Onfido Facial Scan Policy and Release

Legal Rights & Agreement Rules · Context

Entrust Facial Scan and Audio Recording Policy, last updated May 23, 2025

The saved page is the Entrust Identity Verification Services Facial Scan and Audio Recording Policy, which refers to itself as the “Facial Scan Policy”. It states that it was last updated on May 23, 2025.

Supporting quotations

Entrust Identity Verification Services Facial Scan and Audio Recording Policy

LAST UPDATED: May 23, 2025

Qualifications & exceptions

• The date shown is a “LAST UPDATED” date; the saved text states no separate effective date.
• The title names the Entrust Identity Verification Services; the scope section says those services were formerly the Onfido Identity Services.

Not stated here

• Whether a later version of the policy has been published is not established by this saved copy.

Use & Processing · Context

Applies to US users of the Entrust Identity Verification Services, formerly Onfido Identity Services

The policy applies to users located in the United States who use the Entrust Identity Verification Services (formerly the Onfido Identity Services), defined as the “Services”. It does not state that it applies to users outside the United States.

Supporting quotations

This Facial Scan and Audio Recording Policy (“Facial Scan Policy”) applies to users located in the United States who use the Entrust Identity Verification Services (formerly the Onfido Identity Services) (“Services”).

Qualifications & exceptions

• The scope is limited to users located in the United States.
• The Services are the Entrust Identity Verification Services, formerly called the Onfido Identity Services.

Not stated here

• The saved text does not list which products or flows make up the Services beyond that name.

Data Access & Collection · Context

Biometric Data covers Scan Data and Scan Information and may count as biometric identifiers

The policy defines “Entrust” as Onfido, Inc. and its affiliate companies. “Scan Data” is data from photos/videos (including audio recordings) of the user and the user's identity documents captured through the device camera or otherwise uploaded, including data that may be construed as a scan of face geometry or a voiceprint extracted from those images/videos. “Scan Information” is information, however captured, converted, stored or shared, based on Scan Data that is used to identify the user. Together they are “Biometric Data”, which the policy says may be considered biometric identifiers or biometric information under applicable biometric privacy laws.

Supporting quotations

Onfido, Inc. and its affiliate companies* (collectively, “Entrust”)

photos/videos (including audio recordings) of you and your identity documents captured via your device camera or otherwise uploaded

data that may be construed as a scan of face geometry or voiceprint extracted from such images/videos of you and your identity documents

“Scan Data”

information, regardless of how it is captured, converted, stored, or shared, based on your Scan Data that is used to identify you (“Scan Information”)

“Biometric Data”

may be considered to be biometric identifiers or biometric information by applicable biometric privacy laws

*Onfido, Inc. affiliate companies

Qualifications & exceptions

• Scan Data includes photos, videos and audio recordings and data extracted from them; Scan Information includes information based on Scan Data regardless of how it is captured, converted, stored or shared.
• The policy says Biometric Data “may be considered” biometric identifiers or biometric information under applicable law; it does not itself decide that classification.
• The asterisk after “affiliate companies” points to the affiliate list that closes the policy.

Not stated here

• Which biometric privacy laws apply to a particular user is not stated.
• The policy does not describe each affiliate's role in the processing.

Legal Rights & Agreement Rules · Company commitment

Read with the Terms of Service and Product Privacy Notice; this policy prevails on inconsistency

The policy should be read in conjunction with the Entrust Identity Verification Service's Terms of Service and Product Privacy Notice, which describe the Services and their use of personal data, including sensitive personal data, in more detail. It adds that, notwithstanding anything to the contrary in those documents or any other document or policy, the terms of the Facial Scan Policy prevail in the event of any inconsistency with other terms or notices provided to the user.

Supporting quotations

read in conjunction with the Entrust Identity Verification Service’s Terms of Service and Product Privacy Notice

which describe the Services and their use of personal data, including sensitive personal data, in more detail

Notwithstanding any indication to the contrary, in the Terms of Service or Product Privacy Notice or any other document or policy, the terms of this Facial Scan Policy shall prevail in the event of any inconsistency with other terms or notices provided to you.

Qualifications & exceptions

• The precedence rule covers inconsistencies with other terms or notices provided to the user.
• The Terms of Service and Product Privacy Notice are linked; their text is not part of the saved source.

Not stated here

• The linked Terms of Service and Product Privacy Notice are not supplied in this source, so their terms and any differences from this policy are not analyzed.

