Privacy Policy

A. Privacy Statement for Private Identity Services.

This privacy policy (“Privacy Policy”) governs how Private Identity LLC (“Private Identity,” “we”, “our” or “us”) uses Personal Data in connection with your use of our Identity Verification Service (our “Service”), as well as your choices regarding use and disclosure of your Personal Data. This Privacy Policy also applies to information that we collect from visitors to our website privateid.com (the “Site”).

As used in this Privacy Policy, the term “Personal Data” (“Personal Data”) means information that identifies you or your household directly or indirectly, including by reference to identifier(s) such as your name, identification number, location data, online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural, educational, commercial, professional or social identity. Our patented homomorphic token irreversibly encrypts biometric data located on your device so that the data is rendered anonymized. Anonymized data is not Personal Data because it does not identify you or your household directly or indirectly.

By using our Service or accessing our Site, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Service or access our Site. Each time you use our Service or access our Site, the current version of the Privacy Policy will apply. Accordingly, whenever you use our Service, you should check the date of this Privacy Policy (which appears at the top) and review any changes since the last version. This Privacy Policy is applicable to all users of our Service and all Site visitors.

Further, you acknowledge that this Privacy Policy is part of our Terms of Service​. This Privacy Policy is incorporated by reference, and by using our Service, you agree to be bound by the Terms of Service. If you do not agree to our Terms of Service, do not use our Service.

B. Information Collected by Private Identity

Information You Provide When You Visit Our Website. Visitors to our website may contact us using our Contact Us page or by sending us an email, thereby sending us some contact information about themselves such as their name, email, phone, location and comments. We may also automatically collect information when you visit the Site including your device’s IP address, and statistics about how you use the Site.

Information You Provide When You Use Our Services. Your Selfie and Biometric Information. Our Service provides a feature where you can take a selfie, and this image is used to verify your identity. This entire process–from taking the photo to analyzing it for identity verification–happens locally on your device. The analysis runs in the web browser or mobile app you are using, which means that Private Identity has no access to your selfie or any biometric information that might be derived from it. Private Identity does not collect, store, or process your biometric data through your camera for this identity verification functionality.

Anonymized and/or Pseudonymized Information. When you use our Service, the only information Private Identity receives is a homomorphic token which is created on your device using our patented technology and sent to us from your device for identity verification itself. We do not receive or have access to your photo or any other Personal Data. This homomorphic token is further protected with strong encryption (AES256 encryption) and then sent to Private Identity’s servers. Since we do not have any other information about you, this homomorphic token is considered anonymous information (“Anonymized Homomorphic Token”).

Facial Verification Log Files. We use log files for billing and quality assurance only. The information inside the Private Identity log file contains only (a) timestamp (b) status (c) homomorphic token (d) redirect URL. The log files do not include internet protocol addresses, type of browser, referring/exit pages, clicked pages or any other information. We do not combine the information collected by any log files with customer or end-user Personal Data. Such information is therefore not considered Personal Data.

C. How Is Your Information Used?

Information collected about Site Users
We use the information collected about our Site Users for our general commercial purposes such as to improve our Site, grow our business and to offer information about our products or services that we think you may find of interest. We use your contact information to respond to your inquiries or to provide information on products or services to you.

Information collected about Services Users
Our Face Verification Service uses the Anonymized Homomorphic Token solely to confirm to customers (i.e., third party product/service providers) whether you are thought to be you. The customer then independently decides what to do with this information (e.g., whether or not you will be granted access to the requested product/service based on this information alone or whether further human review is available). Private Identity does not engage in any decision making based solely on automated processing.

D. Cookies and Do Not Track Disclosure

We may use cookies and similar technology on our Site to collect aggregate (non-personal) information about Site usage by all of our visitors. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology that is necessary for our Site to function. These cookies usually are erased when you close your browser window. Further general information about cookies and how they work is available at www.allaboutcookies.org.

We do not allow third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.
We do not use technology that recognizes a “do-not-track” signal from your web browser.

E. Disclosing Your Information

We will not sell your Personal Data to third parties for their use for monetary or any other consideration without your consent. We do not share your information with third parties for their direct marketing purposes.

We may reveal information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); or (6) as otherwise described in this Privacy Policy.

