Onfido Privacy Policy

Legal Rights & Agreement Rules · Context

This page is the Entrust Identity Verification Services product privacy notice, last updated September 30, 2026

The saved page is titled 'Entrust Identity Verification Services Product Privacy Notice' and states that it was last updated on September 30, 2026. It is a product-specific privacy notice for the Entrust identity verification Services. The saved buffer registration names it the Onfido Privacy Policy; the notice itself names Onfido Ltd as the controller for controller-side processing.

Supporting quotations

Entrust Identity Verification Services Product Privacy Notice

Last updated: September 30, 2026

Qualifications & exceptions

• The notice is product-specific: it addresses the Entrust Identity Verification Services rather than all Entrust or Onfido processing.
• The saved capture's retrieval record did not observe the HTTP status or redirect destination for the source URL.

Not stated here

• Whether the page at onfido.com/privacy and the entrust.com product-privacy page display the same version; the saved record does not establish a redirect.

Use & Processing · Company practice

Entrust handles Service data as the Customer's processor; Customers must explain that processing to Users

The Services help business Customers verify their Users' identities, carry out identity-related checks, or authenticate Users. When Entrust collects and processes personal data to provide those Services to a Customer, it acts on the Customer's behalf as their service provider and processor. The notice says Customers, not Entrust, are responsible for explaining this processing to their Users.

Supporting quotations

The Entrust Identity Verification Services (“Services”) help Customers verify their Users

When Entrust Corporation and its subsidiaries (“Entrust“) verifies an identity

When Entrust collects and processes personal data for the purpose of providing the Services to a Customer, Entrust acts on the Customer’s behalf as their service provider and processor.

NOTE: Customers are responsible for explaining this processing to their Users.

Qualifications & exceptions

• The processor role described applies to personal data processed for the purpose of providing the Services to a Customer.
• Entrust Corporation and its subsidiaries are referred to collectively as 'Entrust' in the notice.
• Entrust's separate controller-side processing is addressed by another card.

Cross-references

• contrast (model-proposed): Entrust also uses Service data as controller to develop, improve and analyze the Services — The same service data can be processed under two roles: Entrust acts as the Customer's processor to provide the Services, and separately as a controller for development and improvement uses. The notice keeps these roles distinct.

Use & Processing · Company practice

Entrust also uses Service data as controller to develop, improve and analyze the Services

Separately from its processor role, Entrust processes personal data on its own behalf as a controller. It may combine personal data collected while providing the Services with publicly available data to develop, improve, analyze, secure, test, validate and enhance the Services, including through analytics, automated processing, machine learning and artificial intelligence where permitted by applicable law. Onfido Ltd is the controller for this processing.

Supporting quotations

As well as handling personal data on behalf of a Customer for the purpose of providing the Services to them, Entrust also collects and processes personal data on our own behalf as a controller.

including through analytics, automated processing, machine learning, and artificial intelligence technologies where permitted by applicable law.

Onfido Ltd is the Controller for this processing.

Qualifications & exceptions

• Controller-side use is limited to where permitted by applicable law.
• The notice refers readers to its 'Using Personal Data as Controller' section for the purposes and legal bases of this processing.

Cross-references

• contrast (model-proposed): Entrust handles Service data as the Customer's processor; Customers must explain that processing to Users — The same service data can be processed under two roles: Entrust acts as the Customer's processor to provide the Services, and separately as a controller for development and improvement uses. The notice keeps these roles distinct.

Legal Rights & Agreement Rules · Context

Customers are organizations; Users are the individuals whose identities are checked

The notice defines Customers as organizations that ask Entrust to provide the Services to verify someone's identity or carry out identity-related checks. Users are the individuals whose identities a Customer has asked Entrust to verify or otherwise check through the Services.

Supporting quotations

“Customers” are organizations that have asked Entrust to provide the Services to verify someone’s identity, or to carry out checks related to their identity.

“Users” are the individuals whose identities a Customer has asked Entrust to verify or otherwise check via the Services.

Qualifications & exceptions

• These definitions govern how the notice uses 'Customer' and 'User' throughout.

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.

Account & Service Control · Context

Customers interact with Entrust through the API, Dashboard, Studio or a third-party tracking system

Part 1 of the table covers situations where the Customer initiates a check or process and interacts directly with Entrust. It describes four interaction methods: the API, a REST-based interface using standard HTTP response codes; the Dashboard, a graphical user interface to the API; Studio, a visualization layer and workflow builder with no/low-code tools for dynamic user journeys; and a third-party User tracking system that the Customer procures to interact with the API and track Users.

Supporting quotations

| Part 1. Customer initiates a check/process and interacts directly with Entrust |

Application Programming Interface (API) The API is based on REST principles and uses standard HTTP response codes to enable Customer to transmit and receive data from Entrust, as further described in the API Documentation.

Dashboard The Dashboard is a graphical user interface to the API, as further described in the API Documentation.

Studio Studio is a visualization layer and workflow builder providing the Customer with no/low-code tools to create and configure dynamic user journeys incorporating the Services.

Third Party User Tracking System The Customer procured a third-party User tracking system to interact with the API and track Users.

Qualifications & exceptions

• Part 1 applies where the Customer initiates the check and interacts directly with Entrust.
• The table's descriptions are brief; the API Documentation is cited for further detail.

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.

Use & Processing · Company practice

Document Checks analyze identity documents to assess authenticity and signs of tampering

Part 3 describes Document Checks, which verify identity documents from across the globe by analyzing an image or video of the document. Entrust's system extracts information from the image/video or, where possible, from the document's security chip. Its models analyze authenticity, potentially including machine-readable zones, barcodes, QR codes and security chips, to determine whether the document is genuine or shows signs of tampering.

Supporting quotations

| Part 3. Entrust processes the data collected in (1) and (2), above and the following data, on behalf of the Customer to provide the Services |

Document Checks verify identity documents from across the globe by analyzing an image or video of the document. Our system extracts information from the image/video or, if possible, from the security chip embedded in the document. Our models analyze the authenticity of the document, which may include machine-readable zones, barcodes, QR codes, and security chips, to verify whether the document is genuine or shows signs of tampering.

Qualifications & exceptions

• Extraction from a security chip applies only 'if possible' for the document.
• The listed document features 'may include' those elements; they are not guaranteed for every document.

Cross-references

• qualifies (model-proposed): Document Checks compare identity documents with leaked or public compromised-identity data — The compromised-identity comparison is an additional step in the Document Checks process, alongside the authenticity and tampering analysis.

Linking & Identification · Company practice

Document Checks compare identity documents with leaked or public compromised-identity data

Entrust also compares the image or video of the identity document with information about compromised identities that have been leaked or otherwise made publicly available. The notice does not describe what happens when the comparison produces a match.

Supporting quotations

We will also compare the image or video of the identity document with information about compromised identities that have been leaked or otherwise made publicly available.

Qualifications & exceptions

• The comparison uses information about compromised identities that has been leaked or is otherwise publicly available.

Not stated here

• The notice does not state what happens when the comparison produces a match, or how long the comparison data is retained.

Cross-references

• qualified by (model-proposed): Document Checks analyze identity documents to assess authenticity and signs of tampering — The compromised-identity comparison is an additional step in the Document Checks process, alongside the authenticity and tampering analysis.

Use & Processing · Company practice

Entrust may mask Dutch BSN numbers when Dutch law requires it

For Users living in the Netherlands, Entrust may automatically mask the BSN number on their identity document in its back-end systems when required under Dutch law, particularly the Dutch Prevention of Money Laundering and Terrorist Financing Act.

Supporting quotations

NOTE: Users living in the Netherlands should be advised that Entrust may automatically mask the BSN number on their identity document in our back-end systems when required under Dutch law, and particularly the Dutch Prevention of Money Laundering and Terrorist Financing Act.

Qualifications & exceptions

• The masking applies to Users living in the Netherlands.
• Masking is discretionary ('may') and conditioned on a requirement under Dutch law.

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.

Use & Processing · Company practice

Biometric checks compare face-geometry scans from a Selfie and a reference image

For biometric checks, Entrust asks for an image or video (which may include an audio recording) of the User's face (a 'Selfie') and an image or video to use as a reference, such as an image of their identity document. It generates two scans of the User's face geometry, one from the Selfie and one from the reference image, and compares them to assess whether the person in the Selfie is likely to be the same person pictured in the reference image. Entrust also evaluates the authenticity of the images, videos and identity documents, including detecting whether a genuine human or physical document is present and identifying signs of tampering, coercion or social engineering.

Supporting quotations

| Biometric Checks and Authentication These services involve the processing of data that may be considered biometric identifiers or biometric information under applicable laws When providing biometric checks as part of our Services, we’ll ask for an image or video (which may include an audio recording) of a User’s face (a “Selfie”), as well as an image or video to use as a reference image (for example, an image of their identity document). We generate two scans of the User’s face geometry (one scan using the Selfie, and one scan using the reference image) and we compare those two scans to assess whether the person in the Selfie is likely to be the same person

We will also evaluate the authenticity of the images and videos (including audio recordings) and identity documents, including detecting whether there is a genuine human or physical document in the images/videos, and identifying signs of tampering, coercion or social engineering.

Qualifications & exceptions

• The comparison assesses whether the person is 'likely to be' the same, not a certainty.
• The Selfie image or video may include an audio recording.
• The reference image is exemplified by, but not limited to, an identity document.

Cross-references

• qualifies (model-proposed): Extracted face scans are not kept after a check, except for fraud checks — The comparison generates face-geometry scans, while the retention rule limits their storage after the check, except for the fraud-check services.

Retention & Deletion · Company commitment

Extracted face scans are not kept after a check, except for fraud checks

Except as described under 'Fraud checks, including device integrity and fraud signals', Entrust does not store the extracted face scans once a biometric check is complete. Where a Customer asks Entrust to provide an authentication service, the Customer may ask Entrust to store a reference image chosen by the Customer for each relevant User; that image is retained under Customer-set retention periods, subject to minimum or maximum periods specified by Entrust or applicable law. Authentication generates two face scans, one from a new image/video and one from the stored reference, and a match confirms authentication. For Known Faces, Document Known Faces, Authentication: Motion, Face Authentication, Biometric Passkey and Liveness Verification, the maximum period a Customer may instruct Entrust to store and use face scans is 365 days after the Company or User submitted the image/video used to generate the scan.

Supporting quotations

Except as described under the section below headed “Fraud checks, including device integrity and fraud signals”, when performing biometric checks, we do not store the extracted face scans once the check is complete.

Where a Customer has asked us to provide an authentication service, the Customer may ask Entrust to store a reference image chosen by the Customer for each relevant User. (This image is retained in accordance with retention periods set by the Customer subject to any minimum / maximum retention periods specified by Entrust or in applicable laws.)

When Entrust is asked to authenticate a User, we will generate two face scans - one using a new image or video of the User, and one using the reference image we have stored. If the two face scans match, the authentication is confirmed.

The maximum period of time for which a Customer may instruct Entrust to store and use face scans for the purpose of these services is three-hundred and sixty-five (365) days after the Company or the User submitted to Entrust the image / video used to generate the face scan.

