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.
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.
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
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.
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 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:
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:
We do not transfer your personal data outside the United Kingdom of Great Britain and Northern Ireland.
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.
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).
|Data Category||Retention Period|
|Device||90 days (from date of last activity)|
|5 years 6 months (from date of last activity where invitation is verified)
60 days (from date of invite where invitation is unverified)
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.