Jumio Washington State Consumer Health Privacy Notice

Use & Processing · Company practice

Health data is collected to provide the verification you requested

Any Consumer Health Data Jumio collects is collected for the purpose of providing the verification and related online services the person requested, naming Authentication, Document Verification, ID Verification and Identity Verification as the “Services”. That list is introduced with “including but not limited to”, so it is not exhaustive. The notice states its security, fraud and illegal-activity uses separately from this purpose sentence.

Supporting quotations

Any Consumer Health Data collected by Jumio is collected for the purpose of providing the verification and related online services requested by you, including but not limited to Authentication, Document Verification, ID Verification, and Identity Verification (the “Services”). Providing the Services may entail:

Qualifications & exceptions

• “Including but not limited to” leaves the named services non-exhaustive.
• The purpose is tied to services the person requested.

Not stated here

• The notice does not define the named services or say which one applies to a particular verification request.

Use & Processing · Procedure

Verifying identity and blocking fraudulent documents are listed steps

Providing the Services may entail verifying identity, preventing the use of fraudulent identification documents, and identifying and monitoring fraudulent transactions. The list follows “may entail”, so these are possible steps rather than a description of every verification. A fourth listed step compares new scans with scans Jumio previously collected.

Supporting quotations

Providing the Services may entail:

Verifying identity;

Preventing the use of fraudulent identification documents; and

Identifying and monitoring fraudulent transactions.

Qualifications & exceptions

• “May entail” makes the steps possible, not mandatory in every verification.

Not stated here

• The notice does not say which checks apply to a given service or what happens when a check fails.

Use & Processing · Permission or license

Security, fraud and illegal-activity uses apply “under certain circumstances”

Under certain circumstances Jumio may also use the data to prevent, detect, protect against or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or activity that is illegal under Washington state law or federal law, and to investigate, report or prosecute those responsible. The notice presents these as further permitted uses and does not describe what the circumstances are.

Supporting quotations

Under certain circumstances Jumio may also use this data to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or activity that is illegal under Washington state law or federal law; or to investigate, report, or prosecute those responsible for any action that is illegal under Washington state law or federal law .

Qualifications & exceptions

• The additional uses are permissions (“may also use”) available “under certain circumstances” that the notice does not enumerate.
• The illegal-activity branch is tied to Washington state law or federal law.

Not stated here

• The notice does not say what the “certain circumstances” are, whether the person is told before this use, or which authorities may receive reports.

Cross-references

• referred to by (model-proposed): Legal advisers, auditors, courts and authorities may receive health data — Disclosures to legal advisers, auditors, courts and public authorities are tied to the circumstances Section 2 describes for security, fraud and illegal-activity uses.