Cross-references

• qualifies (model-proposed): Clicking “Accept” affirms the policy and Terms and consents to processing — The acceptance statement has the user accept both the Facial Scan Policy and the Terms of Service, while the policy's precedence clause says the Facial Scan Policy prevails over the Terms of Service or any other document or policy in the event of inconsistency. Read together, clicking Accept does not make the Terms of Service override this policy where the two conflict.

Use & Processing · Company practice

Entrust and its named Providers process Biometric Data on the client Company's behalf for listed purposes

The policy says the reader is likely directed to it by a company that owns or operates a website or app the reader wants to use, or another service the reader wishes to access (“Company”), and that this Company is an Entrust client. At the Company's request, Entrust and its service providers named below (“Providers”) will collect, capture, obtain, possess, store, use, process, disclose and re-disclose (“Processes”) Biometric Data on the Company's behalf for the purposes the policy lists.

Supporting quotations

You are likely reading this Facial Scan Policy because you have been directed to it by a company that owns or operates a website or app that you are trying to use or some other service you wish to access (“Company”).

This Company is an Entrust client.

At the Company’s request, Entrust, and its service providers named below (“Providers”), will collect, capture, obtain, possess, store, use, process, disclose and re-disclose (“Processes”) Biometric Data on the Company’s behalf, for the purposes of:

Qualifications & exceptions

• The processing is described as at the Company's request and on the Company's behalf.
• “Processes” is defined to cover collection through re-disclosure.
• The Providers are named later in the policy; this card does not describe their identities or practices.

Not stated here

• The policy does not describe the Company's own role or its separate privacy practices.

Use & Processing · Company practice

Purpose: verify identity by comparing facial Biometric Data to the identity document photo

The first listed purpose is verifying the user's identity by comparing facial Biometric Data extracted from the photo/video of the user's face to facial Biometric Data extracted from the photo in the user's identity document.

Supporting quotations

(1) Verifying your identity by comparing facial Biometric Data extracted from the photo/video of your face, to facial Biometric Data extracted from the photo in your identity document;

Qualifications & exceptions

• The comparison uses Biometric Data extracted from the user's photo/video and from the identity document photo.

Use & Processing · Company practice

Purpose: authenticate the user by comparing a reference image to a new photo/video

The second listed purpose is authenticating the user and the user's use of the Company's services by comparing facial Biometric Data from a reference image — for example, an image the user gave the Company at account sign-up or the photo in the user's identity document — to facial Biometric Data extracted from a new photo/video of the user's face.

Supporting quotations

(2) Authenticating you and your use of the Company’s services by comparing facial Biometric Data from a reference image (for example, an image you provided to the Company when you signed up for an account or the photo in your identity document), to the facial Biometric Data extracted from a new photo/video of your face;

Qualifications & exceptions

• The reference-image examples (“for example”) are not exhaustive.

Use & Processing · Company practice

Purpose: detect and prevent fraud, including prior verification and coercion checks

The third listed purpose is analyzing Biometric Data to detect and prevent fraud, including determining whether Entrust has previously verified the user's identity and identifying signs of coercion or social engineering.

Supporting quotations

(3) Analyzing Biometric Data to detect and prevent fraud, including to determine whether Entrust has previously verified your identity and/or to identify signs of coercion or social engineering;

Qualifications & exceptions

• The fraud uses are listed after “including” and are not exhaustive.

Use & Processing · Company practice

Purpose: evaluate the authenticity of images, videos and identity documents

The fourth listed purpose is evaluating the authenticity of images and videos and identity documents, including detecting whether there is a genuine human or physical document in the user's photos/videos or signs of tampering.

Supporting quotations

(4) Evaluating the authenticity of images and videos and identity documents, including detecting whether there is a genuine human or physical document in your photos/videos or signs of tampering; and

Qualifications & exceptions

• The examples after “including” are not exhaustive.

Use & Processing · Company practice

Purpose: improve and develop the Services where permitted by law

The fifth listed purpose is improving and developing the Entrust Identity Verification Services, where permitted by applicable law.

Supporting quotations

(5) Improving and developing the Entrust Identity Verification Services, where permitted by applicable law.

Qualifications & exceptions

• The purpose is limited to what applicable law permits.

