Privacy Policy
VeriMe Age Verification Service
1.
Introduction
This document contains the current Privacy Policy (a.k.a. Privacy Notice
or Privacy atement) that applies to the VeriMe Age Verification Service ('VeriMe AV Service') that is provided directly to users, where only the
resulting age verification status is communicated to a referring merchant. The nominated merchant is specific to each
age verification transaction.
The scope of this document is constrained to the rationale,
usage and contents of the Privacy Policy that relates to the VeriMe AV Service and the Privacy Policy itself will be
published on the VeriMe website at www.verime.net and referred to within user communications.
The Privacy Policy must comply with the requirements of
both the UK Data Protection Act 2018 and the General Data Protection Regulation
(Regulation (EU) 2016/679)) ('GDPR').
Previous versions of this policy can be found by clicking on the following link
1.1.
Responsibilities
The Data Protection Leads are responsible for ensuring that this notice is made
available to data subjects prior to VeriMe Limited
collecting/processing their personal data.
All Employees/Staff of VeriMe
Limited who interact with data subjects are responsible for ensuring that this
notice is drawn to the data subject's attention and their consent to the
processing of their data is secured.
1.2.
Availability and
Prominence
To ensure the availability of the Privacy Policy it will be
published on the VeriMe corporate website at www.verime.net. A permanent link will also be present at the foot of the www.verime.net home page to ensure availability to those reaching the VeriMe corporate website via a search engine.
A hyperlink to the Privacy Policy will be included within
text shown on the VeriMe AV Service Landing Page
which is displayed to the user before they commit to proceed with the use of
the VeriMe AV Service or provide any personal data to
VeriMe.
1.3.
VeriMe AV Service Landing Page
The VeriMe landing page is the
first VeriMe website page that a user will see when
they are referred to the VeriMe AV Service by a
Merchant. This landing page allows the
user to:-
a) Provide their mobile phone number; and
b) Request that VeriMe carries out age verification using that mobile phone number; and furthermore, this landing page;
c) Provides clarity that the user is requesting VeriMe to perform age verification; and
d) Obtains agreement that their personal data may be used in accordance with VeriMe's terms; and
e) Provides a link to VeriMe AV Service Privacy Policy (which refers to the Terms where applicable); and
f) Obtains acknowledgement that the mobile phone number entered will be transferred to VeriMe for processing.
1.3.1.
Action Statement
The action statement is displayed below the mobile number
entry field but above the action buttons in black with a normal font size (c.
10pt). The standard action statement reads as follows:-
By clicking 'Age Verify' below, you request us to verify
your age and agree that we may process your personal information in accordance
with our terms.
Note that if the 'Age Verify' button label is changed on
the landing page, then the text in the action statement must also be amended
accordingly.
1.3.2.
Rider and Link
The rider is displayed below the mobile number entry and
action buttons area, in dark grey and with a smaller font size (c. 7.5pt). The word 'here; at the end of the footer text
will always contains a hyperlink to https://www.verime.net/privacy_policy.html and typically appear in blue and underlined (depending on
the user's browser settings).
The standard footer reads as follows:-
The Merchant ([Referring_Merchant_Brand])
referred you to us at VeriMe, to undertake
independent age verification. By clicking 'Age Verify' above,
you acknowledge that your mobile phone number will be sent to us for
processing. Learn more about our privacy practices here .
Where [Referring_Merchant_Brand] is substituted for the
consumer facing brand name of the merchant that is contracted with VeriMe, such as 'AgeID' as
illustrated in the example that follows.
Note that if the 'Age Verify' button label is changed on
the landing page, then the text in the rider must also be amended accordingly.
1.3.3.
Landing Page Example
2.
Privacy Policy – Age
Verification Service
Version v5, Last updated 04 February2021
2
Introduction
2.1 This Privacy Policy (together with our terms of use and any other documents referred to in it) explains what we do with your personal data, whether we are in the process of assisting you verify your age, providing you with a service, assisting you with your enquiry or dealing with a formal enquiry from a regulator.
2.2 It describes how we collect, use and process personal data, and how, in doing so, we comply with our legal obligations.
