Jumio Washington State Consumer Health Privacy Notice

Sharing & Disclosure · Company commitment

Jumio states it does not “sell” Consumer Health Data

Jumio says it does not “sell” any Consumer Health Data. The word appears in quotation marks but is not defined in this notice, so the sentence does not describe every disclosure by itself; the same section goes on to permit disclosures to the business customer and to processors.

Supporting quotations

Jumio does not “sell” any Consumer Health Data. Jumio may disclose Consumer Health Data to the following types of third parties:

Qualifications & exceptions

• The no-sale statement puts “sell” in quotation marks and the notice does not define the term here.

Not stated here

• Whether “sell” carries MHMD’s statutory meaning is not stated in this notice.

Sharing & Disclosure · Permission or license

The business customer behind your verification may receive the data

Jumio may disclose Consumer Health Data to the Jumio business customer(s) with which the person has a relationship and through which they accessed the Services. The notice does not name any customer or say whether that customer’s own privacy terms also govern the data it receives.

Supporting quotations

Jumio does not “sell” any Consumer Health Data. Jumio may disclose Consumer Health Data to the following types of third parties:

The Jumio business customer(s) with which you have a relationship and through which you accessed the Services; and

Qualifications & exceptions

• The recipient is the customer the person has a relationship with and through which the person accessed the Services.

Not stated here

• The notice does not name the business customers or describe the terms under which they handle data they receive.

Sharing & Disclosure · Permission or license

Processors, including cloud providers, help run the Services

Jumio may disclose Consumer Health Data to service providers — also called processors under MHMD — that help it deliver, manage, develop and improve the Services, including third-party cloud service providers. The provider list is non-exhaustive (“including but not limited to”).

Supporting quotations

Jumio does not “sell” any Consumer Health Data. Jumio may disclose Consumer Health Data to the following types of third parties:

Service providers (also known as “processors” under MHMD) that help us deliver, manage, develop, and improve the Services including but not limited to third-party cloud service providers.

Qualifications & exceptions

• “Including but not limited to” leaves the provider categories open.

Not stated here

• The notice does not name the processors, state where they process the data, or say what terms govern them.

Sharing & Disclosure · Permission or license

Legal advisers, auditors, courts and authorities may receive health data

When the circumstances set out in Section 2 apply — security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or activity illegal under Washington or federal law, and related investigation or prosecution — Jumio may disclose Consumer Health Data to legal advisors, to auditors performing audits, and to courts and public authorities. The disclosure rests on that Section 2 trigger, not on a separate standard stated here.

Supporting quotations

Moreover, under certain circumstances as set out in Section 2 (“How we use your Consumer Health Data”) we may disclose your Consumer Health Data with the following categories of recipients:

Legal advisors;

Auditors for the performance of audits; and

Courts and public authorities.

Qualifications & exceptions

• The recipients are introduced as categories tied to the circumstances Section 2 describes.

Not stated here

• The notice does not say what evidence is required before a disclosure to these recipients or whether the person is told about it.

Cross-references

• refers to (model-proposed): Security, fraud and illegal-activity uses apply “under certain circumstances” — Disclosures to legal advisers, auditors, courts and public authorities are tied to the circumstances Section 2 describes for security, fraud and illegal-activity uses.