Qualifications & exceptions

• The no-storage commitment is expressly subject to the fraud-checks section.
• Stored authentication reference images follow Customer-set retention periods, subject to Entrust or legal minimums and maximums.
• The 365-day maximum applies to the listed services (Known Faces, Document Known Faces, Authentication: Motion, Face Authentication, Biometric Passkey, Liveness Verification).

Not stated here

• The linked Facial Scan and Audio Recording Policy is not part of the saved source.
• The fraud-checks section's storage rules are analyzed separately and are not restated here.

Cross-references

• qualified by (model-proposed): Biometric checks compare face-geometry scans from a Selfie and a reference image — The comparison generates face-geometry scans, while the retention rule limits their storage after the check, except for the fraud-check services.
• has exception (model-proposed): Known Faces compares a new biometric check with prior checks and adds the new face scan to the database — Known Faces is one of the fraud-check services that operates as an exception to the general no-storage rule for extracted face scans: it adds the new scan to a comparison database and can retain it up to the stated maximum.

Legal Rights & Agreement Rules · Context

Face scan data may be a protected biometric identifier; US policy reference

The notice says these services involve data that may be considered a scan of face geometry or voiceprint, and that may be considered biometric identifiers or biometric information under applicable biometric privacy laws. Users located in the United States should refer to the Facial Scan and Audio Recording Policy for further details.

Supporting quotations

NOTE: These services involve the use of data that may be considered a scan of face geometry or voiceprint, and which may be considered biometric identifiers or biometric information by applicable biometric privacy laws. For more information, please refer to the Facial Scan and Audio Recording Policy for further details.

Users located in the US should refer to the Facial Scan and Audio Recording Policy for further details.

Qualifications & exceptions

• The notice says the data 'may be considered' biometric identifiers or information; it does not itself classify the data under a particular law.
• The United States-specific policy reference is stated separately from the general biometric description.

Not stated here

• The Facial Scan and Audio Recording Policy is linked but not part of the saved source, so its terms are not established here.

Use & Processing · Company practice

Facial Similarity Check - Selfie compares an ID or reference face with a Selfie image

Facial Similarity Check - Selfie compares the face displayed on an identity document or reference image with an image of the User's face to verify that they are the same. The listed data is an image of the User's face, an image of the face in the identity document or reference image, and scans of face geometry.

Supporting quotations

| Categories of Personal Data: ● Image of the User’s face ● Image of the face in the identity document / reference image ● Scans of face geometry | Facial Similarity Check - Selfie Compares the face displayed on an identity document or reference image with an image of the User’s face, to verify that they are the same. |

Qualifications & exceptions

• The comparison is between the reference-image face and the Selfie image.

Inference & Profiling · Company practice

Facial Similarity Check - Selfie Auto makes the comparison automatically, without human review

Facial Similarity Check - Selfie Auto compares the face displayed on an identity document or reference image with an image of the User's face to verify that they are the same. The notice states that this is done automatically and without any human review.

Supporting quotations

| Categories of Personal Data: ● Image of the User’s face ● Image of the face in the identity document / reference image ● Scans of face geometry | Facial Similarity Check - Selfie Auto Automatically (and without any human review) compares the face displayed on an identity document or reference image with an image of the User’s face, to verify that they are the same. |

Qualifications & exceptions

• The notice expressly says 'without any human review' for this check.

Use & Processing · Company practice

Facial Similarity Check - Video compares a facial scan from video and performs liveness detection, with mandatory audio

Facial Similarity Check - Video compares the face displayed on an identity document or reference image with a facial scan captured from a video of the User to verify that they are the same, while also performing liveness detection. The notice says this includes mandatory processing of audio. Its data includes video of the User with audio recording, images of the reference face, transcribed text data from the video clip, and data that may be biometric identifiers or information such as face-geometry scans or voiceprints.

Supporting quotations

| Categories of Personal Data: ● Video of the User (including audio recording) ● Image of the face in the identity document / reference image ● Transcribed text data from the video clip ● Data that may be considered biometric identifiers or biometric information (e.g., scans of face geometry or voiceprints) | Facial Similarity Check - Video Compares the face displayed on an identity document or reference image with a facial scan captured from a video of the User, to verify that they are the same while also performing liveness detection. Includes mandatory processing of audio. |

Qualifications & exceptions

• Audio processing is mandatory for this check.
• The video check also performs liveness detection.

Inference & Profiling · Company practice

Facial Similarity Check - Motion runs automatically with customizable liveness detection and optional audio

Facial Similarity Check - Motion automatically, and without any human review, compares the face displayed on an identity document or reference image with a facial scan captured from a video of the User to verify that they are the same, while also performing customizable liveness detection. Audio processing is optional for this check. Its data includes video of the User with background audio at the Customer's option, the reference face image, transcribed text from the video clip if applicable, and data that may be biometric identifiers or information such as face-geometry scans or voiceprints.

Supporting quotations

| Categories of Personal Data: • Video of the User (including background | Facial Similarity Check - Motion |

audio recording at Customer’s option) ● Image of the face in the identity document / reference image or video ● Transcribed text from the video clip (if applicable) ● Data that may be considered biometric identifiers or biometric information (e.g., scans of face geometry or voiceprints) | Automatically (and without any human review) compares the face displayed on an identity document or reference image with a facial scan captured from a video of the User, to verify that they are the same, while also performing customizable liveness detection. Includes optional processing of audio. |

Qualifications & exceptions

• The check runs automatically and without human review.
• Liveness detection is customizable.
• Background audio recording is at the Customer's option and audio processing is optional.

Linking & Identification · Company practice

Data Verification checks compare User data with Data Provider records and internal checks

Entrust provides data verification checks through a network of trusted Data Providers and its own internal checks. The checks let Customers verify Users, detect fraud and comply with anti-money laundering (AML) and Know Your Client (KYC) requirements. Entrust compares personal data provided by the Customer or User with information held by Data Providers or extracted from documents, such as a utility bill for an address check. The available network varies by the User's location and includes voter and driving licence registers, other government databases, police databases, consumer credit agencies, sanctions and politically exposed persons (PEP) lists, adverse media, utility companies, mobile network providers and other trusted commercial or authoritative sources. In certain jurisdictions, and where selected by the Customer, authoritative-source verification may compare document-derived data, identity information and, where applicable, biometric data against a government or other authoritative database; authorized service providers may facilitate this and consent indicators and request/response data may be processed. At a Customer's request, checks may run on an ongoing basis, for example for regulatory monitoring against sanctions and PEP lists.

Supporting quotations

Entrust provides Customers with data verification checks via a network of trusted Data Providers (defined above) and our own internal checks. These checks enable Customers to verify their Users, detect fraud, and comply with anti-money laundering (AML) and Know Your Client (KYC) requirements.

We conduct these checks by comparing personal data provided by the Customer or the User with information held by Data Providers or information extracted from documents, e.g. a utility bill for proof of address checks.

Our global network of data verification services varies depending on a User's location and includes voter and driving license registers and other government databases, police databases, consumer credit agencies, sanctions and Politically Exposed Persons (PEP) lists, adverse media sources, utility companies, mobile network providers and other trusted commercial or authoritative sources.

In certain jurisdictions, and where selected by the Customer, data verification services may include authoritative-source verification that compares document-derived data, identity information, and where applicable, biometric data against a government or other authoritative database.

At the request of a Customer, these services may be provided on an ongoing basis, for example where a Customer’s regulatory obligations require ongoing monitoring against sanction and PEP lists.

Qualifications & exceptions

• The available checks and information vary by the User's location and the Services selected.
• Authoritative-source verification applies only in certain jurisdictions and where selected by the Customer.
• Ongoing checks are provided at the Customer's request.
• The information collected may include contact details, national identity numbers, utility-bill information, media-search information and sanctions/PEP information.

Not stated here

• The notice does not name every Data Provider or authoritative source used in each jurisdiction.

Linking & Identification · Company practice

Identity Record Check queries authoritative databases and may compare biometric data where supported

The Identity Record Check group (including DVS Database Check, Known Fraud Query, Country Database Query, INE Database Query, Mexico CURP by RENAPO and Mexico RFC by SAT) searches third-party, government, public-authority or other authoritative databases. It identifies whether a User is included, confirms personal data provided by the User or Customer and, where the selected Service supports it, compares document-derived data and biometric data against an authoritative source. The listed data includes full name, date of birth, address and postcode, government-issued identifiers such as Social Security Number, tax ID, voter credential number or population registry number where applicable, telephone number, information extracted from an identity document, and a face image or biometric data where required for the selected database verification service.

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth ● Address and postcode ● National o r g o v e r n m e n t - i s s u e d identifiers where applicable, such as Social Security Number, tax ID number, voter credential number, unique population registry number, or similar identifier) ● Telephone number ● Information extracted from an identity document ● Image of the User’s face and data that may be considered biometric identifiers or biometric information, where required for the selected database verification service.

Searches third party, government, public authority, or other authoritative database(s) to identify whether a User is included in the relevant database(s), confirm personal data provided by the User or Customer, and where supported for the selected Service, compare document-derived data and biometric data against an authoritative source.

Qualifications & exceptions

• Government-issued identifiers apply only 'where applicable'.
• Face image or biometric data is collected only where required for the selected database verification service.
• Biometric comparison against an authoritative source applies only where supported for the selected Service.

Not stated here

• The notice does not identify which databases are available in each country or which support biometric comparison.

Linking & Identification · Company practice

Watchlist Reports search watchlist, sanctions, PEP and adverse-media databases

Watchlist Report products search third-party databases to identify whether a User is included. Enhanced searches watchlist and sanctions databases; Standard searches watchlist, politically exposed persons and sanctions databases; AML searches watchlist, politically exposed persons, sanctions and adverse media databases. For each, the listed data is full name, date of birth and address/post/zip code, with date of birth and address marked as Customer optional.

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth (Customer optional) ● Address and post/zip code (Customer optional) | Watchlist Report – Enhanced Searches third party watchlist and sanctions databases to identify whether a User is included in that database. |

| Categories of Personal Data: ● Full name ● Date of birth (Customer optional) ● Address and post/zip code (Customer optional) | Watchlist Report - Standard Searches third party watchlist, politically exposed persons and sanctions databases to identify whether a User is included in that database |

| Categories of Personal Data: ● Full name ● Date of birth (Customer optional) ● Address and post/zip code (Customer optional) | Watchlist Report - AML Searches third party watchlist, politically exposed persons, sanctions, and adverse media databases to identify whether a User is included in that database. |

Qualifications & exceptions

• Date of birth and address/post/zip code are Customer-optional for these three reports.
• The databases searched differ by report: Enhanced omits PEP and adverse media; Standard omits adverse media; AML includes all listed sources.

Linking & Identification · Company practice

Ongoing Watchlist checks repeat every 24 hours

Watchlist AML Ongoing and Watchlist Standard Ongoing search third-party watchlist, politically exposed persons, sanctions and adverse media databases every 24 hours to identify whether a User is included. Both list full name, date of birth and address/post/zip code, with address optional. The notice describes the two products with the same data and search scope.

