Consent to Personal Data Processing for testing SumSub’s liveness and identity document check tool via WebSDK Demo on SumSub’s website
1. By clicking the “Continue” button, I as the Data Subject hereby acknowledge and express my voluntary, unequivocal and informed consent that my personal data which I am providing to Sum and Substance Ltd.(hereinafter – “SumSub” or “the Data Controller”) to test SumSub’s liveness and identity document check tool via SumSub’s WebSDK Demo on SumSub’s website for the purpose of obtaining a demonstration of the capabilities of SumSub’s identity verification service when the SumSub’s сlients integrated with SumSub service.
I also declare that I have attained the age of majority under the national laws of my country/countries of citizenship and/or residence.
2. Personal data and other means of identification for the purposes of obtaining this consent shall be established in the course of the processing of my personal data carried out in accordance with this consent.
3. The Data Controller
3.1. The Data Controller is Sum and Substance Ltd, incorporated and registered in England with company number 09688671, whose registered office is at 30 St. Mary Axe, London, EC3A 8BF.
3.2. I hereby acknowledge and agree that I know the company details (including address) of the Data Controller.
4. Types of personal data subject to processing
4.1. The consent for the processing expressed hereby includes the following types of personal data:
– general personal data: full name, sex, personal identification code or number, date of birth, legal capacity, nationality and citizenship, location (street, city, country, postcode);
– identity document data: the type of the identity document, issuing country, number, expiry date, MRZ, information embedded to document barcodes (may vary depending on the document), security features;
– facial image data, namely photo images of my face (including selfie images);
– biometric data (facial features);
– e-mail address;
– technical data(Device Signature), including, but not limited to, information regarding the date, time and type of my activity on SumSub’s website in connection with the purpose specified in clause 1 above, IP address and domain name, my software and hardware attributes as well as my general geographic location ( city, country);
– unique identifier (Applicant ID), created only for the purpose of correctly attributing my personal data to me within SumSub’s systems.
4.2. I hereby agree to provide my biometric data simultaneously with the other personal data specified above, since, otherwise, the purpose of this consent will not be achieved and I will not be able to use SumSub’s liveness and identity document check tool via SumSub’s WebSDK Demo on SumSub’s website.
5. Data processing methods
5.1. SumSub’s liveness tool takes images (hereinafter – the Scan) of a real person’s face (hereinafter – the True Scan Object) via a web camera by scanning the face in a random manner. Attempts to fool SumSub’s liveness tool may be made by scanning any other object instead of the human face, such as images projected on digital screens, synthetic masks, etc. (hereinafter – the False Scan Object). After the Scan is collected, SumSub’s liveness tool will instantly process it to determine whether it depicts the True Scan Object or the False Scan Object.
The photo/scan of a person’s face (hereinafter – the Facial Features) and a template of their identity document (hereinafter – the ID) are uploaded into the SumSub’s liveness and ID check tool via a web camera. The software verifies the security features contained in the ID and compares the image of the ID to the respective Facial Features. Algorithms generate the results of both checks and score them in order to determine whether the ID is authentic and matches the respective Facial Features.
5.2. The consent expressed hereby encompasses the following processing activities, which may be carried out manually or via automated systems: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval within the Data Controller’s systems, consultation, use; disclosure by transmission, dissemination or otherwise making available as described in clause 9.1 below; alignment or combination, restriction, erasure or destruction.
6. Retention period
6.1 I hereby acknowledge and agree that my personal data processed based on this consent are permanently deleted within 30 days upon their collection during the testing of SumSub’s liveness and ID check tool via WebSDK Demo on SumSub’s website.
6.2. The specified retention period is justified by the legitimate interest of the Data Controller, namely by the necessity of internal analysis and ongoing improvement of SumSub’s services used by itscustomers in order to protect public interest* through detection and prevention of fraud and other illegitimate activities.
*SumSub provides identity verification and other services involving personal data processing as a solution intended to detect whether a real person is passing the verification procedure, as well as any impersonation or spoofing attempts, so as to prevent money laundering, terrorist financing, fraud, and other illicit activities, which is considered a matter of public interest.
SumSub ensures that no personal data are used for any purposes incompatible with the aforementioned ones.
7. Data subject rights
7.1. I hereby represent that I have been informed about my rights to:
- withdraw this consent to personal data processing;
- access and adjust my personal data;
- make a justified demand in writing to suspend the processing of my personal data due to particular reason;
- object to the processing of my personal data, including when the retention of personal data is based on legitimate interest;
- object to the transfer of my personal data, including the right to object to engaging any third parties to process my personal data;
- make a justified demand in writing to erase my personal data subject to applicable laws and regulations;
all of which may be exercised by contacting the Data Controller with a respective notice at [email protected].
8. Personal data processing and automated decision-making
8.1. I hereby acknowledge that the processing of my personal data within the scope of this consent does not imply automated decision-making and neither produces any legal effects concerning myself nor similarly significantly affects me.
9. Personal data sharing by the Data Controller
9.1. I hereby acknowledge and agree that my personal data may be shared with entities associated with the Data Controller (SumSub group entities) to achieve the purposes of processing based on this consent. The Data Controller guarantees that such entities implement appropriate technical and organisational measures to ensure safety of the personal data. Personal data provided to such entities will only be used as described in this consent.
10. Personal data transfers
10.1. I hereby represent that I have been informed about the conditions of any possible personal data transfers:
● the Data Controller ensures not to transfer or otherwise process my personal data outside the UK or the European Economic Area (EEA);
● all personal data submitted to the Data Controller are stored on the servers located in the EU (Germany);
● cross-border personal data transfers from the UK to the EU/EEA countries are permitted by the UK Government.
11. I hereby represent that I have carefully read all of the above provisions and do voluntarily and unequivocally agree with them.