Cross-references

• referred to by (model-proposed): No sale, lease or trade of Biometric Data; no profit except for the described purposes — The no-sale/no-profit sentence is subject to “other than for the purposes described in this Policy”. Improving and developing the Services, where permitted by applicable law, is one of the five purposes the policy describes, so it falls within the exception that the no-sale card carries.

Use & Processing · Company practice

Other Personal Data, including sensitive data, is processed for the same purposes

In addition to Biometric Data, Entrust says it will Process other personal data, including sensitive personal data, for the purposes listed above. The examples given are IP address and other data about the user's device, and personal data extracted from the user's identity document such as name and date of birth (“Personal Data”). The policy points to the Entrust Identity Verification Services Product Privacy Notice for more information.

Supporting quotations

In addition to the Biometric Data, Entrust will Process other personal data, including sensitive personal data

(for example IP address and other data about your device and personal data extracted from your identity document e.g. name, date of birth etc) (“Personal Data”)

for the purposes listed above

See the Entrust Identity Verification Services Product Privacy Notice for more information.

Qualifications & exceptions

• The examples of Personal Data follow “for example” and are not exhaustive.
• The Product Privacy Notice is a separate linked document.

Not stated here

• The linked Product Privacy Notice's text is not supplied in this source, so its further detail is not analyzed.

Security & Safeguards · Company commitment

Reasonable, industry-consistent protection at least as protective as for other confidential data

Entrust says it will use reasonable standards of care, consistent with its industry, to store, transmit and protect Biometric Data from disclosure, in a manner that is the same as or more protective than the way it stores, transmits and protects other confidential and sensitive information.

Supporting quotations

Entrust will use reasonable standards of care, consistent with its industry, to store, transmit, and protect from disclosure your Biometric Data, in a manner that is the same as or more protective than the manner in which it stores, transmits, and protects other confidential and sensitive information.

Qualifications & exceptions

• The standard is “reasonable standards of care, consistent with its industry”; no specific measures, audits or certifications are stated.

Sharing & Disclosure · Company commitment

No sale, lease or trade of Biometric Data; no profit except for the described purposes

Entrust says it will not sell, lease, trade or otherwise profit from Biometric Data, except for the purposes described in the policy. The no-profit restriction therefore carries an exception for those purposes, which include the five processing purposes listed earlier.

Supporting quotations

Entrust will not sell, lease, trade, or, other than for the purposes described in this Policy, otherwise profit from Biometric Data.

Qualifications & exceptions

• The exception is “other than for the purposes described in this Policy”.
• The purposes described include verifying identity, authenticating users, fraud prevention, authenticity checks and improving/developing the Services where permitted by law.

Cross-references

• refers to (model-proposed): Purpose: improve and develop the Services where permitted by law — The no-sale/no-profit sentence is subject to “other than for the purposes described in this Policy”. Improving and developing the Services, where permitted by applicable law, is one of the five purposes the policy describes, so it falls within the exception that the no-sale card carries.

Retention & Deletion · Company practice

Biometric Data kept up to 365 days; photos and videos up to three years, then destroyed

Entrust stores and uses Biometric Data for a maximum of 365 days after the user or the Company submitted photos/videos of the user's face and/or identity document to the Services, or a shorter period set by the Company. After that it permanently destroys the Biometric Data it stores, unless law or legal process requires retention. Photos/videos (including audio recordings) are stored for up to three years after submission, then permanently destroyed unless law or legal process requires retention. The policy tells the user to read the Company's own policies to understand how long the Company may retain Biometric Data.

Supporting quotations

Retention of your Biometric Data:

Entrust stores and uses the Biometric Data described above for a maximum of three-hundred and sixty five (365) days after you or the Company submitted photos/videos of your face and/or identity document to the Services, or a shorter retention period set by the Company.

After this, it permanently destroys your Biometric Data that it stores, unless otherwise required by law or legal process to retain the data.

Entrust stores all photos/videos (including audio recordings) for up to three (3) years after submission of photos/videos of your face and/or identity document to the Services, at which time they are permanently destroyed, unless otherwise required by law or legal process to retain the materials.

(You should read the Company’s own privacy related policies and terms of use to understand how long the Company may retain Biometric Data if applicable).

Qualifications & exceptions

• The periods run from submission of the photos/videos to the Services.
• The Company may set a shorter period than 365 days for Biometric Data.
• Destruction is subject to retention otherwise required by law or legal process.
• The three-year period applies to photos/videos (including audio recordings), which the policy distinguishes from the Biometric Data described above.

