Privacy Policy

TrustVision eKYC/FA App Privacy Policies

8 April 2020

Privacy practices specific to Service Data

a. Overview

Our facial recognition service (the “Service”) allows our clients (“End Users”) to check image quality, liveness of customer, and to match face images to assist in their KYC process. Clients use our Service at a point of sale to onboard clients in highly regulated industries such as banking, financial services or telecommunications. They use the app to match customer faces between selfies and ID cards, check liveness of the customer and extract details from ID cards through OCR. We require Partners to use the following approach when deploying the Service:

• It requires the client customer’s explicit consent
• To use our Service, the End User takes a photo of their customer
• The Partner does not provide us with the individual’s name, contact information, username, etc. as part of this process
• We scan the photo to create a vectorized customer image (Face Index), which is a unique collection of measurements of the face in the photo. This is used to compare against faces in a different photo or video
• If the photo quality is insufficient, the Service offers an opportunity for the attendee to submit a better photo
• All face images collected can be deleted in a period as determined by the End User/s

b. Types of Service Data

Our Service handles the following types of data:

• Selfies submitted through the app
• ID card images submitted through the app
• The original face vectors created from those photos
• Matching scores
• Information extracted from the identity card
• Handphone type
• Device ID
• App ID

c. Uses and Disclosures of Service Data

Subject to our contractual obligations to Channel Partners and End Users, we use the Service Data as follows:

• To provide the Service to help our clients use our product capabilities including face matching, face authentication, ID OCR and liveness checking for onboarding customers and as part of a KYC or underwriting process
• To improve the Service
• To enforce the legal terms that govern the Service;
• For other purposes authorized by the Client or, if applicable, their representative (usually a Channel Partner or Registration Provider).
• We do not share data with third parties

d. Personal Data Rights and Choices

We allow clients to request deletion of all test face and ID data sent to us on request or at a specified period from the point of testing. Please contact respective account managers to determine how long the data should be stored for audit or testing purposes.

e. Security and Data Retention

To manage data security risks, we maintain physical, organizational and technical safeguards, which are subject to periodic changes. We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for longer than the original data.

f. International Data Transfers

We are based in Singapore, and recipients of the data disclosures described in this Privacy Policy are located in Singapore and elsewhere in the world, including where privacy laws may not provide as much protection as the country in which you are located. Where applicable, we will comply with legal requirements for cross-border data protection.

g. Notification of Changes

Trustingsocial may change this Privacy Policy to reflect changes in the law, our data handling practices or the features of our business. The updated Privacy Policy will be posted on https://ekyc.trustingsocial.com/privacy-policy/