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth ● Address and post/zip code (Customer optional) | Watchlist AML Ongoing Searches third party watchlist, politically exposed persons, sanctions, and adverse media databases every 24 hours to identify whether a User is included in that database. |

| Categories of Personal Data: ● Full name ● Date of birth ● Address and post/zip code (Customer optional) | Watchlist Standard Ongoing Searches third party watchlist, politically exposed persons, sanctions, and adverse media databases every 24 hours to identify whether a User is included in that database. |

Qualifications & exceptions

• The checks repeat every 24 hours.
• Address/post/zip code is Customer-optional; date of birth is not marked optional in these rows.
• The notice describes the AML Ongoing and Standard Ongoing rows with the same databases and data fields.

Not stated here

• The notice does not state when ongoing monitoring stops or how the Customer configures its duration.

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.

Use & Processing · Company practice

Autofill classifies identity documents and returns OCR-extracted human-readable data

Autofill classifies identity documents and, using optical character recognition technology, returns automatically extracted human-readable data from the identity document. The listed data is an image of the identity document and information describing it.

Supporting quotations

| Categories of Personal Data: • Image of the identity document and information describing the identity document | Autofill Classifies identity documents and using optical c h a r a c t e r r e c o g n i t i o n t e c h n o l o g y , returns automatically extracted human- readable data from the identity document. |

Qualifications & exceptions

• The extraction is automatic and uses optical character recognition.

Linking & Identification · Company practice

AAMVA Check searches participating US state DMV databases via a third-party sub-processor

The American Association of Motor Vehicle Administrators (AAMVA) Check uses the AAMVA Driver's License Data Verification (DLDV) service, through a third-party sub-processor, to search participating US state DMV databases and match a User's personal details. The listed data is full name, document ID number, US state code and optional data fields from the identity document at the Customer's option.

Supporting quotations

| Categories of Personal Data: ● Full name ● Document ID number ● US state code ● Optional data fields from the identity Document (at Customer’s option) | American Association of Motor Vehicle Administrators (AAMVA) Check Uses the AAMVA Driver’s License Data Verification (DLDV) service (via a third-party sub-processor) to search participating US state DMV databases to match a User’s personal details. |

Qualifications & exceptions

• Only participating US state DMV databases are searched.
• The service is provided via a third-party sub-processor.
• Optional identity-document fields are included at the Customer's option.

Not stated here

• The notice does not list which states participate.

Linking & Identification · Company practice

India Tax ID verifies a PAN against the Income Tax Department of India database

The India Tax ID service verifies that the Personal Account Number (PAN) provided by the User or Customer matches the PAN number found on the database held by the Income Tax Department of the Government of India. The listed data is full name, date of birth and PAN.

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth ● Personal Account Number (PAN) | India Tax ID Verifies that the PAN provided by the User or Customer matches the PAN number found on the database held by the Income Tax Department of the Government of India. |

Qualifications & exceptions

• The check is limited to matching the PAN against the Indian Income Tax Department database.

Linking & Identification · Company practice

UK eVisa uses a User-generated sharecode to search the UK Home Office visa record database

The UK eVisa service uses an eVisa sharecode generated by the User to search the UK Home Office's electronic visa record database and verify the identity of individuals in the UK. The listed data is a photo, first and last name, date of birth, eVisa share code and eVisa expiration date.

Supporting quotations

| Categories of Personal Data: • Photo • First and last name • Date of birth • eVisa share code • eVisa expiration date | UK eVisa Uses an eVisa sharecode generated by the User to search the UK Home Office’s electronic visa record database to verify the identity of individuals in the UK. |

Qualifications & exceptions

• The sharecode is generated by the User.
• The search is limited to the UK Home Office's electronic visa record database.

Inference & Profiling · Company practice

Phone Verification Report checks mobile-number status through mobile network databases and scores fraud risk

The Phone Verification Report searches a range of mobile network operator databases, through a third party, to verify whether a phone number provided by a User is active and reachable. It also considers additional phone intelligence attributes to help the Customer assess the fraud risk associated with the phone number. The listed data is full name, address, mobile number, mobile number network history details, mobile account details and a mobile risk score.

Supporting quotations

| Categories of Personal Data: ● Full name ● Address ● Mobile number ● Mobile number network history details ● Mobile account details ● Mobile risk score | Phone Verification Report Searches a range of mobile network operator databases (via a third party) to verify if a phone number provided by a User is active and reachable; and considers additional phone intelligence attributes to help the Customer to assess the fraud risk associated with the phone number. |

Qualifications & exceptions

• The searches are conducted through a third party.
• The report assists the Customer's fraud-risk assessment; it does not itself state the Customer's decision.

Not stated here

• The notice does not identify the third party or the mobile network databases used.

Linking & Identification · Context

Customer-Issued Entra Verified Credential integrates Microsoft Entra with Entrust verification

The Customer-Issued Entra Verified Credential row states that the Customer procures Microsoft's Entra Technology in its own environment and integrates it with Entrust's Identity Verification Services. The listed data is a photo, first and last name, email address, mobile number and date of birth. The notice does not describe the verification steps or outputs for this integration.

Supporting quotations

| Categories of Personal Data: • Photo • First and last name • Email address • Mobile number • Date of birth | Customer-Issued Entra Verified Credential Customer procures Microsoft’s Entra Technology in their environment and integrates with Entrust’s Identity Verification Services. |

Qualifications & exceptions

• The integration is configured in the Customer's environment; the Customer procures Microsoft Entra.

Not stated here

• The notice does not describe what Entrust verifies in this integration, how the credential is issued, or what data is returned to the Customer.

Use & Processing · Company practice

Some fraud checks depend on the selected Services; others apply across all Services

Entrust uses several fraud detection capabilities. Some depend on the scope of the Services the Customer selected, while other fraud checks are applied across all the Services. An example given is analyzing metadata associated with the User's Selfie and the image or video of their identity document to identify whether editing software can be detected, as part of assessing the likelihood that the User is genuine.

Supporting quotations

| Fraud checks, including device integrity and fraud signals Entrust leverages several different fraud detection capabilities. Some of these depend on the scope of the Services selected by the Customer, whereas other fraud checks are applied across all the Services.

(For example, Entrust will analyze the metadata associated with the User’s Selfie and the image or video of their identity document (to identify whether any editing software can be detected) to assess the likelihood that the User is genuine.)

Qualifications & exceptions

• The split between service-specific and all-service fraud checks varies by capability.
• The metadata analysis example assesses likelihood; it is not stated as conclusive proof of editing.

Not stated here

• The notice does not enumerate which fraud checks apply to every Service.

Inference & Profiling · Company practice

Device Intelligence assesses device, email and phone signals and can infer location and an identity risk score

Device Intelligence helps Customers determine whether a device, email address or phone number has previously been used in relation to suspected fraudulent activity, shows unusual usage patterns, has been manipulated or otherwise indicates the user may not be genuine. At a Customer's request, Entrust and its Data Providers may collect 'passive signals' from the Customer (such as a mobile number or email address) or from a User's device as the User engages with the Customer's website, app or services. The information may include device identifiers, IP address, device information such as operating system and whether the device provides false randomized device or network information or has otherwise been compromised, and how the User interacts with the Services or their device. Examples include upload time, software version, camera name and model, indicators of tampering or emulation, clipboard use and navigation between applications. Entrust and Data Providers may use this information to infer other information such as broad geographical location from the IP address, or to calculate an identity risk score, helping them assess the likelihood of the individual being a genuine User.

Supporting quotations

Device Intelligence. Entrust can help Customers to determine whether a device, email address or phone number has previously been used in relation to suspected fraudulent activity, shows unusual usage patterns, has been manipulated or otherwise indicates that the user may not be genuine. At a Customer’s request, Entrust and our Data Providers may collect ‘passive signals’ from the Customer (for example mobile number or email address) or a User’s device as they engage with the Customer’s website, app or services. Such information may include device identifiers, IP address, information about the device (for example the operating system used, whether the device is providing false randomized device and network information or has otherwise been compromised) and how the User interacts with:

• The Services. For example, information about the upload time, which version of our software was used, the camera name and model used to capture any images and whether there are any indicators that the device has been tampered with or emulated; and • Their device. For example, fraudsters will cut and paste large volumes of information from their clipboard, use this functionality multiple times and otherwise navigate between applications on their device very differently from a genuine User.

Entrust and our Data Providers may also use such information to infer other information about the User, for example their broad geographical location from their IP address, or to calculate an identity risk score.

an individual being a genuine User, assign a risk score and infer certain information such as a User’s broad geographical location from their IP address.

Qualifications & exceptions

• Collection occurs at a Customer's request.
• Passive signals may come from the Customer or from the User's device.
• The notice says Entrust and Data Providers 'may' use the information to infer location or calculate a risk score.
• The listed examples of interaction data are illustrative, not an exhaustive list.

Not stated here

• The notice does not specify the full set of risk-score inputs or how the score is used by a Customer.

Linking & Identification · Company practice

Repeat Attempts and Known Faces compare new checks with information previously verified for the same Customer

At a Customer's request, Entrust can check whether it has previously verified a User on behalf of that Customer by comparing information submitted as part of a new Document Check and/or Biometric Check with information previously verified for that Customer. More specifically, at the Customer's request Entrust will retain information extracted from a User's identity document or Selfie, which may include a scan of face geometry depending on the service chosen, and compare it with newly submitted information. The notice says this helps verify identities and protects against fraud by helping Customers understand when a User may be generating multiple identities, editing or tampering with documents, or manipulating device or network information. The maximum period a Customer may instruct Entrust to store and use face scans for these services is 365 days after the Company or User submitted the image/video used to generate the scan.

Supporting quotations

Repeat Attempts, Known Faces and Document Known Faces. At a Customer’s request, we can check whether we have previously verified a User on behalf of that Customer by comparing the information submitted as part of a new Document Check and/or Biometric Check, to information we have previously verified for that Customer.

More specifically, at a Customer’s request we will retain information (which may include a scan of a User’s face geometry depending on the service the Customer has chosen to use) extracted from a User’s identity document or Selfie, and compare this retained information to the newly submitted information.

This helps our Customer not only verify Users’ identities but further protects them and their Users from fraud by helping Customers understand when a User may be generating multiple identities, editing and tampering with documents or manipulating device or network information.

The maximum period of time for which a Customer may instruct Entrust to store and use face scans for the purpose of these services is three-hundred and sixty-five (365) days after the Company or the User submitted to Entrust the image / video used to generate the face scan.

Qualifications & exceptions

• The comparison is performed only at the Customer's request and only for that Customer's previously verified Users.
• Retained information may include face-geometry scans depending on the service the Customer chose.
• The 365-day maximum applies to Known Faces and Document Known Faces among the listed services.

Not stated here

• The notice does not describe how matches are reviewed or what a Customer does with a match result.

Use & Processing · Company practice

Authentication services store a face scan in an Encrypted Biometric Token held by Entrust and the Customer

For Authentication: Motion, Face Authentication and Biometric Passkey, a Customer may instruct Entrust to generate a scan of a User's face geometry from an image/video of the User or their identity document. Entrust embeds the scan in an Encrypted Biometric Token (EBT) stored by Entrust and by the Customer, either on the Customer's infrastructure or on the User's device. For authentication, the Customer may instruct Entrust to compare the scan in the EBT with a scan generated from a separate image or video; if the two match, the User is authenticated. Separately, Customers may associate the EBT with a passkey generated and managed in their own environment for passwordless authentication. The maximum period a Customer may instruct Entrust to store and use face scans for these services is 365 days after the Company or User submitted the image/video used to generate the scan.