Not stated here

• The Company's own retention periods are not stated in this policy; it directs the reader to the Company's policies.

Use & Processing · User right or choice

Consent is requested; refusal means no Biometric Data processing or identity verification

The policy says the user will be asked whether they consent to the use of their Biometric Data as described in the policy. If the user does not consent, Entrust will not extract Biometric Data from the user's photos/videos or audio recordings, will not Process the user's Biometric Data, and will not verify or authenticate the user's identity.

Supporting quotations

You will be asked whether you consent to the use of your Biometric Data as described above (see more below).

If you do not consent, Entrust will not extract Biometric Data from your photos/videos or audio recordings, Process your Biometric Data, or verify or authenticate your identity.

Qualifications & exceptions

• The consequence of refusal is stated for extraction, processing and identity verification/authentication.
• The policy does not describe an alternative verification route for a user who refuses.

Not stated here

• What happens to a user who refuses consent beyond the partial-process record and photos/videos the policy says are stored is not stated.

Retention & Deletion · Company practice

Without consent, the partial-process record and photos/videos are kept up to three years

If the user does not consent, Entrust will store a record of the partially completed process and any photos/videos (including audio recordings) in accordance with the Company's instructions, up to a maximum of three years from the time the user terminated the process. After that, Entrust permanently destroys the photos/videos (including audio recordings), unless law or legal process requires retention.

Supporting quotations

Entrust will store a record of the partially completed process and any photos/videos (including audio recordings) in accordance with the instructions of the Company up to a maximum of three (3) years from the time you terminated the process.

After this time Entrust will permanently destroy your photos/videos (including audio recordings), unless otherwise required by law or legal process to retain the materials.

Qualifications & exceptions

• Storage follows the Company's instructions.
• The three-year maximum runs from when the user terminated the process, not from submission.
• Destruction is subject to retention otherwise required by law or legal process.

Sharing & Disclosure · Company commitment

Biometric Data is disclosed only in the circumstances the policy lists

When Processing Biometric Data on behalf of the Company (the Entrust client that directed the user to the policy), Entrust says it will only disclose, redisclose or otherwise disseminate Biometric Data in the circumstances listed. The list covers Company instructions and the user's authorization, financial transactions, legal requirements, warrants or subpoenas, the named Providers, and express consent.

Supporting quotations

Disclosure of your Biometric Data: When Processing your Biometric Data on behalf of the Company, Entrust will only disclose, redisclose or otherwise disseminate Biometric Data in the following circumstances:

This Company is an Entrust client.

Qualifications & exceptions

• The “only” commitment is limited to the listed circumstances.
• The commitment is described for Processing on the Company's behalf.

Not stated here

• The policy does not describe how the Company or the Providers may further disclose Biometric Data.

Sharing & Disclosure · Permission or license

Disclosure to complete a Company transaction as instructed and authorized by the user

One listed circumstance is disclosure in accordance with the Company's instructions, to complete a Company transaction, and as requested and authorized by the user or the user's legally authorized representative.

Supporting quotations

In accordance with the Company’s instructions, to complete a Company transaction and as requested and authorized by you or your legally authorized representative;

Qualifications & exceptions

• The circumstance combines the Company's instructions with the user's request or authorization.
• It is tied to completing a Company transaction.

Sharing & Disclosure · Permission or license

Disclosure to complete a financial transaction the user requested or authorized

Another listed circumstance is disclosure to complete a financial transaction that the user or the user's legally authorized representative requested or authorized.

Supporting quotations

To complete a financial transaction requested or authorized by you or your legally authorized representative;

Qualifications & exceptions

• The disclosure is tied to a financial transaction requested or authorized by the user or the user's representative.

Sharing & Disclosure · Permission or license

Disclosure as required by state or federal law or municipal ordinance

Another listed circumstance is disclosure as required by state or federal law, or by a municipal ordinance.

Supporting quotations

As required by state or federal law, or municipal ordinance;

Qualifications & exceptions

• The circumstance covers requirements of state or federal law and municipal ordinances.

Not stated here

• The policy does not identify particular statutes or the process Entrust follows to assess a requirement.

Sharing & Disclosure · Permission or license

Disclosure as required by a warrant or subpoena from a court of competent jurisdiction

Another listed circumstance is disclosure as required pursuant to a warrant or subpoena issued by a court of competent jurisdiction.

