CREDAS APP END USER PRIVACY POLICY

Introduction

This App End User Privacy Policy (together with our Terms and Conditions as set out here (“Terms”) applies to your use of:

• Credas Technologies Ltd web application software and/or Credas Technologies Ltd mobile application software (“App”).
• Any of the services accessible through the App (“Services”).

Please read the following App End User Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Credas Technologies Ltd (collectively referred to as “Credas“, “We“, “Us” or “Our” in this policy) is responsible for the App.

The purpose of the App is to help our business clients (“Company”) to provide services to their clients (“you” or “End User”) quickly and securely, and the purpose of this App End User Privacy Policy is to tell you how We process your personal data on behalf of the Company as a data processor.

A Company may ask you to download or access our App and use our Services in order for Us to assist them in facilitating identity verification and documentation checks (“Verification Check(s)”) as further detailed below in this App End User Privacy Policy.

You will be asked to provide Us with specific information dependant on the Verification Check that the Company wants Us to carry out. This information will be shared with third party data providers (as detailed in this App End User Privacy Policy) (“Data Providers”) who will verify this information. We will then make available a report detailing the results of the Verification Checks with the Company who will decide on how to proceed with you.

In relation to the personal data that you provide to Us for the purposes of carrying out Verification Checks, We act as a data processor, and the Company is the data controller of such personal data. For more information on how the Company will use and store this personal data, please refer to the Company’s privacy policy.

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Name: Louis Lancaster
Email address: Louis.Lancaster@credas.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this App End User Privacy Policy and your duty to inform Us of changes

We keep Our privacy policy under regular review.

This version was last updated on 26 July 2021. It may change and if it does, these changes will be posted on this page.

It is important that the personal data We, and the Company hold about you is accurate and current. Please keep Us and the Company informed if your personal data changes during Our relationship with you.

The data We collect about you

We will collect different data from you for different purposes, whether we are acting as a data controller to set up your account on the App or acting as a processor on behalf of the Company to process Verification Checks. This is further identified in the table set out below in this App End User Privacy Policy.

The categories of data which we collect are as follows:

Identity Data: First name, last name, date of birth
Contact Data: Address, email address and telephone number
Financial Data: Bank account details and credit check status
Content Data:  Includes login information, digital content uploaded, photos (selfies for identity verification), documents (for document verification such as passports, driving licence, utility bills, etc.), responses to questions that you upload into the App
Profile Data: Includes your email address and password, preferences, feedback and survey responses
Usage Data: Includes details of your use of the App

Verification Checks and Special Category Data We may collect about you

If you are using the App to facilitate identity verification (facial recognition), this is classed as Special Category Data as it may include genetic and biometric data.

Under data protection laws We require your express consent to process Special Category data, which will be facilitated in the registration process when you upload your identity documentation to Us. If you do not provide your consent for Us to process this data, We may not be able to carry out the Verification Check required by the Company, and the Company will be notified of this.

We do not collect any additional Special Categories of Personal Data about you.

Certain Verification Checks will require Us to collect information from our Data Providers relating to criminal convictions, offences, and terrorist activity.

Aggregated Data

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this privacy policy.

How your personal data is collected

We will collect and process the following data about you:

Information you give Us: This is information you consent to giving Us about you by filling in forms on the App, or by undertaking the steps to take a selfie for ID Verification Check purposes, or by corresponding with Us. It includes information you provide when you register to use the App, download or register the App, use any of the Services to carry out Verification Checks, search for the App or when you report a problem with an App or Our Services. If you contact Us, We will keep a record of that correspondence.

Information We collect about you: Each time you use Our App We will automatically collect personal data including Content and Usage Data. We collect this data using cookies (web application only) and other similar technologies. Please see Our cookie policy https://www.credas.co.uk/cookie-policy/ for further details.

Information We receive from other sources including third parties and publicly available sources: If you have uploaded your personal data into the App for the purpose of carrying out Verification Checks, We will share this information with our Data Providers in order to verify that this information is correct. Our Data Providers, who may be based outside of the EU are: GB Group Plc; LexisNexis Risk Solutions UK Limited; Companies House and the Electoral Register. This shall include receiving information on your identity; information from the birth register and death register; your address; your date of birth; whether you are sanctioned in the UK or in any country internationally; and whether you are a politically exposed person.

