Sensity B.V. Nassaukade 322H 1053LT Amsterdam NH The Netherlands VAT: NL859386636B01 Registration number: 73175501
PRIVACY POLICY This agreement applies to registered account holders of platform.sensity.ai, as well as End Users of our Identity Verification Services used through API/SDKs, and Sensity B.V.
Last Updated: December 2022
Scope: Sensity B.V. is building an identity layer to power the next generation of digital first, trust based services, globally. We provide the Identity Verification Services (Services) which power and facilitate access and trust for our clients and their customers.We provide identity verification services through the use of a proprietary platform which combines deepfake detection models, facial recognition technology, ID authenticity checks, forensic check on PDFs, and all enhancements, features and improvements thereto.
By using the Services, you agree to input your biometric data and identity information for purposes of proving your identity. We will use your information in accordance with this Privacy Policy. For details regarding what information is collected about you when you visit our Website, including how we use cookies.
PERSONAL INFORMATION WE COLLECT.
When you interact with our Services, we may collect the following categories of personal information.Information You Provide to Us.Registration and Your Information. If you want to use certain features of the Services, you will have to create an account (“Account”).
You may also receive an invitation to proceed with the registration via the email used to register an account.Accuracy of Account Information. It is important that you provide us with accurate, complete and up-to-date information for your Account and you agree to update such information to keep it accurate, complete and up-to-date. If you don’t, we might have to suspend or terminate your Account. You agree that you won’t disclose your Account password to anyone, and you’ll notify us immediately of any unauthorized use of your Account.
You’re responsible for all activities that occur under your Account, whether or not you know about them. Verification Information. When you use Sensity B.V.’s Services, we may collect the following personal information:Full name, email address, telephone number, and address; Short selfie videos that contain both visual and audio recordings; Identification documents (which may include passport, driver’s license and any other relevant identification documents requested from time to time) and any data contained within that identification document (for example, age, gender, place of birth, nationality, place of residence); Biometric data that is extracted from both selfie videos and any photos within identification information.
By providing us with selfie videos and/or identification documents, you consent to our extraction and processing of the biometric data contained therein as set forth in this Privacy Notice; Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, or otherwise communicate with us. Surveys.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.Interactive Features. We may offer interactive features such as forums, blogs, chat and messaging services, and social media pages.
We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein.
By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.
Customer Service and Support.
If you call or otherwise interact with Sensity B.V.’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.
Information Collected Automatically.
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your registration date, Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
HOW WE USE YOUR INFORMATION
Sensity B.V. in fulfilling its customer contracts to provide the Services shall use your personal information for a variety of business purposes, including:To Provide the Services or Information Requested, such as: Fulfilling our contract with you; Managing your information; Authenticating the unique biometric information extracted from your selfie videos against the information represented on your identity document. To send you SMS messages where your mobile information is requested for the purpose of fulfilling a multi-factor authentication process.
To populate a user profile composed of your submitted identity documents; Processing payment card and/or other financial information to facilitate your use of the Services; Responding to questions, comments, and other requests; Providing access to certain areas, functionalities, and features of our Services; Answering requests for customer or technical support. Administrative Purposes, such as:Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention; Measuring interest and engagement in our Services; Developing new products and services; Ensuring internal quality control and safety; Authenticating and verifying your identity; Carrying out audits; Communicating with you about your account, activities on our Services and Privacy Notice changes; Preventing and prosecuting potentially prohibited or illegal activities; Enforcing our agreements; and Complying with our legal obligations.
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising” including cross-device tracking. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
Consent.
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, or with your consent.De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
OUR LAWFUL BASIS FOR PROCESSING (EUROPEAN ECONOMIC AREA ONLY).If you are located in the European Economic Area, Sensity B.V.’s processing of your personal information is supported by the following lawful bases:Consent and Explicit Consent: In some cases, Sensity B.V. also relies on your consent and/or explicit consent to process your personal information. For example, by providing us with your selfie video and/or identification documents, you explicitly consent to our extraction and processing of the biometric data contained therein.Compliance with our Legal Obligations: Sensity B.V. may process your personal information to comply with our legal obligations.Performance of a Contract: Sensity B.V. needs to process your personal information to fulfill an agreement to provide the Services.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES.
Sensity B.V. does not share, sell, rent or loan Personal Information to independent third parties. Nevertheless, we may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to:(i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena;(ii) protect your, our, or others’ rights, property, or safety;(iii) enforce our policies or contracts;(iv) collect amounts owed to us; or(v) assist with an investigation or prosecution of suspected or actual illegal activity. Under such circumstances where the law, a court order or other legal process prohibits notice prior to disclosure, none shall be provided.We may share your personal information with the following categories of third parties:Other Organizations at your Instruction. You may instruct Sensity B.V. to share your personal information, including your biometric data, with third parties for their own, independent purposes. Once you share your personal information with these parties, it will be subject to the privacy policy and practices of the receiving party. These third parties are not controlled by Sensity B.V.. We encourage our users to read the privacy policies of each third party with which they interact. We are not responsible for the privacy and security practices of such third parties. Disclosing your information to these third parties is at your own risk.Service Providers. Sensity B.V. employs third party service providers in the process of fulfilling the Services. Where Personal Information is shared with a service provider each third party is required under contract with Sensity B.V. to secure all Personal Information with access permissions provided to only those employees who need it to complete a task on our behalf. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
SUBPROCESSORS
HubSpot Customer relationship management US
Google Workspace Email, office tools, and authentication platform US
Google Cloud Platform (GCP) US
Cloud infrastructure and data storage EU
Google Analytics Analytics EU
Slack Internal communications US
GitHub Source code and task manager US
Trello Task manager US
Notion Knowledge base US
Xero Invoicing Australia
Stripe Payment US
NMBRS Accounting The Netherlands
INTERNATIONAL DATA TRANSFERS.
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, The Netherlands or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. Further details can be provided upon request.
YOUR CHOICES
General. You may have the right to opt out of certain uses of your personal information.Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Notice).
INDIVIDUAL RIGHTS IN PERSONAL INFORMATION.
In accordance with applicable law, you may have the right to:(i) request confirmation of whether we are processing your personal information;(ii) obtain access to or a copy of your personal information;(iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);(iv) object to our processing of your personal information(v) restrict our uses of your personal information; (vi) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information;(vii) withdraw your consent; and(viii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.If you are a Netherlands resident, you have the right not to receive discriminatory treatment by Sensity B.V. for the exercise of your rights.
DATA RETENTION. We store the personal information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We will delete your biometric data within 14 days of your last interaction with the Services.
SECURITY OF YOUR INFORMATION.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable laws, we do not accept liability for unauthorized disclosure.By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
CHILDREN’S INFORMATION.
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.S
SUPERVISORY AUTHORITY.
If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe our processing of your personal information violates applicable law. This Privacy Policy is governed by the applicable laws in the Country of The Netherlands.CHANGES TO OUR PRIVACY NOTICE.We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
CONTACT US: support@sensity.ai