Supporting quotations

As required pursuant to a warrant or subpoena issued by a court of competent jurisdiction;

Qualifications & exceptions

• The circumstance names a warrant or subpoena issued by a court of competent jurisdiction.

Not stated here

• The policy does not describe notice to the user or any challenge process.

Sharing & Disclosure · Permission or license

Named Providers: Microsoft Ireland (speech-to-text) and Amazon Web Services (speech-to-text, storage)

Another listed circumstance is disclosure to a third-party Provider acting on Entrust's behalf: Microsoft Ireland Operations Limited, whose technology converts the user's audio recording into written text (“Speech to Text”), and Amazon Web Services, which provides another Speech to Text service as well as cloud storage.

Supporting quotations

To a third-party Provider acting on Entrust’s behalf, namely Microsoft Ireland Operations Limited (whose technology is used to convert your audio recording into written text (“Speech to Text”)) and Amazon Web Services (who provides another Speech to Text service as well as cloud storage); or

Qualifications & exceptions

• The Providers are named as Microsoft Ireland Operations Limited and Amazon Web Services.
• The card describes only the roles the policy states for them; it does not describe their separate practices.

Not stated here

• The policy does not state the terms on which the Providers act or their own retention periods.

Sharing & Disclosure · Permission or license

Disclosure as expressly consented to by the user or an authorized representative

The final listed circumstance is disclosure as expressly consented to by the user or the user's authorized representative.

Supporting quotations

As expressly consented to by you or your authorized representative.

Qualifications & exceptions

• The consent must be express.

Legal Rights & Agreement Rules · Context

Entrust disclaims responsibility for the Company's and Providers' practices

The policy says Entrust is in no way linked to or responsible for the practices of the Company or the Providers. It encourages the user to read the Company's and any Provider's privacy policies and terms and conditions that may apply to the use of Biometric Data.

Supporting quotations

Entrust is in no way linked to or responsible for the practices of the Company or Providers. Entrust encourages you to read the Company’s and any Provider’s privacy policies and terms and conditions which may apply to the use of Biometric Data.

Qualifications & exceptions

• The disclaimer covers the Company and the Providers.
• The referenced privacy policies and terms are not supplied in this source.

Not stated here

• The Company's and Providers' privacy policies and terms are not supplied in this source, so their practices are not analyzed.

Use & Processing · Permission or license

Clicking “Accept” affirms the policy and Terms and consents to processing

The policy states that by clicking the “ACCEPT” button the user agrees that they: (1) have read, understand and accept the Facial Scan Policy and the Terms of Service; (2) consent to Entrust, the Company and the Providers processing their Biometric Data and other Personal Data for the purposes described in the policy; and (4) confirm that they are not accessing the Services in any jurisdiction where the Services are not permitted by applicable law. The release in element (3) is described in a separate card.

Supporting quotations

BY CLICKING ON THE “ACCEPT” BUTTON, YOU AGREE THAT YOU:

(1) HAVE READ, UNDERSTAND, AND ACCEPT THIS FACIAL SCAN POLICY AND TERMS OF SERVICE;

(2) GRANT CONSENT TO ENTRUST, THE COMPANY AND PROVIDERS TO PROCESS YOUR BIOMETRIC DATA AND OTHER PERSONAL DATA FOR THE PURPOSES DESCRIBED IN THIS FACIAL SCAN POLICY;

(4) CONFIRM THAT YOU ARE NOT ACCESSING THE SERVICES IN ANY JURISDICTION WHERE THE SERVICES ARE NOT PERMITTED BY APPLICABLE LAW.

Qualifications & exceptions

• The consent is given by clicking “ACCEPT”.
• The consent names Entrust, the Company and the Providers and covers Biometric Data and other Personal Data.
• The jurisdiction element is the user's own confirmation, not a verification by Entrust.

Not stated here

• The linked Terms of Service's text is not supplied in this source, so what the user accepts there is not analyzed.

Cross-references

• qualified by (model-proposed): Read with the Terms of Service and Product Privacy Notice; this policy prevails on inconsistency — The acceptance statement has the user accept both the Facial Scan Policy and the Terms of Service, while the policy's precedence clause says the Facial Scan Policy prevails over the Terms of Service or any other document or policy in the event of inconsistency. Read together, clicking Accept does not make the Terms of Service override this policy where the two conflict.
• qualified by (model-proposed): Withdraw consent by contacting the Company as described in its Privacy Policy — Consent is given by clicking Accept, but the policy routes withdrawal through the Company as described in the Company's Privacy Policy. This qualifies how the consent granted by the click-through can be undone.