Supporting quotations

Authentication: Motion, Face Authentication, and Biometric Passkey. A Customer may instruct Entrust to generate a scan of a User’s face geometry using an image / video of the User or their identity document. Entrust embeds the scan in an Encrypted Biometric Token (“EBT”) that is stored by Entrust and by the Customer (either on the Customer’s infrastructure or on the User’s device).

For Authentication, the Customer may instruct Entrust to compare the scan embedded in the EBT with a scan of the User’s face geometry generated from a separate image or video of the User. If the two scans match, the User is authenticated.

Separately, Customers may associate the EBT with a passkey generated and managed in their own environment to support passwordless authentication.

The maximum period of time for which a Customer may instruct Entrust to store and use face scans for the purpose of these services is three-hundred and sixty-five (365) days after the Company or the User submitted to Entrust the image / video used to generate the face scan.

Qualifications & exceptions

• Generation and comparison occur on Customer instruction.
• The EBT is stored by Entrust and by the Customer, on the Customer's infrastructure or the User's device.
• Passkeys are generated and managed in the Customer's own environment.
• The 365-day maximum applies to Authentication: Motion, Face Authentication and Biometric Passkey among the listed services.

Not stated here

• The notice does not describe the encryption or key-management details of the EBT.

Use & Processing · Company practice

Liveness Verification confirms physical presence through a passive facial capture without identity matching

Liveness Verification confirms a User's physical presence through a real-time passive facial capture, without performing identity matching. A Customer may instruct Entrust to generate a scan of the User's face geometry from an image or video of the User to assess whether the User is physically present. If the Customer requests it, the scan may be embedded in an Encrypted Biometric Token and stored by Entrust and/or the Customer, on the Customer's infrastructure or the User's device. The maximum period a Customer may instruct Entrust to store and use face scans for these services is 365 days after the Company or User submitted the image/video used to generate the scan.

Supporting quotations

Liveness Verification. Entrust can confirm a User’s physical presence through a real-time passive facial capture, without performing identity matching. A Customer may instruct Entrust to generate a scan of User’s face geometry using an image or video of the User for the purpose of assessing whether the User is physically present. If requested by the Customer, the scan may be embedded in an Encrypted Biometric Token (“EBT”) and stored by Entrust and/or the Customer (either on the Customer’s infrastructure or on the User’s device).

The maximum period of time for which a Customer may instruct Entrust to store and use face scans for the purpose of these services is three-hundred and sixty-five (365) days after the Company or the User submitted to Entrust the image / video used to generate the face scan.

Qualifications & exceptions

• Liveness Verification does not perform identity matching.
• The facial capture is real-time and passive.
• EBT storage occurs only if requested by the Customer.
• The 365-day maximum applies to Liveness Verification among the listed services.

Inference & Profiling · Company practice

Device Intelligence - Standard analyzes technical data, device signals, IP address and geolocation

Device Intelligence - Standard analyzes technical data, device signals, IP address, geolocation and other fraud signals to assess the likelihood that the User is genuine. The signals are collected through the SDK or standard tracking technologies such as JavaScript snippets from Users as they interact with the Services. The listed data is broad: a User unique identifier; document number and data from an associated document check; address and IP address type with city/region/country location; check status/outcome and tracking information; Device Intelligence inferences and outputs such as risk score and risk level; device fingerprint and identifiers including audio/video fingerprint, Android/Google Advertising ID and hardware-based identifiers such as MAC address; uploaded images/videos and their metadata/metatags; device hardware and software attributes; behavior during the Services including timing, forms, pointer/touch events, sensor data such as accelerometer and gyroscope; application authenticity such as use of stolen security tokens; and other fraud signals listed in the Onfido API Documentation.

Supporting quotations

| Categories of Personal Data: ● User unique identifier ● Document number and other data extracted from any associated document check ● address and IP address type, including associated city/region/country level location ● Check status/outcome and related tracking information ● Inferences and outputs from Device Intelligence e.g. risk score, risk level; ● Device Fingerprint, device identifiers including audio and video fingerprint, Android/Google Advertising ID (AAID or GAID), hardware-based identifiers (e.g. MAC address) ● Images and videos uploaded by User and any related metadata and metatags ● Information about Users' device including hardware and software attributes (e.g. device type and model, manufacturer, operating system type and version (e.g. iOS or Android), browser type and version, user-agent, navigator, screen details, plugins, fonts, memory, WebGL, battery information, language, time zone, camera name, microphone name, aspect ratio, resolution, frame rate, etc.) ● Information about an end user’s behavior when interacting with the Services, including how the end user uses the Services such as start/stop time, forms/fields completed, pointer and touch events, time zone offset, distraction events, sensor data like accelerometer and gyroscope Application Authenticity - Whether the device is using stolen security tokens ● Other fraud signals listed in the Onfido API Documentation.

Device Intelligence – Standard Analysis of technical data, device signals, IP address, geolocation, and other fraud signals (collected via the SDK or standard tracking technologies (e.g. JavaScript snippets) from Users as they interact with the Services) to assess the likelihood that the User is genuine.

Qualifications & exceptions

• Collection occurs as Users interact with the Services, via the SDK or standard tracking technologies such as JavaScript snippets.
• The listed device attributes are examples ('e.g.') and not an exhaustive list.
• Other fraud signals are defined in the Onfido API Documentation, which is not part of the saved source.

Not stated here

• The Onfido API Documentation listing other fraud signals is not supplied.

Linking & Identification · Company practice

Repeat Attempts stores document data and flags anomalous cross-matches with other Users' documents

Personal data extracted from a User's identity document during a Document Check is stored in the Repeat Attempts Database and compared with the same data points from other documents submitted by the Customer's new Users for detecting and preventing fraud. Abnormal or inconsistent matches are flagged as a possible indicator that the new User's document is not genuine. The listed data is a User unique identifier, image of the identity document, information extracted from the document, a document image hash number, and information about anomalous cross-matches with other documents.

Supporting quotations

| Categories of Personal Data: ● User unique identifier ● Image of the identity document ● Information extracted from the document ● Document image hash number ● Information about anomalous cross-matches with other documents | Repeat Attempts Personal Data extracted from the User’s identity document during a Document Check are stored in the Repeat Attempts Database and are compared to the same data points from other documents submitted by the Customer’s new Users for the purposes of detecting and preventing fraud. Abnormal/inconsistent matches will be flagged as a possible indicator that the document presented by the new User is not genuine. |

Qualifications & exceptions

• The comparison is with documents submitted by the Customer's new Users, not all Entrust customers.
• A flagged abnormal match is a 'possible indicator' that the document is not genuine, not a conclusive finding.

Not stated here

• The notice does not state how long Repeat Attempts data is retained.

Linking & Identification · Company practice

Known Faces compares a new biometric check with prior checks and adds the new face scan to the database

Known Faces compares the face on the image or video provided for a new Biometric Check with a database of faces supplied for previous Biometric Checks performed on the Customer's behalf, and alerts if there is a match. It then adds the face-geometry scan extracted from the newly provided image or video to that database. The listed data is a User unique identifier, image or video of the User's face, check status/outcome and related tracking information, and scans of face geometry. The maximum period a Customer may instruct Entrust to store and use face scans for these services is 365 days after the Company or User submitted the image/video used to generate the scan.

Supporting quotations

| Categories of Personal Data • User unique identifier • Image or video of the User’s face • Check status/outcome and related tracking information • Scans of face geometry | Known Faces (1) Compares the face on the image / video of the User provided for the purposes of a new Biometric Check against a database of faces supplied for previous Biometric Checks performed on the Customer’s behalf and alerts if there is a match, and (2) adds the scan of face g e o m e t r y e x t r a c t e d f r o m t h e n e w l y provided image/video to the database in (1). |

The maximum period of time for which a Customer may instruct Entrust to store and use face scans for the purpose of these services is three-hundred and sixty-five (365) days after the Company or the User submitted to Entrust the image / video used to generate the face scan.

Qualifications & exceptions

• The comparison database contains faces from previous Biometric Checks performed on the Customer's behalf.
• A match produces an alert; the notice does not state the Customer's resulting action.
• The 365-day maximum applies to Known Faces, Document Known Faces, Authentication: Motion, Face Authentication, Biometric Passkey and Liveness Verification.

Not stated here

• The notice does not describe how a match alert is reviewed or what decision the Customer makes.

Cross-references

• exception to (model-proposed): Extracted face scans are not kept after a check, except for fraud checks — Known Faces is one of the fraud-check services that operates as an exception to the general no-storage rule for extracted face scans: it adds the new scan to a comparison database and can retain it up to the stated maximum.

Linking & Identification · Company practice

Document Known Faces compares a new document check with prior document checks and adds the new scan

Document Known Faces compares the face on an image or video of the User's identity document provided for a new Document Check with a database of faces supplied for previous Document Checks performed on the Customer's behalf, and alerts if there is a match. It then adds the face-geometry scan extracted from the newly provided image or video to that database. The listed data is a User unique identifier, image of the identity document, check status/outcome and related tracking information, and scans of face geometry.

Supporting quotations

| Categories of Personal Data • User unique identifier • Image of the identity document • Check status/outcome and related tracking information • Scans of face geometry | Document Known Faces (1) Compares the face on an image / video of the User’s identity document provided for the purposes of a new Document Check against a database of faces supplied for previous Document Checks performed on the Customer’s behalf and alerts if there is a match, and (2) adds the scan of face geometry extracted from the newly provided image/video to the database in (1). |

Qualifications & exceptions

• The comparison database contains faces from previous Document Checks performed on the Customer's behalf.
• A match produces an alert; the notice does not state the Customer's resulting action.
• The 365-day face-scan storage maximum stated for these services applies.

Not stated here

• The notice does not describe how a match alert is reviewed or what decision the Customer makes.

Inference & Profiling · Company practice

Mastercard Identity combines submitted data with Mastercard Identity Network signals

Mastercard Identity looks for patterns in the submitted information combined with signals provided by the Mastercard Identity Network to determine if the applicant is valid or potentially fraudulent. The listed data is name, address, email address, phone number and IP address.

Supporting quotations

| Categories of Personal Data • Name • Address • Email address • Phone number • IP Address | Mastercard Identity Looks for patterns in the submitted information combined with signals provided by the Mastercard Identity Network to determine if the applicant is valid or potentially fraudulent. |

Qualifications & exceptions

• The assessment combines the submitted data with Mastercard Identity Network signals.
• The output describes the applicant as valid or potentially fraudulent; it does not state a final Customer decision.

Not stated here

• The notice does not describe the Mastercard Identity Network signals or how the pattern assessment is weighted.

Use & Processing · Company practice

Authentication: Motion and Face Authentication compare an EBT face scan with video and check liveness

Authentication: Motion and Face Authentication each use an image or video of the User or their identity document to generate a face-geometry scan embedded in an Encrypted Biometric Token. The service compares that face scan with a facial image captured from a video of the User to verify that they are the same, while also performing liveness detection. Both include optional processing of audio. Their listed data is video of the User including background audio at the Customer's option, the face image in the identity document or reference image, transcribed text from the video clip if applicable, scans of face geometry and data that may be considered a voiceprint. The notice describes the two rows with the same data and processing.

