Onfido Privacy Policy

Data Access & Collection · Company practice

Entrust may collect User data from the Customer, the User, or third-party Data Providers

To provide the Services, Entrust collects and processes personal data about the Customer's Users. It may collect that data from the Customer, from the User, or from third-party data providers called Data Providers. Data Providers are trusted third-party service providers or public authorities who supply additional information depending on which Services the Customer has chosen.

Supporting quotations

To provide the Services to a Customer, Entrust collects and processes certain personal data about the Customer’s Users.

Entrust may collect personal data about a User from the Customer, from the User, or from third party data providers (“Data Providers”).

Data Providers are trusted third party service providers or public authorities who provide additional information depending on the Services a Customer has chosen to use.

Qualifications & exceptions

• Collection from Data Providers depends on the Services a Customer has chosen to use.
• The notice says Entrust 'may' collect from these sources; it does not state that every source is used for every check.

Data Access & Collection · Company practice

Which personal data is collected depends on the Customer's integration, collection method and Services chosen

The precise personal data Entrust collects and processes on a Customer's behalf varies with three choices: how the Customer interacts with Entrust (for example API or Dashboard, Part 1 of the table), what data collection method the Customer uses (for example Applicant Form or SDK, Part 2), and which Services the Customer selects (Part 3). The table sets out data Entrust may collect and process; Customers are directed to the API Documentation and Guides for more detail.

Supporting quotations

The precise personal data Entrust collects and processes on behalf of a Customer varies depending on:

How a Customer chooses to interact with Entrust (for example, via our API or the Dashboard as set out in Part 1 of the table below).

What data collection method the Customer chooses to use (for example, our Applicant Form or SDK as set out in Part 2 of the table below).

Which Services the Customer chooses to use (as set out in Part 3 of the table below).

The table below sets out the personal data Entrust may collect and process to provide the Services. Customers should refer to the API Documentation and Guides for more details.

Qualifications & exceptions

• The examples given in the notice (API, Dashboard, Applicant Form, SDK) are illustrative of the categories of choice, not an exhaustive list of methods.
• The table describes data Entrust 'may' collect and process, not data necessarily collected in every engagement.

Not stated here

• The API Documentation and Guides the notice refers to for more detail are not part of the saved source, so the precise fields they define are not established here.

Cross-references

• qualifies (model-proposed): Part 1 data includes user IDs, check results, selected fields, technical metadata and uploaded data — The Part 1 data categories are one application of the determinants rule: the precise data depends on the interaction method, collection method and Services chosen, so the listed categories are not uniform for every engagement.

Data Access & Collection · Company practice

Part 1 data includes user IDs, check results, selected fields, technical metadata and uploaded data

For the Part 1 interaction methods, the table lists categories of personal data that may include: a User unique identifier; check status or outcome and related information such as a Report; optional data fields selected by the Customer from those technically supported and listed in the API Documentation; technical metadata described in that documentation; IP address and associated city/country-level location; and all data the Customer uploads through the Services' custom input or send/receive features for use in a workflow. Entrust also collects the full name, login credentials and usage logs of Customer personnel who access the Dashboard.

Supporting quotations

| Categories of Personal Data: ● User unique identifier ● Check status/outcome and related information (e.g., a Report) ● Optional data fields selected by Customer from those technically supported and listed in the API Documentation) for example, the User’s title - Mr., Mrs., Miss) ● Technical metadata as described in the API Documentation ● IP address and associated city/country level location information ● All data uploaded by Customer via ‘custom input’ or ‘send/receive’ features within the Services for use during a workflow ● All other information processed by Entrust relevant to the applicable Services (Note: Entrust will also collect the full name, login credentials, and usage logs for Customer personnel accessing the Dashboard.)

| Categories of Personal Data: • User unique identifier • Check status/outcome and related information (e.g., a Report) • Optional data fields as listed in the API Documentation

Qualifications & exceptions

• Optional data fields are limited to those technically supported and listed in the API Documentation.
• The stored text presents the table with merged or blank method cells; this card does not assert that every listed category applies to every method.
• The final catch-all covers other information processed by Entrust relevant to the applicable Services.

Not stated here

• The API Documentation that defines the supported optional fields and technical metadata is not part of the saved source.
• Which categories attach to the Dashboard or Studio rows specifically is not clear from the stored flattened table text.

Cross-references

• qualified by (model-proposed): Which personal data is collected depends on the Customer's integration, collection method and Services chosen — The Part 1 data categories are one application of the determinants rule: the precise data depends on the interaction method, collection method and Services chosen, so the listed categories are not uniform for every engagement.

Data Access & Collection · Company practice

Entrust collects User data directly through an Applicant Form or an SDK

Part 2 covers data Entrust collects directly from Users on the Customer's behalf. The Applicant Form lets a User enter data on an Entrust-provided form; it collects images and text-based data specified by the check or process, email address, the content of reminder emails, and a User identifier, and the Customer must already have given Entrust an email address so the form can be sent. The SDK provides drop-in user-interface screens for mobile (iOS and Android) and web applications to capture identity documents and facial photographs or video; its data includes images/video and describing information, IP address and city/country location, anonymized usage data, a User identifier and technical metadata. Telephone number and SMS content are collected only through the web SDK and are optional.

