Smile Identity
Privacy Policy

“2.1. Server logs” refers to a document that automatically records information and details about online interactions with our sites. For example, server logs may record information about a person's visit to our Site on a particular time and day and collect information such as device ID or IP address.

“2.2. Cookies” refers to small files that are stored on a user's device through the use of our websites. A cookie allows the Site to recognize users who have visited and may store user preferences and other information. For example, cookies can be used to collect or store information about use of our website during a session and over time (including the pages viewed and the files downloaded), the device’s operating system, device ID, IP address, and users general geographic location.

“2.3. Personal iInformation” refers to information that can be used to identify, locate, or contact an individual, alone or when combined with other personal or identifying information.

3.1. Third Party Collection

We collect information from third parties who provide it to us through the Services. We may also collect information from third parties pursuant to explicit consent from persons. We further automatically collect certain information about persons from their smartphone or other device when they use, access, or interact with our Services. Additionally, we collect information when persons use any of the devices related to our ID verification and KYC services.

3.2. Personal information provided directly by you through the Site

We collect personal information from users who create an account on the Site, login to their account on the Site, or apply to a job with us. We may collect the following categories of information from these users:

• Full name
• The password you create for your account
• Email address
• Phone number
• Organization name
• Information about your customers
• Payment card information
• Resume information (including experiences and education information)
• Any personal information you provide in your cover letter
• Information we collect through your social media profiles or personal website

3.3. Personal information collected through our identity verification or KYC services

Additionally, we may collect the following categories of information about users who are subject to our identity verification or KYC services through our partners:

• Full name
• Contact Information
• Biometric information (facial geometry)Government ID number (from a national database)
• A photo of your face (selfie)

4.1. We use the information that we collect for a variety of purposes. Our legal bases for processing  personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3)  consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.

4.2. The purposes for which we use personal information include to:

• To provide Users with our Services;
• Respond to  questions or requests concerning the Services;
• Fulfill the terms of any agreement requiring processing of personal data;
• Fulfill requests for our Services or otherwise complete a transaction that persons initiate;
• Send information about our Services and other topics that are likely to be of interest, including newsletters, updates, or other communications, including promotional emails;
• Improve our artificial intelligence and machine learning;
• Deliver confirmations, account information, notifications, and similar operational communications;
• Improve user experience and the quality of our products and Services;
• Comply with legal and/or regulatory requirements;
• Aggregate and de-identify information;
• Serve advertisements;
• Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services;
• Create new products and Services; and
• Manage our business.

5.1. We share personal information with third parties for a variety of purposes, as described below

• • 5.1.1. Businesses who sign up for our Services
    We may share personal information which includes your identity verification status with the businesses who utilize our Verification of KYC Services. In addition to this privacy policy, information collected from persons by businesses who use our services may be subject to the privacy policies of these businesses.
  • 5.1.2. Third-party service providers
    Smile Identity uses third-party service providers that perform Services on our behalf, including web-hosting companies, and mailing vendors. These service providers may collect and/or use personal information we process, including information that identifies persons, to assist us in achieving the purposes discussed above. We may also share personal information with third parties when necessary to fulfill requests for Services; to complete a transaction nitiated by persons through third parties ; to meet the terms of any agreement that persons may have with third parties or with us ; or to manage our business.
  • 5.1.3. Analytics
    We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access device IDs and IP addresses from your device.
  • 5.1.4. Interest-based Advertising
    The Services also enable third-party tracking mechanisms to collect information about persons and personal computing devices for use in online interest-based advertising. For example, third parties, such as Facebook, may use personal information deposited in our App to target online ads to persons who may have used our apps.. In addition, our third-party advertising networks might use personal information obtained from use of our Services to help target advertisements based on mobile activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

5.2. We share personal information with third parties for a variety of purposes, as described below. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. Persons who prefer to prevent third parties from setting and accessing cookies on their computer or other device may set their browser to block cookies.

5.3. Additionally, persons may remove themselves from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Site currently does not respond to “do not track” browser headers, persons can limit tracking through these third-party programs and by taking the other steps discussed above.

6.1. Persons who may wish to access, correct, or delete the personal information we have on file, may contact us at compliance@usesmileid.com

6.2. Residents of the EU, UK, or another jurisdiction with an applicable privacy law,  may have certain rights. These rights may include:

• The right to be informed about our data collection practices;
• The right to access and rectify your data;
• The right to erase or delete your data;
• The right to data portability;
• The right to restrict and object to the processing of your data (including for direct marketing purposes);
• The right to opt-out of marketing emails and text messages;
• The right to limit our use of any automated decision-making processes;
• The right to lodge a complaint to your local data protection authority; and
• The right to withdraw consent (to the extent applicable).

6.3. To exercise any of the rights listed above, please contact us via email at compliance@usesmileid.com. We will respond to your request as soon as reasonably possible but no longer than 30 calendar days.

7.1. We do not warrant, endorse, guarantee, or assume responsibility for the accuracy or reliability of any information offered by third-party websites linked through the site or any website or feature linked in any banner or other advertising.

8.1. We employ physical, technical, and administrative procedures to safeguard the personal information we collect both online and offline. However, no website or platform is 100% secure, and we cannot ensure or warrant the security of any information you transmit through the Services or to us, and therefore you transmit such information at your own risk.

9.1. We retain personal information necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy personal information, we do so in a way that prevents that information from being restored or reconstructed.

10.1. The information that we collect through or in connection with the Services is transferred to and processed in the United States of America for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. However, we comply with all applicable laws regarding international data transfers.

10.2. By using the Services or by providing any information to us, persons expressly consent to such transfer and processing.

11.1. Content on the Services is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.

12.1. We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Services, and we encourage users to review this page periodically.

13.1. If there are questions or concerns about this Policy, we can be contacted by email at compliance@usesmileid.com.