Supporting quotations

| Categories of Personal Data ● Video of the User (including background audio recording at Customer’s option) ● Image of the face in the identity document / reference image ● Transcribed text from the video clip (if applicable) ● Scans of face geometry ● Data that may be considered a voiceprint | Authentication: Motion Uses an image/video of the User / their identity document to generate a scan of face geometry which is embedded in an EBT and compares that face scan with a facial image captured from a video of the User, to verify that they are the same, while also performing liveness detection. Includes optional processing of audio. |

| Categories of Personal Data ● Video of the User (including background audio recording at Customer’s option) ● Image of the face in the identity document / reference image ● Transcribed text from the video clip (if applicable) ● Scans of face geometry ● Data that may be considered a voiceprint | Face Authentication Uses an image/video of the User / their identity document to generate a scan of face geometry which is embedded in an EBT and compares that face scan with a facial image captured from a video of the User, to verify that they are the same, while also performing liveness detection. Includes optional processing of audio. |

Qualifications & exceptions

• Audio processing is optional, with background audio recorded at the Customer's option.
• The notice describes Authentication: Motion and Face Authentication with identical data and processing text.
• The 365-day face-scan storage maximum stated for these services applies.

Not stated here

• The notice does not state how the EBT is protected or what happens when the comparison fails.

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.

Account & Service Control · Company practice

Biometric Passkey ties an EBT face scan to a passkey and compares it for routine access

Biometric Passkey uses passkey authentication with a scan of the User's face geometry generated during enrollment and embedded in an Encrypted Biometric Token, which is associated with the passkey. The passkey authenticates the User for routine access and, where required, compares the stored face scan with a facial image to verify the User's identity. The listed data is video of the User including optional background audio, the reference face image, transcribed text from the video if applicable, face-geometry scans, data that may be a voiceprint, and a User unique identifier.

Supporting quotations

| Categories of Personal Data ● Video of the User (including background audio recording at Customer’s option) ● Image of the face in the identity document / reference image ● Transcribed text from the video clip (if applicable) ● Scans of face geometry ● Data that may be considered a voiceprint ● User unique identifier | Biometric Passkey Uses passkey authentication with a scan of the User’s face geometry generated during enrollment and embedded in an EBT, which is associated with the passkey. The passkey is used to authenticate the User for routine access and, where required, compares the stored face scan with a facial image to verify the User’s identity. |

Qualifications & exceptions

• The face scan is generated during enrollment and embedded in an EBT associated with the passkey.
• Face comparison occurs only 'where required'; routine access uses the passkey.
• Background audio is optional and at the Customer's option.
• The 365-day face-scan storage maximum stated for these services applies.

Legal Rights & Agreement Rules · Company practice

Qualified Electronic Signature Package combines ETSI-certified identity verification with a qualified signature

The Qualified Electronic Signature (QES) Package provides ETSI-certified identity verification and issuance of a qualified electronic signature, as set out in the product guide. The listed data is full name, email address, telephone number, and information extracted from or describing the identity document.

Supporting quotations

| Other Services |

| Categories of Personal Data ● Full name ● Email address ● Telephone number; and ● information extracted from, or describing, the identity document | Qualified Electronic Signature (“QES”) Package ETSI certified identity verification and issuance of a qualified electronic signature, as set out in the product guide. |

Qualifications & exceptions

• The service is described as ETSI-certified and the details are set out in the product guide.

Not stated here

• The product guide is not part of the saved source, so the signature issuance process and any additional terms are not established here.

Account & Service Control · Procedure

One-Time Password verifies phone possession by sending a unique code to the User's number

One-Time Password (OTP) verifies that the User is in possession of the phone number by sending a unique code to the User's phone number for validation. The listed data is the telephone number and, where applicable, information related to the risk profile of the telephone number.

Supporting quotations

| Categories of Personal Data ● Telephone number; and ● Information related to the risk profile of a telephone number, where applicable | One-Time Password (“OTP”) Verifies that the User is in possession of the phone number by sending a unique code to the User’s phone number for validation. |

Qualifications & exceptions

• Telephone risk-profile information is included only where applicable.

Account & Service Control · Company practice

Passkey lets Users enroll and authenticate accounts with passkeys

The Passkey service provides capabilities for Users to enroll and authenticate their accounts with passkeys. The listed data is a User unique identifier.

Supporting quotations

| Categories of Personal Data • User unique identifier | Passkey Provides capabilities for Users to enroll and authenticate their accounts with Passkeys. |

Not stated here

• The notice does not describe the passkey protocol, storage location or recovery process for this service.

Legal Rights & Agreement Rules · Context

Identity Verification Services integrate with other Entrust offerings under their own privacy notices

Entrust Identity Verification Services integrate with other Entrust offerings, including Identity as a Service (IDaaS), Identity Verification as a Service (IDVaaS) and Workflow Signing Services. For privacy considerations for those offerings, the notice directs readers to the relevant Entrust Product Privacy Notice.

Supporting quotations

Entrust Identity Verification Services integrate with other Entrust offerings, including Identity as a Service (IDaaS), Identity Verification as a Service (IDVaaS) and Workflow Signing Services. For more information about privacy considerations for these offerings, review the relevant Entrust Product Privacy Notice.

Qualifications & exceptions

• The notice does not state the privacy terms of the other Entrust offerings; it cross-refers to their own product notices.

Not stated here

• The relevant Entrust Product Privacy Notices for IDaaS, IDVaaS and Workflow Signing Services are not part of the saved source.

Inference & Profiling · Context

AI Transparency Notice covers automated processing, model governance and human oversight

For additional information about automated processing, machine learning, artificial intelligence, model governance and human oversight within the Services, the notice refers readers to the Entrust Identity Verification Services AI Transparency Notice.

Supporting quotations

For additional information about the use of automated processing, machine learning, artificial intelligence, model governance, and human oversight within the Services, please refer to the Entrust Identity Verification Services AI Transparency Notice.

Qualifications & exceptions

• The notice cross-refers rather than reproducing the AI Transparency Notice's content.

Not stated here

• The AI Transparency Notice is not part of the saved source, so its governance and oversight details are not established here.

Sharing & Disclosure · Company practice

IAM integrations exchange limited user attributes and structured verification results

Customers may use the Services with an identity and access management platform such as Microsoft Entra or Okta to initiate identity verification as part of authentication or account-management workflows. In these integrations, the IAM platform may provide limited user attributes, such as name or other profile information, to Entrust to initiate verification, and may receive structured verification results, which may include verification outcomes and, where applicable and configured by the Customer, limited identity attributes, to support authentication and access decisions. Entrust processes personal data collected during identity verification primarily on the Customer's behalf, including in these integrations, and does not share identity documents, biometric data or underlying verification artifacts with the IAM platforms.

Supporting quotations

Integrations with Identity and Access Management Platforms

The following describes how personal data may be exchanged in integrations with third-party platforms configured by Customers.

The Services may be used in conjunction with a Customer’s identity and access management platform (such as Microsoft Entra or Okta) to initiate identity verification as part of authentication or account management workflows.

In these integrations, the identity and access management platform may provide limited user attributes (such as name or other profile information) to Entrust to initiate verification and may receive structured verification results (which may include verification outcomes and, where applicable and configured by the Customer, limited identity attributes) to support authentication and access decisions.

Entrust processes personal data collected during identity verification primarily on behalf of the Customer, including when integrated with such platforms in accordance with Customer configuration, and does not share identity documents, biometric data, or underlying verification artifacts with such platforms.

Qualifications & exceptions

• The exchange occurs in integrations configured by the Customer.
• The IAM platform provides only limited user attributes to initiate verification.
• Returned verification results may include limited identity attributes only where applicable and configured by the Customer.
• Identity documents, biometric data and underlying verification artifacts are excluded from what Entrust shares with IAM platforms.

Not stated here

• The notice does not enumerate every field included in 'structured verification results'; that depends on Customer configuration.

Cross-references

• qualifies (model-proposed): IAM platforms are independent controllers, not Entrust sub-processors; Customers must disclose their use — The limited data exchange with an IAM platform does not make the platform an Entrust sub-processor; the notice treats the platform as an independent controller within its own services.

Legal Rights & Agreement Rules · Company practice

IAM platforms are independent controllers, not Entrust sub-processors; Customers must disclose their use

The identity and access management platforms operate as independent controllers of personal data processed within their services and are not sub-processors of Entrust. Customers are responsible for configuring and disclosing their use of such platforms to their end users, including how personal data is processed in connection with authentication and access management.

Supporting quotations

These identity and access management platforms operate as independent controllers of personal data processed within their services and are not sub-processors of Entrust. Customers are responsible for configuring and disclosing their use of such platforms to their end users, including how personal data is processed in connection with authentication and access management.

Qualifications & exceptions

• The controller status applies to personal data processed within the IAM platform's own services.
• The Customer bears responsibility for configuration and disclosure to end users.

Cross-references

• qualified by (model-proposed): IAM integrations exchange limited user attributes and structured verification results — The limited data exchange with an IAM platform does not make the platform an Entrust sub-processor; the notice treats the platform as an independent controller within its own services.

Legal Rights & Agreement Rules · Context

Customers may have extra legal duties for biometric and sensitive-data Services

Where a Customer makes the listed Services available to a User, the Customer may be subject to additional obligations under applicable data protection laws, particularly where the Services involve biometric data or other sensitive personal data. These may include providing appropriate notices to Users, obtaining required consents, and complying with legal requirements for collection, use, storage and retention. In certain jurisdictions, including the United States, the Services involve data that may be considered biometric identifiers or biometric information, and additional requirements may apply; Customers are responsible for ensuring compliance.

Supporting quotations

Obligations for Biometric and Sensitive Data Processing

Where the Customer makes any of the following Services available to a User, the Customer may be subject to additional obligations under applicable data protection laws, particularly where those Services involve the processing of biometric data or other sensitive personal data.

These obligations may include providing appropriate notices to Users, obtaining any required consents, and complying with applicable legal requirements relating to the collection, use, storage, and retention of such data.

In certain jurisdictions (including the United States), these Services involve the processing of data that may be considered biometric identifiers or biometric information under applicable laws, and additional requirements may apply. Customers are responsible for ensuring compliance with such requirements.

Qualifications & exceptions

• The obligations fall on the Customer, not Entrust.
• The notice says the Customer 'may' be subject to additional obligations, depending on applicable law and the Services used.
• The notice says the data 'may be considered' biometric identifiers or information; it does not itself classify it under a specific law.

Not stated here

• The exact obligations vary by jurisdiction and are not enumerated in the notice.

Legal Rights & Agreement Rules · Context

Covered Services include Facial Similarity Checks, Known Faces, authentication, liveness and document checks

The Services to which the biometric and sensitive-data obligations apply include: Facial Similarity Check - Selfie, Selfie Auto, Video and Motion; Known Faces; Document Known Faces; Authentication: Motion, Face Authentication and Biometric Passkey; Liveness Verification; and Document Check, Document Check Video and Document Check Driver Verification.