Legal Rights & Agreement Rules · Permission or license

Clicking Accept releases claims related to Biometric Data and photos/videos

As part of the same click-through statement, the user agrees to release, in favour of Entrust, the Company and the Providers, any claims related to their Biometric Data and photo/video (including audio recordings).

Supporting quotations

(3) RELEASE IN FAVOUR OF ENTRUST, THE COMPANY, AND THE PROVIDERS ANY CLAIMS RELATED TO YOUR BIOMETRIC DATA, PHOTO/VIDEO (INCLUDING AUDIO RECORDINGS);

Qualifications & exceptions

• The release is part of the click-through “ACCEPT” statement.
• It is stated in favour of Entrust, the Company and the Providers.
• It covers claims related to Biometric Data and photo/video, including audio recordings.

Not stated here

• The policy does not say whether the release is limited to claims connected with the described processing or reaches other claims.

Legal Rights & Agreement Rules · User right or choice

Withdraw consent by contacting the Company as described in its Privacy Policy

The policy says that a user who consents and later wants to withdraw consent should contact the Company as described in the Company's Privacy Policy.

Supporting quotations

Withdrawal of your consent: If you consent now but would like to later withdraw your consent, please contact the Company as described in the Company’s Privacy Policy.

Qualifications & exceptions

• The withdrawal route runs through the Company, not Entrust.
• The procedure is the one described in the Company's Privacy Policy.

Not stated here

• The Company's Privacy Policy is not supplied in this source, so the withdrawal procedure and its effects are not stated here.

Cross-references

• qualifies (model-proposed): Clicking “Accept” affirms the policy and Terms and consents to processing — Consent is given by clicking Accept, but the policy routes withdrawal through the Company as described in the Company's Privacy Policy. This qualifies how the consent granted by the click-through can be undone.

Legal Rights & Agreement Rules · Context

Affiliate list: Onfido entities, Airside Mobile and Entrust Corporation with its subsidiaries

The policy's asterisked list of “Onfido, Inc. affiliate companies” names Onfido Ltd (London), Onfido SAS (Paris), Onfido Inc (Camden, Delaware), Onfido GmbH (Hamburg), Onfido Unipessoal (Lisbon), Onfido Services India Private Limited (Mumbai), Onfido PTE Ltd (Singapore), Onfido BV (Amsterdam-Duivendrecht), Airside Mobile Inc (Delaware), and Entrust Corporation (Shakopee, Minnesota) together with each of its subsidiaries that may process personal data to provide the Services to the Company. Each entry gives the entity's address.

Supporting quotations

*Onfido, Inc. affiliate companies

Onfido Ltd 14-18 Finsbury Square, 3rd Floor, London, England, EC2A 1AH

Onfido SAS Regus La Defense Tour Ariane, 5 place de la Pyramide, 92088 Paris La Defense Cedex

Onfido Inc Paracorp Incorporated, 2140 South Dupont Highway, Camden, Delaware 19934

Onfido GmbH Am Kaiserkai 69, 20457 Hamburg

Onfido Unipessoal Avenida D João II, n°46 - 4A, 1990-095 Lisboa

Onfido Services India Private Limited Unit No. 9, Corporate Park II, 9th floor, VN Purav Marg, Near Swastik Chambers, Chembur, Mumbai - 400071

Onfido PTE Ltd 100 Tras Street, #16-01, 100 AM, Singapore (079027)

Onfido BV Ground, 1st, 2nd and 3rd Floor, Joop Geesinkweg 901-999, Amsterdam-Duivendrecht, 1114 AB, Netherlands

Airside Mobile Inc 3500 S Dupont Highway, Dover, Kent Country, 19901, Delaware

Entrust Corporation, 1187 Park Place, Shakopee, Minneapolis, MN 55379, Minnesota and each of its subsidiaries who may process personal data in order to provide the Services to the Company.

Qualifications & exceptions

• The list gives the entities' addresses; it does not describe each entity's role.
• Entrust Corporation is listed together with each of its subsidiaries that may process personal data to provide the Services.

Not stated here

• The policy does not state which entity contracts with a particular Company or user.