Our Commitment to You
We're here to provide you with tools and services that are designed to help you with your identity verification needs. Before you get started, we'd like to tell you more about what we do with information we collect about you.
In other words, as legalese as they are, please read these documents carefully.
What This Policy Covers
That said, you should know that we may provide third party content or links to third-party web sites or applications, or include features that allow you to connect your PersoKey account with your accounts with third parties, such as financial institutions or social media platforms like Facebook. When you leave our Services or interact with a third-party feature, you should also read the applicable third party's privacy policies and terms of service to make sure you understand how they might collect and share information about you (everybody is different).
What Information We Collect
To put it simply, there are three main ways we collect information about you: when you give it to us, with automatic technologies and when we ask others for it. Allow us to explain.
Information You Provide to Us
We may ask you to provide certain information to us through various forms, features or other means throughout our Services. A couple of examples are our registration form for new users and/or information provided to us by a company you do business with -- sponsoring entity (see below) . The types of information we may collect from you fit in two general categories:
Personal Information: This is information that identifies you personally, such as your name, address, email address, Social Security number or phone number.
Non-Personal Information: This is information about you or your household that doesn't identify you personally, like your gender, zip code, or the model of your phone.
When we combine information that isn't Personal Information (like Non-Personal Information or Usage Information, which we explain below) with Personal Information, we treat it like Personal Information for as long as it is combined.
Information We Automatically Collect
In addition to information you provide to us, we automatically collect certain information about how you access and interact with our Services (“Usage Information”). This Usage Information is a key part of how we improve your PersoKey experience and provide more streamlined authentication/verification services with less friction when possible. We and our business partners may use various technologies to collect and store Usage Information in connection with our Services. These may include things like cookies, browser web storage (e.g., HTML5), web beacons and similar technologies. There are three types of Usage Information we may collect:
Device Information. This is information about how you access our Services, such as the operating system, hardware model, SIM card and phone number associated with it, application or browser type and version, and unique identifiers associated with your device. We may also integrate with built-in device features (e.g., when you turn on fingerprint access for your PersoKey account).
Log Information. There are certain pieces of information we automatically collect in system logs or similar files about how you interact with our Services, such as which features you visit or click on. This Log Information may also include things like your IP address, browser or device configuration, date and time of access and cookie information.
Location Information. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or state). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services. We will only use these location-enabled services on your device with your consent, though, and only at the time of being verified. We do not track your location after you completed our verification.
Information Third Parties Provide About You
Many of our identity verification features rely on information about you that we collect from third parties, such as banks, financial institutions or merchants that you do business with. These third parties are defined in our ecosystem as “Sponsoring Entities”. We may also work with different third party data partners we use direct integration with Mobile Network Operators for our SIM authentication technology.
In most cases, your information has been provided by a sponsoring entity that you are already a customer of. These sponsoring entities are usually banks, financial institutions, merchants or other companies and they use PersoKey as a verification agent and so we can provide verification services to them that helps confirm you as the person behind a transaction. For us to perform a verification of you on behalf of the sponsoring entity, they provide PersoKey with personal information about you, including your name, address, mobile phone number, email as well as transaction details that will let you know why the sponsoring entity is asking for a verification.
We may also work with different third party data partners including Mobile Network Operators (MNOs). We use direct integration with Mobile Network Operators for our SIM authentication technology, and they provide information about the phone number that is used in the verification, and matching scores that indicate the level of association of you with the phone number, and other signals such as pre-paid vs. postpaid plan and for how long have you used this mobile number. In some cases we can also receive the device model used in the verification.
How We Use the Information We Collect
We use the information we collect from you and third parties to operate our Services, communicate with you, conduct verifications and improve or enhance our Services and our users' experience. These are a few examples:
Providing fast verifications to your sponsoring entity. We use our scores to provide a recommendation to pass or fail the verification based on multiple data points, including your phone number, the tenure, proof of possession etc. We can store your IP address that was used to pass our verification and use it later to facilitate a faster verification when possible.
Using data received from sponsoring entities. Subject to our agreements with sponsoring entities, PersoKey may apply statistical analytics to aggregate data received from sponsoring entities, in order to identify patterns or anomalies that are useful in predicting the likelihood of fraud in any given transaction.
Using your location in our risk models. We use your location as an input to our risk model. We use precise location internally in our models but never share this precise location with third parties including the sponsoring entity. We may share an approximate location at the city and state level with the sponsoring entity to be able to approve certain transactions like for example delivering a replacement card to a hotel when you are travelling. We may record your location securely in our platform to create a positive history of legitimate locations where you usually transact. This will help in approving verifications in the future and reduce the friction.