2.3 We respect your privacy and are committed to protecting it through our compliance with applicable privacy and data protection laws and regulations. Please read this privacy policy carefully to understand our policies and practices regarding your personal data and how we treat it. By using the VeriMe Age Verification Service, you are accepting the practices described in this privacy policy.
2.4 If you do not want your information to be processed as set out in this privacy policy, please do not provide any personal data to us and do not use our age verification service.
2.5 It is important to note that we may amend this Privacy Policy from time to time. We review our Privacy Policy on an annual basis, sooner if changes to regulation require or if we change the way we process personal information. We will post any updates to this Privacy Policy on our website at www.verime.net/privacy_policy.html so please visit this page if you would like to stay up to date.
2.6 If you have any questions about our privacy practices, please refer to the contact details at the end of this privacy policy.
2.7 The VeriMe Age Verification Service ('VeriMe AV Service') is owned and operated by VeriMe Limited a company registered in England and Wales with Company No 09692519 ('VeriMe', 'we', 'us' or 'our'). Our registered office is at Cotswold House, 219 Marsh Wall, London E14 9FJ.
2.8 For the purposes of the UK Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679)) ('GDPR'), in respect of the VeriMe AV Service, we are the data controller. We are responsible for the processing of any personal data you provide to us whilst using our services. VeriMe Limited is registered with the UK Information Commissioner's Office under Registration No. ZA216213.
3
When This Privacy
Policy Applies
3.1 This Privacy Policy applies to personal information that we collect whilst you are using the VeriMe AV Service and in any email and other communication between you and us.
3.2 It does not apply to information collected by any other website or web-based service operated by us (or our group companies), any website operated by a third party including those operated by the merchant that referred you to the VeriMe AV Service or any third party application or content (including advertising) that may link to or be accessible from the VeriMe AV Service.
3.3 Please check the privacy policies of any external site before submitting any personal data to them, as we cannot accept any responsibility or liability in relation to them.
4
Why does VeriMe Limited need to
collect and store personal data?
4.1 We collect information in order to provide an age verification service to merchants who operate websites, applications and businesses which are required to verify a person's age before allowing them to a) access certain websites and/or certain types of content shown on websites, or b) purchase certain types of goods and/or services either via a website, an application or in person. We also provide an age verification service to certain merchants and partners who aggregate different age verification attributes in order to provide users with other proof of age services.
5
Personal Data we
collect and how we collect it
5.1 In order for us to provide our age verification services to you we need to collect limited personal data from you for identification and validation purposes. We cannot perform age verification without the personal data associated with the age verification method. In any event, we are committed to ensuring that the information we collect and use is kept to a minimum, is appropriate for this purpose and does not constitute an invasion of your privacy
5.2 Data we collect directly from you via forms presented when using the VeriMe AV Service is:
|
Age
Verification Method |
Personal
Data Type |
Source |
|
UK Mobile Phone |
Mobile Phone Number |
You |
Data collected automatically
5.2.1 When you access our web based services, we may also receive information automatically which relates to your computer, mobile device and internet connection, whether you decide to use our services or not. This includes your internet protocol address ("IP address"), your country of location, operating system, browser and platform type and access times. These are not actively utilised by the service and are only present in log file for technical operations and maintenance purposes. These log files are automatically deleted after 3 months.
5.2.2
Our website uses cookies which are small files of
letters and numbers that we put on your computer. These cookies allow us to
distinguish you from other users of our website, which helps us to provide you
with a good experience when you browse our website and also
helps us to improve our website. We use analytical cookies which enable us to
recognise and count the number of visitors and to see how visitors move around
our website. This helps us to improve the way our website works.
We currently use the following types of cookies.
|
Cookie |
Purpose |
Type |
|
PHP Session
Cookie |
Allows a user to be recognised within a
website visit so that changes or data selection is remembered from page to
page. |
Session Cookie |
|
Analytics |
We use Google Analytics cookies which allows
Google Inc. to collect information about how visitors use our site. We then
use this information to help us improve our site. The Google privacy policy is located at: https://www.google.co.uk/policies/privacy You can find out how to opt out of Google Analytics by
visiting https://tools.google.com/dlpage/gaoptout |
Persistent Cookie Various Durations (max 2 Years) |
5.2.3 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
5.2.4 Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
6
Consent
6.1 By consenting to this privacy policy, you are giving us permission to process your personal data specifically for the purposes identified. If you do not want your information to be processed as set out in this privacy policy, please do not provide any personal data to us and do not use our age verification service.