Supporting quotations

These services include:

Facial Similarity Check – Selfie, Selfie Auto, Video, Motion

Known Faces

Document Known Faces

Authentication: Motion, Face Authentication, Biometric Passkey

Liveness Verification

Document Check, Document Check Video, Document Check Driver Verification

Qualifications & exceptions

• The list is introduced by 'These services include:' in the section on obligations for biometric and sensitive data processing.
• The list cross-refers to the obligations card; it does not itself state new obligations.

Inference & Profiling · Company practice

Each Report gives an overall result of Clear or Consider, with reasons for a Consider result

After Entrust verifies an identity or runs a check, it shares the results with the Customer in a Report. Each Report contains an overall result of 'Clear' or 'Consider'. Entrust notifies the Customer that checks are Clear if it was able to verify the User's identity and the requested checks do not show signs of fraud or other anomalies. It returns a Consider result if it was unable to verify the identity, the User was unable to pass all requested checks, or the checks show signs of fraud or other anomalies. A Consider result includes a detailed breakdown of the reasons, generated from the machine-learning models and/or human-powered processes used to verify an identity or perform a check.

Supporting quotations

Reports

Once Entrust has verified an identity or run a check, we share the results with the Customer in a report (“Report”). Each Report contains an overall result of ‘Clear’ or ‘Consider’:

If we’re able to verify the identity of a User, and the requested checks do not show signs of fraud or other anomalies, we notify the Customer that the checks are Clear.

If we’re unable to verify the identity of a User, or the User is unable to pass all requested checks or the checks show signs of fraud or other anomalies, we return a Consider result. If we return a Consider result, we will also provide a detailed breakdown of the reasons why. (The reasons are generated from the different machine learning models and/or human powered processes that are used to verify an identity or perform a check.)

Qualifications & exceptions

• Clear requires both successful identity verification and no signs of fraud or other anomalies in the requested checks.
• A Consider result can arise from inability to verify, failure to pass all checks, or signs of fraud or anomalies.
• The reasons for Consider may come from machine-learning models and/or human-powered processes.

Cross-references

• qualifies (model-proposed): Reports do not determine any outcome for a User; the Customer is solely responsible for acting on them — A Clear or Consider result is an assessment, not a decision about the User: the Customer remains solely responsible for how to act on the Report.

Legal Rights & Agreement Rules · Company commitment

Reports do not determine any outcome for a User; the Customer is solely responsible for acting on them

Reports reflect the outcome of the checks performed and provide an assessment, including an overall result of Clear or Consider and supporting reasons. They are provided for the Customer's use and do not, on their own, determine any outcome relating to a User. The Customer is solely responsible for determining how to act on the information, including making any decisions regarding the User.

Supporting quotations

Reports reflect the outcome of the checks performed and provide an assessment, including an overall result of ‘Clear’ or ‘Consider’ and supporting reasons. Reports are provided for the Customer’s use and do not, on their own, determine any outcome relating to a User. The Customer is solely responsible for determining how to act on the information provided, including making any decisions regarding the User.

Qualifications & exceptions

• The Report is an assessment and does not itself decide any outcome for the User.
• The Customer bears sole responsibility for decisions made from the Report.

Cross-references

• qualified by (model-proposed): Each Report gives an overall result of Clear or Consider, with reasons for a Consider result — A Clear or Consider result is an assessment, not a decision about the User: the Customer remains solely responsible for how to act on the Report.

Use & Processing · Context

Reports aim to help Customers make informed decisions and help Users who have difficulty passing a check

Entrust says that by providing detailed Reports, it aims to empower Customers to make informed decisions about their Users and to provide help to Users who are having difficulty passing a check.

Supporting quotations

By providing our customers with these detailed Reports, our aim is to empower our Customers to make informed decisions about their Users and to provide help to Users that are having difficulty in passing a check.

Qualifications & exceptions

• This is a statement of aim, not an obligation to achieve a particular outcome for a User.

Inference & Profiling · Company practice

Automated processing may support or make verification determinations; Customers decide how outputs are used

The Services incorporate automated processing technologies, including machine-learning models, rules-based systems and other analytical tools, to assess identity information, detect fraud and generate verification outcomes. These technologies may be used to support or, in certain cases, make verification determinations as part of the verification process. The outputs, including Reports and related indicators, are provided to Customers. Customers determine how verification outcomes, Reports and related indicators are used within their own onboarding, authentication, fraud-prevention, compliance, account-access or other business processes.

Supporting quotations

Automated Processing and Verification Outcomes

The Services incorporate automated processing technologies, including machine learning models, rules-based systems, and other analytical tools, to assess identity information, detect fraud, and generate verification outcomes. These technologies may be used to support or, in certain cases, make verification determinations as part of the verification process. The outputs of these processes, including Reports and related indicators, are provided to Customers. Customers determine how verification outcomes, Reports, and related indicators are used within their own onboarding, authentication, fraud prevention, compliance, account access, or other business processes.

Qualifications & exceptions

• Automated technologies 'may' support determinations and, 'in certain cases', may make them.
• The Customer decides how verification outcomes, Reports and related indicators are used in its own processes.
• The listed Customer processes are examples, not an exhaustive list.

Not stated here

• The notice does not specify which verification determinations are made solely by automated processing and which require human involvement.
• The linked AI Transparency Notice is not part of the saved source.

Legal Rights & Agreement Rules · Company practice

Entrust acts as controller for this processing; EEA and UK Users get a legal basis for each purpose

The notice distinguishes Entrust's processor role when providing the Services to Customers from its controller role when processing personal data on its own behalf for the purposes in this section. If a User is in the European Economic Area or United Kingdom, Entrust says it will only use the User's personal data for a particular purpose where it has a legal basis, and it sets out those legal bases for each purpose. Onfido Ltd is the Controller for this processing, and the Contact Information section explains how to contact it.

Supporting quotations

Using Personal Data as Controller

As explained above, when we use personal data to provide the Services to our Customers, we are acting on their behalf as their service provider and processor. However, we also process the personal data of Users, and others, on our own behalf (as a “Controller”) for the purposes described in this section.

If a User is in the European Economic Area or United Kingdom, we will only use your personal data for a particular purpose where we have a “legal basis” for this. We have set out below the legal bases we rely upon for each purpose. Onfido Ltd is the Controller for this processing.

Qualifications & exceptions

• The legal-basis limitation is stated for Users in the European Economic Area or United Kingdom.
• Onfido Ltd is named as the controller for this processing.

Cross-references

• refers to (model-proposed): Entrust is controller for controller-side processing; rights depend on residence and applicable law — The rights section applies to the controller-side processing described earlier and states that availability depends on residence and applicable privacy law.

Use & Processing · Company practice

Entrust uses Service data to improve and develop the Services unless applicable law prohibits it

Provided it is not prohibited by applicable law, Entrust uses personal data it collects about Customers' Users to improve and develop the Services. For the same purpose, it may also use personal information that has been made publicly available or obtained from a third party, again provided this is not prohibited by applicable law.

Supporting quotations

To develop and improve the Services (including machine learning technologies)

At Entrust, our vision is to simplify digital identity. Provided it is not prohibited by applicable law, we use personal data we collect about our Customers’ Users (as described above) to improve and develop the Services. For the same purpose, we may also use personal information that has been made publicly available or that we have obtained from a third party provided this is not prohibited by applicable law.

Qualifications & exceptions

• Both uses are conditioned on not being prohibited by applicable law.
• Publicly available or third-party information may be used for the same improvement purpose.

Cross-references

• defines (model-proposed): Development includes training ML models and human analysts and re-running checks for quality — The development-activities card defines what improving and developing the Services includes: technology and model building, analyst training, and quality re-runs.

Inference & Profiling · Company practice

Development includes training ML models and human analysts and re-running checks for quality

Developing and improving the Services includes building and improving Entrust's technology, such as machine-learning technologies and algorithms, and developing and testing new checks, products and services to better verify identity and/or detect fraud. Examples include training models to recognize a novel fraud attack or a new version of an identity document, or to minimize bias and improve performance. Entrust trains its technology to recognize patterns and make predictions about new information (machine learning), and also trains human analysts to perform those tasks when models are not best suited or are still learning. It may re-run and re-submit checks to ensure the Services work properly, particularly when testing a new feature or service for quality checks.

Supporting quotations

Developing and improving the Services includes building and improving our technology (such as our machine learning technologies and algorithms) and developing and testing new checks, products and services to better verify a User’s identity and/or detect fraud. For example, we may need to train our models to recognize a novel fraud attack, a new version of an ID document or to minimize bias and improve performance. As part of this work, we train our technology to recognize specific patterns in information and make predictions about new sets of information based on those patterns. This is known as machine learning. We also train our human analysts to perform those tasks so they can assist when our machine learning models aren’t best suited for the task or are still learning. Sometimes, we’ll also re-run and re-submit checks to ensure the Services are working properly, particularly when testing a new feature or service for quality checks.

Qualifications & exceptions

• The examples are illustrative of development work, not an exhaustive list.
• Re-running and re-submitting checks is described as sometimes occurring, particularly for testing and quality checks.

Not stated here

• The notice does not state which User data is excluded from model training or how training data is selected.

Cross-references

• defined by (model-proposed): Entrust uses Service data to improve and develop the Services unless applicable law prohibits it — The development-activities card defines what improving and developing the Services includes: technology and model building, analyst training, and quality re-runs.

Legal Rights & Agreement Rules · Context

Development processing relies on legitimate interests in tackling fraud

Entrust processes personal data for the development purposes on the basis that it is necessary for the legitimate interests of its Customers and Entrust. It describes financial crime, fraud and corruption as serious issues affecting law enforcement, financial institutions, the private sector, major corporations and individuals, and considers there is a clear legitimate interest in improving and developing the Services to continue effectively tackling and reducing fraud.

Supporting quotations

We process personal data for these purposes on the basis that it is necessary for the legitimate interest of our Customers and Entrust. Financial crime, fraud, and corruption are serious issues that affect not only the law enforcement community but financial institutions, the private sector, and other major corporations – as well as individuals themselves. As such, Entrust considers there is a clear legitimate interest in improving and developing the Services for the purpose of continuing to effectively tackle and reduce fraud.

Qualifications & exceptions

• This is Entrust's stated basis for the development purpose, not a determination that the basis is legally sufficient.

Cross-references

• qualified by (model-proposed): Sensitive data for development is processed mainly on a substantial-public-interest basis, with safeguards — Sensitive personal data used for development is primarily processed on a substantial-public-interest basis, qualifying the general legitimate-interest basis described for development.

Legal Rights & Agreement Rules · Company practice

Sensitive data for development is processed mainly on a substantial-public-interest basis, with safeguards

Where Entrust uses sensitive personal data for the development purposes, such as information that could potentially reveal racial or ethnic origin, it primarily processes the information on the basis that it is necessary for reasons of substantial public interest. The stated public interests include ensuring equality of treatment across all types of Users by measuring and mitigating algorithmic bias, to provide fair and inclusive Services that effectively detect fraud, balanced against Users' rights and freedoms. Entrust says it implements specific safeguards when developing the Services, including pseudonymization where possible, impact assessments and strict security controls.