F. Minors and Children Privacy

Children Online Protection. Our Service is not intended, designed to be attractive to, or directed to children under the age of 18; if you are not 18 years or older, do not use our Service. Our Site is neither intended to nor designed to be attractive to use by children under the age of 18. We do not knowingly collect Personal Data from children under the age of 18. If we learn that Personal Data of persons less than 18 years-of-age has been collected through our Service, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child or a minor under the age of 18 has posted, submitted or otherwise communicated Personal Data to our Service without your consent, then you may alert us at compliance@private.id so that we may take appropriate action to remove the minor's Personal Data from our systems.

G. Links to Third Party Services

Our Site and our Service may contain links to third party websites, applications and services not operated by us. These links are provided as a service and do not imply any endorsement by Private Identity of the activities or content of these sites, applications or services nor any association with their operators. Private Identity is not responsible for the privacy policies or practices of any third party including websites or services directly linked to our Site or our Service. We encourage you to review the privacy policies of any third-party site that you link from our Site or our Service.

H. Security

We take reasonable technical and organizational precautions to protect the confidentiality, security and integrity of all data. Although we use security measures to help protect data against loss, misuse or unauthorized disclosure, we cannot guarantee the security of information transmitted to us over the Internet. While we strive to use commercially acceptable means to protect data, there is no guarantee that information may not be accessed, disclosed, altered or destroyed.

I. Retention

Your selfie is always captured and processed solely on your own device. We do not receive, process or retain copies of your selfie or any associated biometric data, and this information is deleted from your device within one second of being captured.

Information that we collect from or about Site visitors is stored in a form that permits us to identify you, for no longer than is necessary for the purpose for which the personal data is processed. We store your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically and reasonably feasible to remove it. Otherwise, we will seek to delete your personal data within a reasonable timeframe upon request.

J. International Users.

We are headquartered in the United States. Data may be accessed by us or transferred to us in the United States or to our affiliates, partners, merchants, or service providers who are located worldwide. If you are visiting our Service from outside the United States, be aware that your information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated. We will protect the privacy and security of data we process according to this Privacy Policy, regardless of where it is processed or stored; however, you explicitly acknowledge and consent to the fact that data stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of data. We strive to comply with laws of the United States, where we maintain operations, but we make no representations that the practices described in this Privacy Policy are compliant with laws outside the United States that apply to the collection, security, use and disclosure of personal information.

K. Access to Your Information and Your Choices.

Site Visitors can update, amend or delete your information at any time by [describe: emailing us at the address below; contacting us using the Contact Us page; visiting your registered account, if any]. You can choose not to receive promotional emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us. You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Site may be impaired and certain features may not function at all. Our Anonymized Homomorphic Token is not Personal Data as Private Identity has no way of identifying the individual to whom it relates. As a result, Service Users cannot exercise the above rights in relation to such information.

L. Notice to California Residents: Your California Privacy Rights

California residents with an established business relationship with us are permitted by California law once a year to request information about the manner in which we shared certain categories of information with others for their marketing purposes during the prior calendar year. We do not share your personal information with third parties for their direct marketing use.

M. Notice to California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Virginia and Utah Residents

We are currently not subject to the comprehensive consumer data privacy laws applicable to residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Virginia and Utah. If we become subject to any of these laws in the future we will update this Privacy Policy accordingly.

N. Notice to Nevada Residents

We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at compliance@privateid.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.

O. Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy from time to time. If we make any material changes to this Privacy Policy or the way we use, share or collect Personal Data, we will revise the “Effective Date” at the top of this Privacy Policy and post the updated Privacy Policy on this page. We may also endeavor to notify you by, for example, prominently posting an announcement of the changes on our Site or Service, or sending an email to the email address you most recently provided us (unless we do not have such an email address) prior to the new policy taking effect. Users are bound by any changes to the Privacy Policy when he or she uses our Service or access our Site after such changes have become effective. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with Private Identity’s current practices.

P. Contact Us

If you have any questions in relation to this Privacy Policy or if you wish to request more information about our data protection practices please contact us at: compliance@private.id

If you have any questions in relation to this Privacy Policy, if you wish to request more information about our data protection practices, or to exercise any of your data subject rights, please contact us at:compliance@private.id