Supporting quotations

| Part 2. Entrust collects additional information directly from Users on behalf of the Customer |

| Categories of Personal Data: ● Images and text-based data (as specified in the relevant check or process) ● Email address ● Content of email sent to Users as a reminder to complete the Applicant Form ● User unique identifier (Note: Customer must have already provided Entrust with an email address so Entrust can send the Applicant Form to the User.) | Applicant Form Enables the User to enter data on an Entrust provided form. |

| Categories of Personal Data: ● Images/video and information describing the images/video (as specified in the relevant check or process) ● Telephone number (web SDK only and optional) ● Content of SMS (web SDK only and optional) ● IP address and associated city/country level location information ● Anonymized usage data ● User unique identifier ● Technical metadata as described in

SDK The SDK provides the Customer with a drop-in set of user interface screens for mobile (iOS and Android) and web applications to allow the capture of identity documents and facial photographs/video for use with the Services.

Qualifications & exceptions

• Telephone number and SMS content are web-SDK only and optional.
• The Applicant Form can be sent only where the Customer has already provided an email address.
• Data categories are as specified in the relevant check or process.

Not stated here

• The technical metadata is described in the API Documentation, which is not part of the saved source.

Data Access & Collection · Company practice

Document Check data includes document images, extracted identity fields and possible face-geometry scans

The Document Check row lists as personal data: images of the identity document; information extracted from the document, such as name, document number, date of birth, nationality, document type, issuing country, expiration date and data embedded in barcodes, QR codes, security chips and features; and data that may be considered a scan of face geometry. The row describes analyzing an image of an identity document, including its portrait photo area, to assess the likelihood that the document is genuine.

Supporting quotations

| Categories of Personal Data: | Document Check Document Check- Driver Verification |

| ● Image(s) of the identity document ● Information extracted from the identity document (for example name, document number, date of birth, nationality, type of document, issuing country, expiration date, information embedded in barcodes, QR codes, security chips and features (which will vary depending on the type of document)) ● Data that may be considered a scan of face geometry

Analyzes an image of an identity document (including the portrait photo area) to assess the likelihood that the document is genuine.

Qualifications & exceptions

• Extracted information varies with the type of document.
• The face-geometry data is described as data that 'may be considered' a scan of face geometry.

Data Access & Collection · Company practice

Document Check - Video stores a 1.5-second document video for Customer access, though the video is not used for checks

Document Check - Video analyzes an image of an identity document to assess the likelihood that the document is genuine and synchronously captures a 1.5-second video of the document alongside the image. The video itself is not used for checks, but it is stored for Customer access as an additional security layer. Its listed data includes the video and images of the document, extracted identity information, and data that may be considered a scan of face geometry.

Supporting quotations

| Categories of Personal Data: ● Video of the identity document ● Image(s) of the identity document ● Information extracted from the identity document (for example name, document number, date of birth, nationality, type of document, issuing country, expiration date, information embedded in barcodes, QR codes, security chips and features (which will vary depending on the type of document)) ● Data that may be considered a scan of face geometry

Document Check – Video Analyzes an image of an identity document (including the portrait photo area) to assess the likelihood that the document is genuine and enhances the identity verification process by synchronously capturing a 1.5-second video of the identity document alongside the image. While the video itself is not used for checks, it is stored for Customer access, providing an additional layer of security.

Qualifications & exceptions

• The video is captured synchronously alongside the document image.
• The video is not used for checks; it is stored for Customer access.
• Extracted information varies with the type of document.

Not stated here

• This row does not state a retention period for the stored video.

Data Access & Collection · Company practice

Proof of Address Check tests whether a non-ID document is suitable proof of address

Proof of Address Check checks that a non-identity document is a suitable proof of address. The listed data is full name, address and postcode, and an image of the proof-of-address document with information describing it.

Supporting quotations

| Categories of Personal Data: ● Full name ● Address and postcode ● Image of proof of address document and information describing the document | Proof of Address Check Checks that a non-ID document is a suitable proof of address. |

Qualifications & exceptions

• The check applies to a non-ID document.

Data Access & Collection · Company practice

Liveness Verification data includes image/video, face scans and an optional Encrypted Biometric Token

The Liveness Verification data row lists an image or video of the User, scans of face geometry and an Encrypted Biometric Token where generated or stored at the Customer's request. The service uses the image or video to confirm a User's presence through a real-time passive facial capture, ensuring the individual is physically present without performing identity matching.

Supporting quotations

| Categories of Personal Data • Image/video of the User • Scans of face geometry • Encrypted Biometric Token (“EBT”), where generated or stored at the Customer’s request | Liveness Verification Uses an image/video to confirm a User’s presence through a real-time passive facial capture (image/video), ensuring the individual is physically present without performing identity matching. |

Qualifications & exceptions

• An EBT is generated or stored only at the Customer's request.
• Liveness Verification does not perform identity matching.

Data Access & Collection · Company practice

Entrust collects broad location data to apply sanctions rules and show consent screens

Entrust may collect a User's broad geographic location, such as country- or city-level location, either directly from the User or Customer or by approximating it from the User's device IP address. The stated purpose is to enable Entrust and its Customers to comply with global sanctions requirements and the increasing number of biometric and privacy laws that apply to the Services. Entrust uses the broad location to determine the User's location in order to display the relevant consent screen and collect any necessary biometric consents, or to identify whether a User is in a sanctioned country where Entrust is prohibited by law from providing services.

Supporting quotations

collect a User’s broad geographic location (e.g. country or city-level location), either directly from them or the Customer or by approximating this based on the User’s device’s IP address, to enable Entrust and our Customers to comply with global sanctions requirements and the increasing number of biometric and privacy laws that apply to the Services. We use this broad geographic location to determine a User’s location to display the relevant consent screen and collect any necessary biometric consents or identify if a User is located in a sanctioned country where we are prohibited by law from providing services.

Qualifications & exceptions

• Location is broad (country or city level), not precise.
• Location may be collected from the User or Customer or approximated from the IP address.
• The stated purposes are sanctions compliance, consent display and identifying sanctioned-country Users.