Privacy Policy

Privacy and Cookies policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our present and prospective clients, and our website visitors; in this policy we explain how we will handle your personal data.

1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

2. How we use your personal data

2.1 In this Section 2 we have set out:

  1. the general categories of personal data that we may process;
  2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  3. the purposes for which we may process personal data; and
  4. the legal bases of the processing.

2.2 We may process the data relating to your use of our website and services (” usage data “). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process the data you provide us for demo and production account creation (” account data “). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4 We may process your information included in your personal profile on our website (” profile data “). The profile data may include your name, address, telephone number, email address, profile pictures, gender and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

2.5 We may process your personal data that are provided in the course of the use of our services (” service data “). The service data may include your customer’s name, date of birth, credit/debit card number, snapshots of their face and any of their legal document (e.g. identity card, driving license, passport, credit/debit card, etc.) that you present during the service, the real-time video stream of the entire verification process, and video frames captured during verification process. The source of the service data is your customer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.6 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is upholding the terms of the contract that customer enters with the provider .

2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.10 Your Personal information is used by Shufti Pro only as directed by the Third-Party Data Controller (our “clients” ) that integrates our services into its website or application.

2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Automated decision-making

3.1 We will use your personal data for the purposes of automated decision-making in relation to recording the live video stream of the entire verification process, taking frames from that video at each verification step, storing your residence address, name, date of birth, credit/debit card number, passport details and driving license details.

3.2 This automated decision-making will involve checking the info provided by you and matching that with the identity document information provided by you to the merchant (our client) .

3.3 The significance and possible consequences of this automated decision-making are to verify your identity and authenticity of your documents, based on which your chosen process will proceed further.

4. Providing your personal data to others

4.1 We may disclose the information provided by you to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

4.3 We may disclose your personal information to our clients insofar as reasonably necessary for verification of your identity and documents and any legal purpose.

4.4 Financial transactions relating to our website and services are handled by our payment services providers, Stripe and Payoneer. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments. You can find information about the payment services providers’ privacy policies and practices at Stripe: https://stripe.com/us/privacy & Payoneer: https://www.payoneer.com/legal/privacy-policy/

4.5 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 We have our office in the United Kingdom and provide services in ALL the countries.

5.3 The hosting facility for our website is situated in the United Kingdom . The European Commission has made an “adequacy decision” with respect to the data protection laws this country.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain and delete your personal data as follows:

  1. personal data category will be retained for 2 years following December 1, 2017 , at the end of which period it will be deleted from our systems.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

  1. the period of retention of your personal information including any data, images, videos and/or private information will be determined based on the need for their presence in our system owing to any legal reasons or for the betterment of our website or services .

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email.

8. Your rights

8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

  1. the payment of a fee (currently fixed at GBP 10) and
  2. the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2 We may withhold personal information that you request to the extent permitted by law.

8.3 You may instruct us at any time not to process your personal information for marketing purposes.

8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Updating information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Acting as a data processor/controller

11.1 In respect of your personal information (including any images, videos, sensitive data, etc.) , the data controller (our client) may require Shufti Pro to collect, use, disclose, or otherwise process data in ways that differ from those described in this policy. Some features of the Services may be immobilized or changed by the data controller (our client). In order to completely comprehend the handling of your private information while using our services, you must also review the privacy policy of the third party with whom you are dealing directly (the “Third-Party Data Controller”).

11.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller (our client).

12. About cookies

12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

13. Cookies that we use

13.1 We use cookies for the following purposes:

  1. authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: ShuftiPro1;
  2. status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: ShuftiPro2;
  3. personalisation – we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: ShuftiPro3);
  4. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: ShuftiPro4);
  5. advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: ShuftiPro5);
  6. analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: ShuftiPro6); and
  7. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: ShuftiPro7).

14. Cookies used by our service providers

14.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

14.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: ShuftiPro8.

14.3 We use Third-party service providers to aid us in managing, improving and efficiently delivering quality services to you . This service uses cookies for online tracking procedures. You can view the privacy policy of this service provider at https://www.google.com/policies/privacy/. The relevant cookies are: ShuftiPro9.

15. Managing cookies

15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

  1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
  2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-websi te-preferences (Firefox);
  3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-expl orer-delete-manage-cookies (Internet Explorer);
  5. https://support.apple.com/kb/PH21411 (Safari); and
  6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-p rivacy (Edge).

15.2 Blocking all cookies will have a negative impact upon the usability of many websites.

15.3 If you block cookies, you will not be able to use all the features on our website.

16. Our details

16.1 This website is owned and operated by Shufti Pro Admin .

16.2 We are registered in England and Wales under registration number 11039567 , and our registered office is at 190 Englishcombe Lane, Bath BA2 2EN .

16.3 Our principal place of business is at 190 Englishcombe Lane, Bath BA2 2EN .

16.4 You can contact us by email, using the email address published on our website from time to time: sales@shuftipro.com.

17. Representative within the European Union

17.1 Our representative within the European Union with respect to our obligations under data protection law is Shufti Pro Admin and you can contact our representative via email: privacy@shuftipro.com.

18. Data protection officer

18.1 Our data protection officer’s contact details are: privacy@shuftipro.com.