Supporting quotations

Where we use sensitive personal data for these purposes (for example, information which could potentially reveal information about someone’s racial or ethnic origin), we primarily process this information on the basis that it is necessary for reasons of substantial public interest. Such public interests include ensuring equality of treatment across all types of Users by measuring and mitigating algorithmic bias with a view to providing fair and inclusive Services, which effectively detect fraud, and are balanced against the rights and freedoms of Users. When developing the Services, we implement specific measures to safeguard the rights and freedoms of those individuals whose data is used for this purpose, including pseudonymization (where possible), impact assessments and strict security controls to safeguard their fundamental rights and their interests.

Qualifications & exceptions

• Sensitive data is processed 'primarily' on this basis, leaving room for other bases not described here.
• The examples of sensitive data are illustrative ('for example').
• Safeguards include pseudonymization where possible, impact assessments and strict security controls.

Cross-references

• qualifies (model-proposed): Development processing relies on legitimate interests in tackling fraud — Sensitive personal data used for development is primarily processed on a substantial-public-interest basis, qualifying the general legitimate-interest basis described for development.

Inference & Profiling · Company practice

Entrust creates statistics and benchmarking from check results, document type and device metadata

Entrust uses personal data such as check results, identity document type and device metadata to create statistics about the use and performance of the Services. It provides these statistics to Customers so that they and Entrust may use them for benchmarking and analytics, for example comparing a Customer's missed fraud rates with an industry's general missed fraud rate or analyzing fraud trends. Entrust also uses the statistics for market insights and to inform product-improvement decisions. It says an individual cannot be identified from these statistics, and where possible it pseudonymizes, aggregates and/or de-identifies the personal information, and where feasible anonymizes it.

Supporting quotations

To compile statistics, benchmarking and analytics

We use personal data (such as check results, identity document type, and device metadata) to create statistics regarding the use and performance of the Services. We provide these statistics to our Customers so that they and we may use them to, for example, conduct benchmarking and analytics (for example, to compare a Customer’s missed fraud rates to the general missed fraud rate for an industry, or to analyze fraud trends). We also use these statistics to gain market insights (for example, to enhance understanding of missed fraud trends and identify fraud patterns) and to inform our decision making on product improvements. An individual cannot be identified from these statistics and where possible, we pseudonymize, aggregate and/or de-identify (and where feasible anonymize) personal information which is used for these purposes.

Qualifications & exceptions

• The listed data (check results, document type, device metadata) is illustrative.
• Anonymization is described as 'where feasible'; pseudonymization, aggregation and de-identification are described as 'where possible'.
• The statistics are provided to Customers as well as used internally.

Not stated here

• The notice does not describe the de-identification or anonymization standards applied.

Legal Rights & Agreement Rules · Context

Statistics processing relies on legitimate interests in understanding aggregate Service use

Entrust processes personal data for the statistics purposes on the basis that it is necessary for Entrust's and its Customer's legitimate interests in understanding, at the aggregate level, how people are using its Identity Services.

Supporting quotations

We process personal data for these purposes on the basis that it is necessary for Entrust’s and our Customer’s legitimate interests in understanding (at the aggregate level) how people are using our Identity Services.

Qualifications & exceptions

• The stated interest is understanding use at the aggregate level.

Legal Rights & Agreement Rules · Company practice

Entrust processes data where needed for legal obligations, legal rights or vital interests

Entrust may process personal data about Customers' Users where necessary for compliance with a legal obligation, to exercise, establish or defend legal rights or claims, or to protect someone's vital interests. For example, it may be required by law to disclose information in response to a request from a government or law enforcement body, as described in the Government and Law Enforcement Requests section.

Supporting quotations

For compliance with applicable law/regulation, to exercise, establish or defend legal rights or claims, or to protect someone’s vital interests

Entrust may process the personal data we collect about our Customers’ Users (as described above) where this is necessary for compliance with a legal obligation, to exercise, establish or defend legal rights or claims, or to protect someone’s vital interests. For example, we may be required by law to:

disclose information in response to a request from a government or law enforcement body as described in the section below headed “Government and Law Enforcement Requests”;

Qualifications & exceptions

• The disclosure example is one illustration of processing under this purpose.
• Government and law enforcement requests are addressed in a separate section of the notice.

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.

Legal Rights & Agreement Rules · Company practice

Entrust may process User data for business transactions and professional advice under legitimate interests

Entrust may need to process a User's personal data in connection with an actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization or any other similar transaction or proceeding, or to obtain professional advice. It states that it processes personal data for these purposes on the basis that it is necessary for Entrust's legitimate interest in running its business in a commercial and compliant manner.

Supporting quotations

In connection with a business transaction or obtaining professional advice

Entrust may need to process a User’s personal data in connection with an actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, or to obtain professional advice. We process personal data for these purposes on the basis that it is necessary for Entrust’s legitimate interest in running its business in a commercial and compliant manner.

Qualifications & exceptions

• The transactions listed are examples of similar proceedings.
• The stated basis is Entrust's legitimate interest in running its business commercially and compliantly.

Retention & Deletion · Company practice

The Customer sets processor-side retention, subject to legal or Entrust/Data Provider minimums and maximums

Where Entrust processes a User's personal data on the Customer's behalf to provide the Services, the Customer determines how long Entrust retains that data. This is subject to minimum or maximum retention periods imposed by applicable law or defined by Entrust or Data Providers. The notice links to further details that are not part of the saved source.

Supporting quotations

Retention Period

Where Entrust processes the personal data of a User on the Customer’s behalf to provide the Services, the Customer determines how long Entrust retains that personal data (subject to any minimum / maximum retention periods imposed by applicable law or defined by Entrust or Data Providers). See here for more details.

Qualifications & exceptions

• Customer control over retention is subject to legal, Entrust and Data Provider minimums and maximums.
• The linked further details are not supplied in the saved source.

Not stated here

• The linked retention details are not part of the saved source, so the specific periods are not established here.

Cross-references

• contrast (model-proposed): Controller-side data is kept as long as necessary for the purpose, subject to legal maximums — Retention differs by role: the Customer sets processor-side retention subject to minimums and maximums, while Entrust keeps controller-side data as long as necessary for its purpose, subject to legal maximums.

Retention & Deletion · Company commitment

Controller-side data is kept as long as necessary for the purpose, subject to legal maximums

Where Entrust processes personal data as controller, it retains the data for as long as is necessary to complete the purpose for which the information is processed, subject to any maximum retention periods imposed by applicable law.

Supporting quotations

Where Entrust processes personal data as Controller, Entrust retains that data for as long as is necessary to complete the purpose for which the information is processed, subject to any maximum retention periods imposed by applicable law.

Qualifications & exceptions

• The retention period is purpose-based (as long as necessary to complete the purpose).
• Applicable law may impose a maximum retention period.

Cross-references

• contrast (model-proposed): The Customer sets processor-side retention, subject to legal or Entrust/Data Provider minimums and maximums — Retention differs by role: the Customer sets processor-side retention subject to minimums and maximums, while Entrust keeps controller-side data as long as necessary for its purpose, subject to legal maximums.

Sharing & Disclosure · Company practice

Entrust shares data with service providers, group companies, transaction parties, advisers, authorities and others

In addition to sharing with Customers and Data Providers, Entrust shares personal data with: third parties who help provide the Services and perform tasks on its behalf, including IT and infrastructure providers, data analytics providers and business process outsourcing partners whose staff perform human review and quality checks; companies in the Entrust group that help provide services, such as ancillary engineering, technical or customer support; an actual or potential buyer, investor or partner and its agents and advisers in relation to a business transaction; parties providing professional advice and services such as advisory and auditing; a competent law enforcement body, regulatory, government agency or court; and any other person where Entrust has a legitimate legal reason. The notice links to a current sub-processor list that is not part of the saved source.

Supporting quotations

Data Sharing and Use of Sub-Processors

In addition to sharing personal data with Customers and Data Providers (as described above), Entrust also shares personal data:

With third parties who help us provide the Services and perform tasks on our behalf. This includes information technology and related infrastructure providers (who provide us with a place to store your personal information); data analytics providers (who help us to analyze trends and provide market insights); and our business process outsourcing partners (whose staff perform human review and quality checks). For the current list of third-party service providers (“sub-processors”) who process User personal data to provide the Services, visit https://www.entrust.com/legal-compliance/data-privacy/sub-processors.

With companies in the Entrust group of companies who help us to provide our services (for example, by providing ancillary engineering, technical or customer support);

With an actual or potential buyer, investor or partner (and its agents and advisers) in relation to a business transaction;

With parties that provide Entrust with professional (e.g. advisory and auditing) advice and services;

With a competent law enforcement body, regulatory, government agency, or court;

To any other person where we have a legitimate legal reason for doing so.

Qualifications & exceptions

• The third-party recipient list is illustrative of the categories described.
• The current sub-processor list is provided by link and is not part of the saved source.
• Entrust group companies are a separate recipient category from third-party sub-processors.

Not stated here

• The linked sub-processor list is not part of the saved source, so the current recipients and their locations are not established here.

Cross-references

• qualifies (model-proposed): Entrust shares identity documents on Customer instruction, including with UK police for the Amberhill Database — Customer-instructed sharing is a specific recipient route within the general sharing categories: Entrust may share with any person a Customer instructs, including compromised identity documents with the UK Metropolitan Police for the Amberhill Database.

Sharing & Disclosure · Company practice

Entrust shares identity documents on Customer instruction, including with UK police for the Amberhill Database

Entrust shares personal data with any other person where a Customer instructs it to do so. For example, if a Customer has configured the Services to check whether an identity document has been previously identified as lost, stolen, fraudulent or otherwise compromised by a government or other external party, Entrust may share that compromised identity document on the Customer's behalf, and the government or other external party may retain a copy to the extent it considers necessary, proportionate and lawful. Under Customer instruction and as permitted by applicable law, Entrust currently shares identity documents with the UK Metropolitan Police as part of the Amberhill Database for these purposes.

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With any other person where instructed to do so by a Customer. For example, if a Customer has configured the Services to check whether an identity document has been previously identified as lost, stolen, fraudulent, or otherwise compromised by a government or other external party, Entrust may share that compromised identity document on behalf of that Customer, and the government or other external party may retain a copy to the extent they consider it necessary, proportionate, and lawful. Under the instruction of Customers and as permitted by applicable law, Entrust currently shares identity documents with the UK Metropolitan Police as part of the Amberhill Database for such purposes; and

Qualifications & exceptions

• The sharing requires Customer instruction.
• The external party's retention is described as to the extent it considers necessary, proportionate and lawful.
• The Amberhill Database sharing is current and subject to applicable law.

Not stated here

• The notice does not describe the full data set shared with the Amberhill Database or every participating external party.

Cross-references

• qualified by (model-proposed): Entrust shares data with service providers, group companies, transaction parties, advisers, authorities and others — Customer-instructed sharing is a specific recipient route within the general sharing categories: Entrust may share with any person a Customer instructs, including compromised identity documents with the UK Metropolitan Police for the Amberhill Database.

Security & Safeguards · Company commitment

Entrust seeks contractual safeguards on shared data where legally possible, with a government-disclosure exception

Whenever legally possible, Entrust seeks to protect the personal information it shares by imposing contractual privacy and security safeguards on the recipient. In some cases this is not possible, for example when Entrust has a legal obligation to disclose information to a government authority and that authority is not willing to enter into such contractual safeguards.

