the information. If you wish to request access, or deletion of your personal information please contact us at firstname.lastname@example.org. Note that we may retain certain information as required by law or for legitimate business purposes. We will respond to your request within a reasonable timeframe, usually within thirty (30) business days.
Although Verif-y makes good faith efforts to provide individuals with access to their PII, there may be circumstances in which Verif-y is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If Verif-y determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.
The rights and options described above are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
WHAT YOU CAN DO TO KEEP YOUR INFORMATION SECURE
Remember that the email verification and two-factor authentication methods we use are for your protection. Consistent with best practices, we recommend that you always create a password that is at least eight characters in length, and that integrates at least one upper and one lower case character, a special character (like an asterisk), and a number. The more random your password, the better. You do not want to use a word that can be found in a dictionary, nor should you use the names of your friends and family, your birthday, or any other PII associated to you (e.g. your social security number, your street address, the make and model of your vehicle, to name but a few). For more information about how to create a complex password we recommend reviewing the post from a former Director of NIST entitled Easy Ways to Build a Better P@$5w0rd dated October 04, 2017. Additionally we recommend that you visit the SysAdmin, Audit, Network and Security (SANS) Institute and read their password construction guidelines. While industry best practice is for service providers to invalidate any and all cookies that may have been temporarily stored in the web browser cache, when in doubt, you are advised to remove cookies that may have been stored during your web browsing session.
Viruses are dangerous. They can slip into your system without your knowledge. Some viruses such as Trojan Horses can capture the contents of your system, including your passwords. Installing up-to-date antivirus software and running it will help thwart these and other unwanted programs.
THIRD PARTY SERVICES
The Services are not directed to individuals under the age of 18 and Verif-y will never knowingly collect PII or other information from anyone it knows is under the age of 18. In the case we are alerted that we have inadvertently collected PII from a child under the age of 18, we will take the appropriate steps to immediately remove it.
REDRESS AND ACCOUNTABILITY/ CONTACT US
Verif-y will address your concerns and attempt to resolve any privacy issues in a timely manner