CREDAS APP END USER PRIVACY POLICY

CREDAS APP END USER PRIVACY POLICY

Credas Technologies Ltd are committed to protecting your personal data and respecting your privacy.

Introduction

This End User Privacy Policy together with Our Terms of Use as set out at  (“Terms”) applies to your use of:

• Credas Technologies Ltd application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone, handheld device or computer (Device).
• Any of the services accessible through the App (Services).

This End User Privacy Policy sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us.

This App is not intended for children and We do not knowingly collect data relating to children.

Please read the following 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 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 our App and use our Services in order for Us to assist them in facilitating ID verification and documentation checks (“Verification Check(s)”) as further detailed below in this 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 End User Privacy Policy) (“Data Providers”) who will verify this information. We will then send a report detailing the results of the Verification Checks with the Company who will make a decision with how to proceed with you.

In some cases, the Company may request additional information from you before making a decision, or ask us to carry out an additional Verification Check if an earlier Verification Check was not passed.

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

Our full details are:

• Full name of legal entity: Maria Clement, Credas Technologies Ltd
• Email address: maria@credas.co.uk
• Postal address: Tec Marina, Terra Nova Way, Penarth, CF64 1SA
• Telephone number: 02920 102555

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 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 3^rd July 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS, email, or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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 Credas 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 End User Policy.

The categories of data which we collect are as follows:

• Identity Data: First name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data. address, email address and telephone numbers.
• Financial Data. Bank account details and credit check status.
• Device Data. Includes the type of mobile device you use, unique device identifier (for example your devices IMEI number, MAC address of the device wireless network interface, or the mobile phone used by the device, mobile network information, mobile operating system, type of mobile browser being used, times one setting.
• Content Data. Includes information stored on your device including login information, digital content uploaded, photos (selfies for ID verification), documents (for document verification such as passports, driving licence, national ID card, VISA, utility bills, payslips, CSCS card, residence permit, birth certificate or other) that you upload into the App.
• Profile Data. Incudes you username and password, preferences, feedback and survey responses.
• Usage Data. Includes details of your use of the App.

The Company may request us to carry out the following Verification Checks, therefore the data that will be requested from you will depend on the Verification Check we are asked to perform:

• ID verification,
• address,
• date of birth
• mortality check,
• international PEP check,
• international sanctions check,
• bank account verification check,
• credit status check,
• right to work checks,
• right to rent checks,
• proof of ownership check, and
• ultimate beneficial owner check.

Verification Checks and Special Category Data we may collect about you

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

When carrying out an ID Verification Check on your passport, in the first instance we will only read the data from the chip contained on the passport. If this process is successful in providing us with the data that we need to satisfy the Verification Check, we will not scan a copy of the photo.

If the chip reading is unsuccessful, we will only then proceed to scan a copy of the photo which will be considered Special Category Data. Under data protection laws we require your express consent to process Special Category data, which will be facilitated in the sign up process when you upload your ID 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 (details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or information about your health).

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 is your personal data collected?

We will collect and process the following data about you:

• Information you give Us. This is information (including Identity, Contact, Content, Marketing and Communications Data) you consent to giving Us about you by filling in forms on the Credas, or by undertaking the steps to take a selfie / video for ID Verification Check purposes, or by corresponding with Us. It includes information you provide when you register to use the Credas 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 and your device. Each time you use Our App We will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies 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. We will receive personal data about you from various third parties and public sources as set out below:
• Device Data from the device you are using such as platform, os version, model, app version, locale:
• Verification Check data: If you have uploaded your personal data into the Credas 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.
• Unique application numbers. When you want to install or uninstall our App which contains a unique application number or when such the App searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App or the distribution platform (“Appstore”) and to remember your preferences. This helps Us to provide you with a good experience when you use the App or browse any of Our Sites and also allows Us to improve the App and Our Sites. For detailed information on the cookies We use, the purposes for which We use them and how you can exercise your choices regarding Our use of your cookies, see Our cookie policy https://www.credas.co.uk/cookie-policy/

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.

More information about the types of lawful basis that We will rely on to process your personal data is contained at the end of this document.

We do not send you any marketing communications of any kind.

We do not share your data with third parties for marketing purposes.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

This table identified 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.

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:

• External Third Parties as follows:
  • 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 (please see their individual privacy policies that apply to your data that is shared with them):
  • Our Data providers:
    • GB Group Plc: https://www.gbgplc.com/privacy-policy/
    • LexisNexis Risk Solutions UK Limited: https://risk.lexisnexis.co.uk/privacy-policy

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

All information you provide to Us is stored on Our secure servers. Where We have given you (or where you have chosen) a password that enables you to access certain parts of the App you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 App.

We are required under our contract with the Company to store your personal data for a period of 5 years. As we are holding this data as a data processor of the Company, therefore if you wish to invoke any of your data subject access rights in relation to such data, please contact the Company in this regard, and we will act in accordance with their instructions in relation to the processing of your data.

In some circumstances We will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer or your personal data.
• Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

Glossary

• Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of Our business in conducting and managing Our business to enable us to give you the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on you (both positive and negative) and your rights before We process your personal data for Our legitimate interests. We do not use your personal data for activities where Our interests are overridden by the impact on you (unless We have your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our legitimate interests against any potential impact on you in respect of specific activities by contacting Us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that We are subject to.

• Your legal rights

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 data 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 data. This enables you to ask Us to delete or remove personal data where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove your personal data 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 data to comply with local law. 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 data where We are relying on a legitimate interest (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. You also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask Us to suspend the processing of your personal data in the following scenarios:

if you want Us to establish the data’s accuracy;

where Our use of the data is unlawful but you do not want Us to erase it;

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; or

you have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you.
• Withdraw consent at any time where We are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.