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Whenever legally possible, we seek to protect the personal information we share by imposing contractual privacy and security safeguards on the recipient of that information. In some cases, however, it’s not possible for us to do so — for example, when we have a legal obligation to disclose information to a government authority and that government authority is not willing to enter into such contractual safeguards.

Qualifications & exceptions

• The safeguard commitment applies only 'whenever legally possible'.
• The government-authority example is not the only possible exception ('for example').

Legal Rights & Agreement Rules · Company practice

Cross-border transfers outside the EEA use Standard Contractual Clauses or another safeguard

The sharing of personal data may involve cross-border transfers. Entrust says it makes cross-border transfers in accordance with relevant data privacy law requirements. For example, it ensures that personal data transferred outside the EEA benefits from an adequate level of protection by requiring sub-processors to enter into European Commission-approved Standard Contractual Clauses, and/or their UK and Switzerland equivalents, if they are not in a country with an adequacy decision and there is no alternative transfer safeguard.

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International Data Transfers

The sharing of personal data may involve the cross-border transfer of personal data. Entrust makes cross-border transfers of personal data in accordance with relevant data privacy law requirements. For example, we ensure that personal data that is transferred outside of the EEA benefits from an adequate level of protection by requiring sub-processors to enter into the European Commission approved Standard Contractual Clauses (and/or their UK and Switzerland equivalents) if they are not in a country that has the benefit of an adequacy decision and if there is no alternative transfer safeguard.

Qualifications & exceptions

• Standard Contractual Clauses are required only if the destination lacks an adequacy decision and there is no alternative transfer safeguard.
• The UK and Switzerland equivalents may be used alongside the EU clauses.

Security & Safeguards · Company commitment

Entrust uses pseudonymization and administrative, physical, technical and organizational security measures

Where possible, Entrust pseudonymizes, de-identifies and/or aggregates personal data to protect privacy and minimize security risks. It explains pseudonymized data as information replaced, transformed or removed so that it no longer identifies an individual without additional information. Entrust also takes administrative, physical, technical and organizational measures designed to help protect the information it holds from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. The notice links to an information-security page that is not part of the saved source.

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Security Measures

Where possible, we pseudonymize, de-identify and/or aggregate personal data to protect privacy and minimize security risks. Pseudonymized data is where we replace, transform, or remove information so that it no longer identifies an individual without additional information. Entrust also takes appropriate administrative, physical, technical and organizational measures designed to help protect the information it holds from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For more information about information security in relation to the Services, please visit https://www.entrust.com/legal-compliance/security.

Qualifications & exceptions

• Pseudonymization, de-identification and aggregation occur 'where possible'.
• The security measures are described as designed to help protect the information, not as a guarantee.

Not stated here

• The linked information-security page is not part of the saved source, so further technical details are not established here.

Legal Rights & Agreement Rules · Procedure

Users must contact the Customer for processor-side privacy requests; Entrust assists the Customer

The Customer is the controller for all personal data Entrust processes to provide the Services. A User of an Entrust Customer who wishes to exercise data privacy rights over that processor-side processing should contact the Customer so it can respond directly. If the User contacts Entrust instead, Entrust will notify the Customer so the Customer can address the request. Entrust, as processor/service provider, will assist the Customer to the extent reasonable and practicable in responding to data subject requests the Customer receives about the Services.

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Data Privacy Rights

The Customer is the controller for all personal data processed by Entrust for the purpose of providing the Services. If you are a User of an Entrust Customer and you wish to exercise your data privacy rights in relation to how we use your personal data as described in the section of this notice headed “The Personal Data We Process on Behalf of Our Customers”, please contact the Customer so they may respond to you directly. If you contact us instead of our Customer, we will notify the Customer so they are able to address your request. Entrust, as the processor/service provider, will assist the Customer, to the extent reasonable and practicable, in responding to data subject requests the Customer receives with respect to the Services.

Qualifications & exceptions

• This route applies to personal data Entrust processes to provide the Services on the Customer's behalf.
• Entrust's assistance to the Customer is limited to the extent reasonable and practicable.

Legal Rights & Agreement Rules · Context

Entrust is controller for controller-side processing; rights depend on residence and applicable law

Entrust is the controller for the processing described in the 'Using Personal Data as Controller' section. Depending on where the individual lives and subject to applicable privacy law, the individual may have the rights listed in the following items in respect of that processing.

Supporting quotations

Entrust is the controller for the processing of personal data described under the section of this notice headed “Using Personal Data as Controller.” Depending on where you live and subject to applicable privacy law, you may have the following rights in respect of this processing:

Qualifications & exceptions

• The rights apply to controller-side processing, not to data Entrust processes as the Customer's processor.
• Availability depends on where the individual lives and on applicable privacy law.

Cross-references

• referred to by (model-proposed): Entrust acts as controller for this processing; EEA and UK Users get a legal basis for each purpose — The rights section applies to the controller-side processing described earlier and states that availability depends on residence and applicable privacy law.

Legal Rights & Agreement Rules · User right or choice

Controller-side rights include access, correction, suppression, objection and deletion

For controller-side processing, the listed rights include the right to request access to and disclosure of personal data; the right to change or correct personal data if inaccurate; the right to block or suppress processing, enabling a request that Entrust suspend processing in certain circumstances; the right to object to processing based on a legitimate interest (of Entrust or a third party) where the individual feels it impacts their fundamental rights and freedoms; and the right to request deletion of personal data, subject to certain exceptions. Entrust notes it may demonstrate compelling legitimate grounds that override the objection rights and freedoms.

Supporting quotations

the right to request access to and disclosure of your personal data.

the right to change and/or correct your personal data if it is inaccurate.

the right to block or suppress our processing of your personal data. (This enables you to request that Entrust suspends the processing of your data in certain circumstances.)

the right to object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you feel such processing impacts on your fundamental rights and freedoms. (In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.)

the right to request that we delete your personal data, subject to certain exceptions.

Qualifications & exceptions

• The suppression right operates 'in certain circumstances'.
• The objection right is qualified by Entrust's possible showing of compelling legitimate grounds that override it.
• The deletion right is 'subject to certain exceptions'.

Legal Rights & Agreement Rules · User right or choice

Controller-side rights also include portability, consent withdrawal and regulator complaints

The listed rights also include the right to request portability of personal data, with Entrust providing the individual or a chosen third party the data in a structured, commonly used, machine-readable format; the right to withdraw consent where applicable, without affecting the lawfulness of processing before withdrawal or processing conducted on other lawful grounds; and the right to lodge a complaint with the local data protection authority or regulator.

Supporting quotations

the right to request portability of your personal data. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format.

the right to withdraw your consent, if applicable. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

the right to lodge a complaint with your local data protection authority or regulator.

Qualifications & exceptions

• Portability is provided in a structured, commonly used, machine-readable format.
• Consent withdrawal does not affect prior lawful processing or processing based on other lawful grounds.
• The consent right applies only 'if applicable'.

Legal Rights & Agreement Rules · Procedure

Controller-side rights are exercised by email or post, without discrimination

To exercise rights over controller-side processing, the notice directs individuals to identity-privacyrequests@entrust.com or the postal address below. It states that if an individual exercises any of the data protection rights detailed in the section, Entrust will not discriminate against them.

Supporting quotations

If you wish to exercise your rights in relation to how we use your personal information as described under the section headed “Using Personal Data As Controller”, please contact us at identity-privacyrequests@entrust.com or at the postal address below. If you exercise any of your data protection rights detailed in this section, we will not discriminate against you.

Qualifications & exceptions

• The contact route applies to the controller-side processing described in the section.

Legal Rights & Agreement Rules · Procedure

Government and law enforcement requests go to the Customer unless a legal requirement compels disclosure

A government or law enforcement body seeking personal data or confidential information about a check on a particular User should contact the Customer on whose behalf the check was carried out. Because Entrust provides the Services on behalf of Customers, it says it cannot disclose information related to a specific check unless the relevant Customer directs it to, or Entrust is subject to a legal requirement such as a court order or statutory power mandating disclosure. A body that has such a legal requirement should contact identity-privacyrequests@entrust.com with clear details of the legal requirement in its message.

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Government and Law Enforcement Requests

If you are a government or law enforcement body that wishes to request personal data or confidential information related to a check that we may have conducted on a particular User, please contact the Customer on whose behalf the check was carried out. Since we provide our Services on behalf of our Customers, we are not able to disclose any information related to a specific check unless the relevant Customer directs us to do so, or we are subject to a legal requirement (such as a court order or statutory power mandating disclosure) to do so. If you wish to request the disclosure of information in respect of which there is such a legal requirement, please contact us at identity-privacyrequests@entrust.com providing clear details of the legal requirement in your message. providing clear details of the legal requirement in your message.

Qualifications & exceptions

• The general route is to the Customer, not Entrust.
• Disclosure without Customer direction requires a legal requirement such as a court order or statutory power.
• The saved text repeats the closing phrase 'providing clear details of the legal requirement in your message.' twice.

Legal Rights & Agreement Rules · Company practice

Entrust may update the notice; material changes are communicated and the last-updated date shows effect

Entrust may update this Product Privacy Notice from time to time to reflect changes in its processing practices, applicable laws or operational requirements. Where it makes material changes, it will take reasonable steps to inform affected individuals, which may include notice through the product, by email or by other appropriate means. The updated notice will be available at https://www.entrust.com/legal-compliance/product-privacy, and the 'last updated' date will indicate when the changes became effective.

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Amendments to this Privacy Notice

We may update this Product Privacy Notice from time to time to reflect changes in our processing practices, applicable laws, or operational requirements.

Where we make material changes to this notice, we will take reasonable steps to inform affected individuals, which may include providing notice through the product, by email, or by other appropriate means.

The updated notice will be made available at https://www.entrust.com/legal-compliance/product-privacy, and the

“last updated” date will indicate when the changes became effective.

Qualifications & exceptions

• Updates may occur from time to time, not on a fixed schedule.
• Notice of material changes may be through the product, email or other appropriate means.
• The notice does not state an advance-notice period.

Not stated here

• The notice does not state how far in advance material changes take effect or whether continued use signifies acceptance.

Legal Rights & Agreement Rules · Procedure

Privacy questions go to Onfido Limited in London; the DPO is contactable through Mishcon de Reya

Questions about the notice go to Onfido Limited at identity-privacyrequests@entrust.com or Attention: Privacy Office, 9 Devonshire Square, 4th Floor, London, United Kingdom, EC2M 4YF. To raise a concern or communicate with the Data Protection Officer, the notice gives DPO@mishcon.com, Attention: Entrust DPO, Mishcon de Reya LLP, Africa House, 70 Kingsway, London, WC2B 6AH, United Kingdom.

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Contact Information

If you would have any questions about this notice, please contact Onfido Limited at identity-privacyrequests@entrust.com or at: Attention: Privacy Office, 9 Devonshire Square, 4th Floor, London, United Kingdom, EC2M 4YF.

If you would like to raise a concern or otherwise communicate with our Data Protection Officer, you may contact them at DPO@mishcon.com Attention: Entrust DPO, Mishcon de Reya LLP, Africa House, 70 Kingsway, London, WC2B 6AH, United Kingdom

Qualifications & exceptions

• The notice names Onfido Limited as the contact for privacy questions.
• The Data Protection Officer is contacted through Mishcon de Reya LLP at the stated address.