Privacy Policy

 

Introduction

This App Privacy Notice applies to your use of iDWallet. 

Who we are 

We are Legal Brokers Ltd and iDWallet (referred to as “iD Wallet“, “We“, “Us” or “Our” in this notice) is one of our trading styles.

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, however, we would always appreciate the opportunity to resolve any issue you may have directly with the App or Services in the first instance. 

The purpose of the App is to store digitally approved ID’s whilst also help businesses (“Customers”) provide Services to their clients (“you” or “End User”) and to enable you to upload, access, collect, retain and amend your data quickly and securely. 

We allow users to have their ID confirmed so that they have the ability to demonstrate their age to others without the need to physically carry an ID document.

The data we collect about you 

We will collect different data from you for different purposes: 

As a processor, when we are asked by a Company to process specific checks on you on their behalf (“Verification Checks”). 

As a controller, to administer and protect our business, App and sites including troubleshooting, data analysis and system testing. 

The categories of data which we may collect are as follows: 

• Contact – Email address, Postal address, Telephone number
• Content – Document, Photo, Text
• Financial – Bank account, Credit check, Transactional
• Identity – Biometric liveness check (selfie), Date of birth
• Profile – Feedback, Preference, Preferences 
• Usage – Device, IP address, System 

 The above categories of data may change to reflect additional services offered by us, from time to time, and we will amend this policy from time to time to reflect such additional services. 

Special Category Data we may collect about you 

If you are using the App for identity verification (facial verification), this is classed as Special Category Data as it includes biometric data. The biometric data will be used to determine the likeness between your ‘selfie’ and your photo identity document. This determination will be completed by our data verifier. We will retain the ‘selfie’ (but not the biometric mapping) for as long as required by our client, the Data Controller, so that they might identify you, as their customer.

Under data protection laws we require your explicit consent to process Special Category Data, which will be provided by you in the registration process. If you do not provide your consent for us to process this data, we are unable to carry out the Verification Check and request that you delete the App.

 How your personal data is collected 

We may collect and process your data using different methods: Information you give us: This is information you consent to giving us about you by using the App and our Services. Information We receive from others: This is information given to Us by the Company or information we receive from our Data Providers when carrying out a Verification Check on behalf of the Company. 

How we use your personal data 

 We will only use your personal data when the law allows us to do so. More commonly we will use your personal data in the following circumstances: 

• Consent: where you have consented before the processing 
• Contract: where we need to perform a contract we have with the Company that has requested that you use Our App 
• Legitimate Interests: where it is necessary for Our legitimate interests and your interests and fundamental rights do not override those interests 

Disclosures of your personal data 

When you consent to providing Us with your personal data, you also consent for us to share your personal data with the third parties set out below: 

• Service providers acting as processors to provide IT and system administration services (e.g. Microsoft). 
• 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 notice. 
• Data Providers.  

 Fraud prevention agencies

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. 

International transfers 

 We do not transfer your personal data outside the United Kingdom. 

Data security 

 All information you provide to us is stored on secure servers situated in the United Kingdom. All communication between our App and the servers are 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 

The data controller (the Customer) decides the retention period for data we process. We shall retain the data until such a time as we are told to delete or anonymise the data; whether that be by explicit instruction by the Controller or contractual obligation. We do, however, retain the right to delete all data at our discretion.

 Your legal rights 

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

 Your right of access 

 You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

 Your right to rectification 

 You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here. 

 Your right to erasure 

 You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right here.  

 Your right to restriction of processing 

You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here. 

Your right to object to processing 

 You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests. You can read more about this right here.  

 Your right to data portability 

 This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this right here. You are not required to pay any charge for exercising your rights. We have one month to respond to you. Please contact the Customer if you wish to make a request.

Legitimate Interest 

Usage category data is required in order to troubleshoot any issues encountered (e.g. operating system version is not supported) and/or to inform product development (e.g. user preference of web app over mobile app).