Privacy Policy

Authentifan respects your privacy and is committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our website or interact with us.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how Authentifan collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a licence from us, or interact with us in any other way.

Controller

Authentifan Ltd (referred to as Authentifan, "we", "us" or "our" in this privacy policy) is the controller of this website and responsible for personal data collected through it. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by emailing [email protected]. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on 07 April 2024.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications (including Yoti (our ID verification provider) and Stripe (our payment services provider)). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or access such third party websites, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer the following kinds of personal data about you:

• · Identification Data includes information you provide to us or to Yoti to allow us to verify your identity when you sign up for a Authentifan, such as:
  • · your passport number or driver’s licence number;
  • · any photos or videos of yourself that you provide to us or to Yoti; and
  • · any other information contained in any identity documents you provide to us;


• · Membership Verification Data includes your membership number(s) for other organisations. This information is collected to facilitate the verification process with those organisations and ensure the integrity of membership access and privileges.


• · Contact Data includes email address and telephone number(s);


• · Transaction Data includes details about payments to and from you and details of your purchase(s) of Authentifan(s) from us;


• · Technical Data includes your login data.


• · Profile Data includes your username and password, purchases or orders made by you, preferences and feedback; and


• · Usage Data includes information about how you use our website, products and services.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a Authentifan). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

Direct interactions

We use different methods to collect data from and about you including through direct interactions. This includes personal data you provide when you:

• · register and create an account on our website;
• · Go through the verification process with us to validate your identity for memberships; or
• · give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties

We may receive Identity, Identification, Contact and Transaction Data from providers of identification and payment services such as Yoti and Stripe (see section 5 for further details).

4. HOW WE USE YOUR PERSONAL DATA

When members of an organisation require verification to gain full access to their membership, they will be directed to Authentifan for identity verification. In this process, we collaborate with our identity verification partner, Yoti, to authenticate members' IDs. Yoti conducts the verification and authentication checks, after which the results are sent back to us. We then communicate to the requesting organisation only the membership status of the individual—whether the member has passed the verification checks or not. We ensure the privacy of our users by not sharing their Document ID number with any organisation. This sensitive information is encrypted and stored securely in our database for future reference if necessary.

Following verification, our system offers organisations the capability to manage user access effectively, including the ability to ban users who violate terms of service. Additionally, it facilitates an innovative feature where organisations can be informed if a user holding memberships across different organisations has been banned elsewhere. This is done without sharing detailed personal information or the reasons for the ban, thereby ensuring privacy while maintaining a safe and compliant environment for all users. Organisations are notified only of the ban status, allowing them to take appropriate action based on their policies without direct access to other organisations' specific data.

Lawful basis for use of personal data

We will only use your personal data when the law allows us to (when we have a “lawful basis”), such as:

• · Where we need to perform the contract we are about to enter into or have entered into with you, or to take steps at your request before entering into such a contract;
• · Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• · Where it is necessary in order for us to comply with a legal obligation that we are subject to.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Generally, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer, for a subscription with Authentifan	Identity, Contact, Identification	• Performance of a contract with you
To process and deliver your order including verifying that you have paid and collecting and recovering money owed to us	Identity, Contact, Transaction	• Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us)
To confirm that your identity has been verified and therefore your membership should be granted full access	Identity, Contact	• Performance of a contract with you
To manage our relationship with you, including contacting you to inform you about changes to our product, our terms and conditions or our privacy policy, or asking you to leave a review or take a survey	Identity, Contact, Profile	• Performance of a contract with you • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To block users who violate our rules of conduct or misuse their Authentifan, in accordance with our terms and conditions	Identity, Contact	• Necessary for our legitimate interests (in maintaining the reputation and integrity of our service and ensuring that our service is secure)
To respond to issues in the identity verification process	Identity, Contact	• Performance of a contract with you • Necessary for our legitimate interests (to ensure that customers can activate their Authentifan)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact, Technical	• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) • Necessary to comply with a legal obligation

Marketing

We do not currently use your personal data for marketing purposes. We may in the future send you marketing communications regarding our products and services if you have:

• · requested information from us; or
• · purchased an Authentifan subscription from us; and
• · you have not opted out of receiving that marketing.

If we do start sending marketing communications, you can ask us to stop sending you them by contacting us at any time. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us through your purchase and use of our website and your Authentifan.

Cookies

You can set your browser to refuse all or some non-essential browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For further details on how we use cookies please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

• · Yoti, Inc. (Yoti): When you register for an Authentifan on our website, you will be redirected to Yoti’s site so that you can upload identification documents and evidence to allow Yoti to verify your identity. Once Yoti has confirmed your identity, we will receive the ID document number and the results of your checks, which we will encrypt and store securely. The information you provide to Yoti is stored on their databases and servers. While Authentifan is able to access this data, we will never export any of your personal data from Yoti except for the ID document number and verification results. For further information about how Yoti processes your personal data, please see their privacy policy available here.
• · Stripe Inc. (Stripe): Stripe manages the invoicing and payment processing on our website. Authentifan does not process or store your payment details. When purchasing a subscription, Stripe will handle the transaction, and you can find the invoices within your billing section. Authentifan ensures a seamless experience by integrating Stripe’s services, maintaining the highest standards of security and privacy. For further information about how Stripe processes your personal data, please see their privacy policy available here.
• · Heroku Postgres (Heroku): Provides cloud data storage services as a data processor on our behalf.
• · Other service providers who provide IT and system administration services.
• · Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• · HM Revenue & Customs, regulators and other authorities based in the United Kingdom where we are required to disclose personal data by law.
• · Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• · The country to which your personal data is transferred has been deemed to provide an adequate level of protection for personal data; or
• · We have put in place specific contracts approved for use in the UK which give exported personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In the case of users who have been banned from using our services due to a breach of terms or other serious infractions, we will retain personal data indefinitely to prevent circumvention of the ban. This retention is critical to uphold the integrity of our services and ensure that banned individuals cannot simply re-register and continue to access services from which they have been prohibited.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, data protection law gives you the following rights in relation to your personal data:

• · Right to request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• · Right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• · Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, we are unable to erase data for individuals who have been banned from our services for breaching terms of service. In such cases, retaining your personal data is necessary for us to uphold the terms of the ban and ensure the integrity and safety of our services. Apart from these circumstances, we will comply with your request for erasure unless we are required to keep your data due to other legal reasons, which, if applicable, will be notified to you at the time of your request.
• · Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• · Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• · If you want us to establish the data's accuracy;
• · Where our use of the data is unlawful but you do not want us to erase it;
• · Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• · You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• · Right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and
• · Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required




You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you




We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond




We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Do you need extra help?




If you would like this policy in another format, please contact us – [email protected]