6.2 Consent is required for VeriMe to process personal data, but it must be explicitly given. VeriMe does not collect or process sensitive personal data.
7
Will VeriMe Limited share my personal data with anyone else?
7.1 We may pass your personal data on to third-party service providers contracted to VeriMe Limited in the course of providing our age verification services to you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide to us. When they no longer need your data to fulfil this service, they will dispose of the details.
7.2 We may disclose your personal data if we are required to do so by law, any applicable regulation or to protect the rights, property, or safety of ourselves or others.
7.3 VeriMe Limited will not pass on your personal data to any other third parties. We do not pass the personal data you provide to us, back to the merchant whose website referred you to us. We only indicate the success or failure of the age verification process to the referring merchant.
8
How will VeriMe Limited use the personal data it collects about me?
8.1 VeriMe Limited will process (collect, store and use) the information you provide in a manner compatible with the UK Data Protection Act 2018 and the GDPR. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. VeriMe Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
8.2 Where we undertake your Age Verification via your UK mobile phone number we will exchange Short Message Service ('SMS') text messages with you via your mobile network. We will use the Mobile Network Operator's content control status associated with your Mobile Station International Subscriber Directory Number ('MSISDN') to determine successful age verification.
9
How long will VeriMe Limited keep the personal data it collects about me?
9.1 VeriMe Limited will process personal data only for the time required to complete the age verification process and once this is complete we will store the personal data in an encrypted format for a period of five years in order to provide customer service, maintain an audit trail of age verifications and comply with our legal and regulatory requirements.
10 Under
what circumstances will VeriMe Limited contact me?
10.1 Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. We will not normally contact you once your age verification is complete. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
11
Your Rights as a
Data Subject
11.1 At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- 'Right of access ' you have the right to request a copy of the information that we hold about you.
- 'Right of rectification ; you have a right to correct data that we hold about you that is inaccurate or incomplete.
- 'Right to be forgotten ' in certain circumstances you can ask for the data we hold about you to be erased from our systems.
- 'Right to restriction of processing ' where certain conditions apply to have a right to restrict the processing.
- 'Right of portability ' you have the right to have the data we hold about you transferred to another organisation.
- 'Right to object ' you have the right to object to certain types of processing such as direct marketing.
- 'Right to object to automated processing, including profiling ' you also have the right to be subject to the legal effects of automated processing or profiling.
- 'Right to judicial review ' - in the event that VeriMe Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
11.2 If you would like to exercise any of these rights, details of how to contact our Data Protection Leads can be found at the end of this policy. In order to assist you with exercising these rights we will first need to confirm your identity. VeriMe Limited will normally accept the same form of identity that you originally submitted for age verification.
12
How to Complain
12.1 VeriMe Limited takes complaints very seriously and will respond to complaints within 30 days, this allows us time to investigate your complaint thoroughly. In the event that you wish to make a complaint about how your personal information is used by us please contact our Data Protection Leads.
|
How to Contact our data protection leads |
|
The Data Protection Office |
|
Email: dpo@verime.net |
12.2 If you are not satisfied with our response or believe we are not processing your personal data in accordance with UK Data Protection Act 2018 and the requirements of the GDPR; you can complain directly to the UK Supervisory Authority.
|
How to Contact
the UK Supervisory Authority |
|
Customer Contact |
|
Email: casework@ico.org.uk |
|
Web: www.ico.org.uk |
|
Helpline: 0303 123 1113 |
Control Sheet
Summary of Changes
|
Version |
Date |
Author |
Description of changes |
|
0.1 |
28/08/2018 |
Danny Payea |
Initial Draft |
|
0.2 |
04/02/2021 |
Rudd Apsey |
Data retention periods revised
and updated to reflect the encrypted nature of details which will be stored
for a period of five years. Data Protection Officer has been updated to
reflect the implementation of Data Protection Leads. |
Sign Off
|
Approver |
Title |
Date of Approval |
|
Rudd Apsey |
Managing Director |
04/02/2021 |
|
Anjum Khan |
CTO |
04/02/2021 |