Communicating with you. We may use information we collect to provide you with servicing communications. These communications could be done on behalf your sponsoring entity or directly by us to give you an alert when we suspect someone may be trying to steal your identity.
Legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to:
Comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law;
Enforce our Terms of Service, including investigating any potential violations;
Protect the safety, integrity, rights or security of our users, our Services or equipment, or any third party; or
Detect, prevent or otherwise address fraud, security or technical issues related to our Services or our business partners.
For How Long We Retain Your Information
The period for which personal information is retained is determined by the contract between PersoKey and each individual sponsoring entity and may vary based on the type of PersoKey service. However, specific elements of a transaction (such as an face map, face image, email address or phone number), believed to have been used in a fraudulent manner will be retained for longer periods consistent with PersoKey’s agreements with its individual sponsoring entity. Consumers should contact the sponsoring entities with which they directly share their data to learn how long their transaction data may be retained. PersoKey has put in place mechanisms to protect the accuracy and integrity of personal information.
When We Share the Information We Collect
First, we want to be clear about how we do not share information about you (what we call the “No-Nos”):
We do not share your personal information or transaction details with unaffiliated third parties (except agents acting on our behalf; we explain that below).
We do not sell or rent Personal Information to unaffiliated third parties for their advertising or marketing lists.
Now that we've covered the No-Nos, let us explain how we could share with third parties. We may share information about you, including Personal Information, with third parties in the following circumstances:
When we collaborate with third parties to provide and improve our Services. We may sometimes share information about you with our business partners or other third parties we collaborate with in connection with providing or improving our Services. This can occur, for example, when use a third party verification system that may verify things like your email.
When you publicly post the information. As part of our Services, we may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include Personal Information and portions of your PersoKey Profile designated as public profile information, like your name or PersoKey ID. Anything you share in a public forum is, obviously, public, so think carefully about what you decide to share.
As Part of a Corporate Change. We may disclose and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets. If such a business transfer results in a material change in the treatment of your Personal Information, you will be notified by e-mail (using the primary email address on your account) or by a prominent notice on our site.
For Legal Reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes. (You can read more about these in the “How do we use the information we Collect” in the section above.)
With Your Consent. There may also be other limited contexts in which we share specific types of personal information with your express consent.
Accessing and Updating Your Account Information
You are responsible for maintaining the accuracy of the information you provide to us, such as your User Profile information. You can access and make changes to certain Personal Information at any time by logging into your account through our app and/or website and updating your "Personal Information" page.
You can manage your communications preferences by visiting your account profile. For example, you can choose which types of monitoring alerts you want to receive. We'll also include "unsubscribe" instructions in any marketing emails. You can also adjust app-specific communications settings (e.g., for things like push notifications) within the settings screen of the mobile app. Technology moves fast, so the types of communications and communication preference options might change from time to time.
Deactivating Your Account
We hope this never happens, but if you decide you no longer want to use our Services, you can cancel and deactivate your account on our help page.
One more thing to note: Due to our record-keeping and information retention requirements, we do not delete information about you upon deactivation. We will, however, disable your account and stop sending you further communications. Furthermore, except to the extent necessary for legal or regulatory record-keeping purposes or when we suspect the account has been involved in a fraudulent activity, we may retain the data in your Profile for a longer period of time (up to 5 years) after you deactivate your account. It may take a little more time for our automated backup systems to fully process the anonymized account, though.
Do Not Track Signals
At this time, we do not respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser. Please note that blocking cookies may affect your browsing experience on many sites and may limit your ability to use certain features of our Services, including many of the personalized features we provide for our members.
Our Security Practices and Social Security Protection Policy Statement
PersoKey maintains physical, electronic, administrative and procedural safeguards intended to protect the confidentiality of Personal Information that we collect about you, including Social Security numbers or a hash representing Social Security Numbers. We limit access to Social Security numbers to help protect against their loss or misuse and we do not disclose Social Security numbers to third parties except where such disclosure is required or permitted by law. Read more about our Security Practices.
If you have any questions about security on our Services, you can send an email to us at email@example.com.
Want More Information?
Thanks for taking the time to read through all this. If you have questions regarding this policy or privacy practices at PersoKey, you can email us at firstname.lastname@example.org or write to us at: PersoKey, Inc. Attention: Legal Department, 14600 N Airport Dr. Scottsdale AZ, 85260)