How We use your personal data

We will only use your personal data when the law allows Us to do so. Most commonly We will use your personal data in the following circumstances:

• Where you have consented before the processing
• Where We need to perform a contract We are about to enter or have entered with you, or the Company that has requested that you use Our App
• Where it is necessary for Our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where We need to comply with a legal or regulatory obligation

Purposes for which We will use your personal data

This table identifies the types of personal data We use and process for specific purposes and confirms in which situations we are acting as a data controller or processor of such data. It should be noted that the data controller controls the purpose/activity and therefore the range of data We collect will depend on the Services requested by the data controller.

Purpose                         Data                 Lawful Basis                  Controller/Processor

Install the App/Register                Contact              Consent             Controller
as new App User             Identity

Administer and protect                 Contact              Legitimate                      Controller
Our business, Apps and                 Identity              Interests
Sites, including analysis                 Usage

ID Verification Check                    Content  Consent             Processor: Shared with
Identity              Contract            GB Group                                                                                  Special

Address Check                            Contact              Consent             Processor: Shared with
Content  Contract            LexisNexis Risk Solutions

Date of Birth Check                      Contact              Consent             Processor: Shared with
Identity              Contract            LexisNexis Risk Solutions

Mortality Check                           Identity              Consent             Processor: Shared with                                                                                          Contract            LexisNexis Risk Solutions

International PEP Check                 Contact              Consent             Processor: Shared with                                                                  Identity              Contract            LexisNexis Risk Solutions

International Sanctions                  Contact              Consent             Processor: Shared with
Check                                        Identity              Contract            LexisNexis Risk Solutions

Bank Account Check                      Contact              Consent             Processor: Shared with                                                                  Financial Contract            LexisNexis Risk Solutions                                                   Identity

Credit Status Check                      Contact              Consent             Processor: Shared with                                                                  Identity              Contract            LexisNexis Risk Solutions

Proof of Ownership                      Contact              Consent             Processor: Shared with
Check                                        Identity              Contract            LexisNexis Risk Solutions

Right to Rent/Work                      Content  Consent             Processor: Shared with
Check                                        Identity              Contract            GB Group                                                                                  Special

Ultimate Beneficial                       Contact              Consent             Processor: Shared with
Owner Check                              Identity              Contract            LexisNexis Risk Solutions and                                                                                                                        Companies House

Completion of ad hoc                   Contact              Consent             Processor
Forms                                        Content  Contract                                                                                                            Financial                                                                                                                                    Identity                                                                                                                                                  Usage

Disclosures of your personal data

When you consent to providing Us with your personal data, We will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the above table:

• Service providers acting as processors based in based in England and Wales to provide IT and system administration services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in based in England and Wales to provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in England and Wales who require reporting of processing activities in certain circumstances.
• Third parties to whom We may choose to sell, transfer or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Specific third parties as per the following:
  GB Group Plc
  LexisNexis Risk Solutions UK Limited

International transfers

We do not transfer your personal data outside the United Kingdom of Great Britain and Northern Ireland.

Data security

All information you provide to Us is stored on secure servers.

Once We have received your information, We will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

No Sensitive Personal Data is stored in the App and no images are stored locally. All communication between our App and the servers is carried out over secure connections, and data is encrypted during transit and at rest.

We perform ongoing automated penetration to ensure that the App is secure.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when We are legally required to do so.

Data retention

We are required to keep different set of data for different purposes.

In Our role as data processor, We are subject to the data retention periods prescribed by the Company. However, by default, We will retain data processed on behalf of a Company for as long as is prescribed below unless there is a legitimate and/or legal request for it to be retained longer (e.g. at the request of the Company), or there is a legitimate and/or legal request for it to be anonymised sooner (e.g. right to erasure).

Your legal rights

Under certain circumstances you have rights under data protection laws in relation to your personal data. As We are holding your data as a data processor of the Company, your rights should be exercised through the Company.

Further information on your rights can be found on the ICO website here.