This Privacy Notice sets out the basis on which any personal data we collect from you in accessing our valid8Me service will be used by us as controllers for the purposes of the Data Protection Law. Please read this Privacy Notice carefully to understand our views and practices regarding the personal data we collect and how we will treat it.
This Privacy Notice is a statement of our commitment to protect the rights and privacy of individuals in accordance with data protection law.
valid8Me is the owner of a software product known as valid8Me which is a “Know your client” (“KYC”) document sourcing and sharing service that allows corporate, individual and professional bodies (“End Users”) to:
This Privacy Notice provides specific information relating to the following data subjects where we act as controllers of their personal data for the purposes of the GDPR:
OUR PROCESSING ACTIVITIES
We use your personal data to enable both End Users and Onboarding Entities connect for the purpose of sharing of identification and verification documents required by Onboarding Entities for the purpose of providing their products and services.
Personal data will be collected via a mobile application that the End User can download to their device. An Onboarding Entity can request any type of information or documentation as mandated by their AML / KYC policies. The End User will, having considered the Onboarding Entity’s requirements, decide whether to upload and share their information.
Under data protection law, valid8Me must ensure that it has an appropriate lawful basis for the processing of your personal data and let you know what that basis is.
We will be processing your personal data based on the following:
Where the personal data includes special category personal data, valid8Me may seek to rely on:
In addition there will be some processing undertaken for administrative purposes, to provide information to you, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security.
We may need to use your information to comply with legal and regulatory obligations, including complying with your information rights, with reporting obligations and with Court orders. We may also process your personal data where necessary to protect your vital interests or those of another person.
Personal data means any information relating to you, which allows us to identify you, such as your name, contact details, payment details and information about your interaction with the services provided by us.
We collect identity data as follows:
We collect data from your interactions with us and our business relationship
If you interact with us we will record details of those interactions. For example, we will collect details of phone calls, email correspondence and hard copy correspondence.
We collect certain non-personal technical data from your interactions with our website
When you interact with us online we will automatically collect data about your use of our services, including data on the type of device you’re using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This information is collected at an aggregate level and your identity data is not stored as part of this technical data.
For further information see our cookies policies below.
We will collect personal data supplied by the End User which is uploaded and shared with the Onboarding Entity. The Onboarding Entity may request special category or sensitive personal data to be shared but the End User will have control over the information that is uploaded or shared with the Onboarding entity.
In addition, our servers, logs and other technologies automatically collect certain information to help us administer, protect and improve our services, analyse usage and improve End User experiences.
We will only use personal data for the purpose of our processing activities mentioned including to enable End Users create a digital identity through a process of identity verification to connect with an Onboarding Entity for a product or service. The End User will be asked to provide certain information and valid8Me will explicitly seek the consent of End User before sharing each piece of information and documentation with an Onboarding Entity or other Authorised Representative. The information will be shared with any Onboarding Entity the End User or their Authorised Representative connects with and permits access to their documents. The End User or Authorised Representative will receive a request to connect and it will be for it to decide what and with whom it wishes to provide access to documents. Any request left unanswered by the End User or Authorised Representative will remain pending and no access will be permitted until approved by them.
In certain circumstances, we may disclose personal data to third parties as follows:-
When we engage another organisation to perform services for us, we may provide them with information including personal data, in connection with their performance of those functions. We do not allow third parties to use personal data except for the purpose of providing these services
We will take all steps reasonably necessary to ensure that personal data is treated securely in accordance with this Privacy Notice and the relevant law.
In particular, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we manage and collect. All End Users of valid8Me will conduct base IDV checks when setting up their account to ensure that the person holding the device is the same person in the identification documents as well as other measures to minimise identity fraud.
End Users will use valid8Me to create a digital identity through a process of identity verification (selfie photo, identity document, liveness test, two factor authentication) to confirm they are using the correct device.
All information uploaded will be stored in a specific, secure and encrypted online vault hosted by valid8Me.
We also use secure connections to protect personal data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access the services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We do not transfer personal data outside the European Economic Area (“EEA”). If at any time it becomes necessary for us to transfer personal data outside the EEA, it will only be transferred outside the area using legally approved transfer mechanisms.
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The Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website.
If you register with us or if continue to use the Website, you agree to our use of cookies. Please go to the cookie management tool available on the Website at https://www.valid8Me.com or https://www.valid8me.com to understand the cookies that we collect and manage your preferences around them.
Cookies enable us to store information about your preferences and therefore customise the Website according to your individual interests. They are also used to monitor which parts of the Website are the most popular to its visitors. Please be aware that if you do disable cookies however, certain services on the Website will not be available to you and your use and enjoyment of them will be impaired.
You can use the Cookies Settings button below to manage cookies.
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Our Website and the Platform may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy notices. We do not accept any responsibility or liability for these third party websites nor do we provide support for their services. Please undertake the appropriate due diligence before submitting any personal data to these websites.
If you are resident in the EEA, you have several rights under the GDPR. These rights are as follows:
Vindication of your rights shall not affect any rights which we may have under Data Protection Law. You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.
In some circumstances it is not possible for us to specify in advance the period for which we will retain your personal data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain personal data beyond the periods specified herein in some circumstances such as where required for the purposes of a legal claims.
The information and documentation will be retained and processed by valid8Me for as long as an End User maintains it in their personal vault or the Onboarding Entity requires access to it. Once that data is knowingly made available to an Onboarding entity, which the End User has consented to, it will remain available for a number of years in line with the Onboarding Entities legal obligations relating to KYC and AML. In advance of the legal obligation period elapsing, the Onboarding Entity will be informed to confirm they no longer require access. If the Onboarding Entity does not extend the legal term their access to that documentation will be revoked and the End User notified.
We will post any changes on the Website and when doing so will change the updated date at the top of this Privacy Notice. Please make sure to check the date when you use our services to see if there have been any changes since you last used those services. If you are not happy with any changes that we have made you should cease using our services.
In some cases we may provide you with additional notice of changes to this Privacy Notice, such as via email. We will always provide you with such additional notice well in advance of the changes taking effect where we consider the changes to be material
Please contact us if you have any questions about this Privacy Notice or information we hold about you:
The Data Protection Commission in Ireland may be contacted through their website at https://forms.dataprotection.ie/contact if you have any concerns or questions about the processing of your personal data.