T Stamp Inc. d/b/a Trust Stamp (“Trust Stamp”) is an international provider of secure identity authentication and verification services to the financial industry, governments, and other enterprise clients (each a “Verifying Entity”).. You are utilizing Trust Stamp and its family of websites and applications because you have been referred to us by a Verifying Entity or directly accessing Trust Stamp whether by typing a URL, snapping a QR Code or clicking on a link.
Our general contact details can be found at: https://truststamp.ai/contact-us.html.
We will only process and use the personal and sensitive information you provide for the original purpose(s) specified in this Policy and any Terms and Conditions to which you have agreed, in accordance with any applicable legal requirements, including the European Union (“EU”) General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), subject to any legal exemptions and requirements.
Personal Information refers to any data that can identify an individual directly or indirectly.
Collection of Information
When you are completing biometric identity verification through websites and/or mobile applications operated by a Verifying Entity, Trust Stamp acts as a “Processor” of personal and sensitive information you provide. As a Processor, we will process your voluntarily provided personal and sensitive information pursuant to our agreements with a Verifying Entity. In some instances, we also access third-party data sources to augment or validate the information you provide.
Trust Stamp collects Personally Identifiable Information, on behalf of the Verifying Entity, from you when you interact with our products and services and communicate with a member of our team, including but not limited to when you sign up for an account, you are, in some instances, voluntarily providing us with a self-portrait style photographic image (we call it a secure selfie) to allow us to prove your identity, help the Verifying Entity know and trust your identity, for Biometric Multi-factor Authentication (MFA) or Age Estimation. You have consented to that process in accordance with the Terms and Conditions of Use and Privacy Policy applicable to our client’s services.
You are, in some cases, also providing us with an image of an identity document. We use that image to compare the photograph on the document to your secure selfie and estimate whether the identity document photograph matches the secure selfie. Sometimes there is not a match due to the age of the image, damage to the document or the quality of the photograph. We also compare the text on the identity document to the information that you have given in account opening. You have consented to that process in accordance with the Terms and Conditions of Use and Privacy Policy applicable to the Verifying Entities’ services.
We may collect non-personally identifiable information from you regarding your usage of our products and services. Non-personally identifiable information refers to data that does not, by itself identify persons and may include, search criteria used and results, date, time, connection speed, internet protocol ("IP") address, which may also be contained on server logs, and/or other information which does not specifically identify you. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services.
Where specified in the Terms and Conditions to which you have agreed, in limited instances, we may act as a “Controller” with respect to your personal and sensitive information. In those instances, we may retain for limited periods and use your personal and sensitive information for limited purposes including:
Data Storage
If you are in the United States, any data that we store will be stored on a secure server in the United States. If your registered address is in Turkey, any data that we store will be stored on a secure server in Turkey. If you are in the EU or the European Economic Area (“EEA”), any data that we store will be stored on a secure server in the EU. If you are resident in the United Kingdom (“UK”), given that the UK is no longer part of the EU, we will continue to ensure that appropriate technical and organizational measures are implemented to safeguard your personal data.
Unless compelled by law, we do not and will not share your identity or other data with anyone other than a Verifying Entity, and the applicable sub-processors required to fulfill the purpose. We do not use your data to market to you, nor do we sell or share your data to allow anyone else to do so.
Verifying Entities have varying legal obligations as to the length of time that data must be stored. With respect to any data that we store, we comply with requirements as directed by the Verifying Entity and other requirements as agreed to by you.
ADDITIONAL RIGHTS IF YOU ARE RESIDENT IN THE EU, EEA, OR UK
If you are resident in the EU or EEA, you have the right to request a copy of any personal information we hold about you. This is known as a Subject Access Request, for which there is no charge, providing the requests are not manifestly unfounded or excessive. You may submit your request by sending an email to privacy@truststamp.net. We may ask you to provide certain information before processing the request to verify your identity. Once in receipt of this, we will process the request without undue delay and within one month. If the matter is complex, an extension of up to two months can be given.
You also have the right to withdraw consent at any time, acknowledging that withdrawing consent does not affect the lawfulness of processing that has already been completed when consent has been used as legal basis for data collection. To request to withdraw consent, please send an email to privacy@truststamp.ai using the email or at least stating the email you entered when the data was collected.
You also have rights in relation to rectification, erasure, restriction of processing, data portability, objection, and automated decision-making. If you would like more information on these rights or would like to submit a direct request within the context of your relationship with Trust Stamp, please contact us by using the contact details provided below.
We can only delete the data that we have stored and then only if we are not legally obligated to keep it for a set or indeterminate length of time. If you have a broader request than the data we store, we recommend that you contact the referring client who can provide us with a request to delete the data.
If you require further assistance, would like to make a complaint, or wish to access your personal information, please contact us using the information below:
Contact us by emailing privacy@truststamp.ai.
Mailing Address:
Trust Stamp
Level 1,
Tagliaferro Business Centre,
Gaiety Lane c/w High Street, Sliema
SLM 1551, Malta
ADDITIONAL RIGHTS IF YOU ARE RESIDENT OF CALIFORNIA
Residents of California have additional rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). You have the right to know: what categories and specific pieces of CCPA personal information have been collected about you; the categories of sources from which CCPA personal information are collected; our business or commercial purpose for collecting, using, or disclosing CCPA personal information; the categories of third parties with whom we share CCPA personal information; the categories of CCPA personal information we have disclosed about you for a business purpose. We do not sell personal information.
You have a right to receive a copy of the specific CCPA personal information we have collected about you.
You have a right to deletion of your CCPA personal information, subject to exceptions under the CCPA. We will not discriminate against you based on your exercise of any rights under the CCPA or CPRA. However, these rights can only be asserted through a verified request from you. To make a request, or if you have a question regarding our privacy practices, please contact us at: privacy@truststamp.ai
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