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Sumsub Biometrics Processing Consent (U.S. Residents)

This Consent is intended for use when biometric identification, biometric identity verification, or biometric authentication performed by Sumsub is offered or required in the United States.

1. Parties and roles. This Sumsub Biometrics Processing Consent (“Consent”) applies to (i) you, (ii) the Company as defined below, and (iii) Raritex Trade Ltd., HE 369578, 153 Agiou Andreou, 3036, Limassol, Cyprus, together with its relevant affiliates and independent authorized distributors involved in providing identification, identity verification, authentication, and fraud prevention services to the Company (cumulatively “Sumsub”), including without limitation: Sum and Substance Ltd. (UK), Sumsub Tech Ltd. (Cyprus), Sumsub Ltd. (Cyprus), Sumsub Inc. (US), Sumsub GmbH (Germany), Sumsub APAC Pte. Ltd. (Singapore), Sumsub Technology LLC (UAE), Sumsub Brasil LTDA (Brazil), Lexory Technologies OPC (Philippines). The Company is the business with which you seek to establish, maintain, or continue a relationship in connection with your interaction with Sumsub. The Company uses Sumsub’s services and is responsible for deciding whether biometric identification, biometric identity verification, or biometric authentication are required for your onboarding or due diligence checks. Sumsub processes your Biometric Data on the Company’s behalf to provide those services and may also process certain Biometric Data for its own lawful purposes as described in the Sumsub Privacy Notice.

2. What “Biometric Data” means in this Consent. For the purposes of this Consent, “Biometric Data” means (i) scans of face geometry and (ii) information derived from scans of face geometry where those are used to identify an individual. For clarity, photographs, video recordings, and audio recordings are not themselves Biometric Data.

3. Specific Biometric Data processing purposes. Your Biometric Data may be collected, stored, used, disclosed, and otherwise processed by Sumsub and its subprocessors for the following specific purposes:

  • (a) to compare your live facial image or video with the image on your submitted identity document or the image extracted from an external database;
  • (b) to determine whether the presented face appears live and genuine, rather than a spoof, mask, replay, emulator, static image, manipulated video, or deepfake;
  • (c) to detect duplicate, synthetic, or otherwise suspicious identity patterns in connection with the Company’s identity verification program;
  • (d) where the Company uses a repeat-authentication or reverification flow, to authenticate you as the same person previously verified (and to enable such authentication throughout the duration of the term of the contract concluded between the Company and the relevant Sumsub entity);
  • (e) to create, preserve, and review records necessary to demonstrate compliance with legal and contractual obligations;
  • (f) to handle complaints and establish, exercise, and defend legal claims;
  • (g) to support limited service improvement, analytics, quality assurance, and anti-fraud model calibration by Sumsub where allowed by applicable law and as described in the Sumsub Privacy Notice.

4. How the processing is performed. Processing of Biometric Data may include: automated and manual capture, extraction, and conversion of facial images into scans of face geometry; cross-comparison of scans of face geometry; liveness analysis; anti-spoofing analysis; duplicate-identity detection; fraud scoring; and related recordkeeping. Human review may also occur when needed for quality assurance, fraud prevention, customer support, complaint handling, or legal and regulatory compliance. Sumsub’s automated tools assist the process, but the final decision whether to approve, reject, or otherwise act on your application or account is made by the Company, not by Sumsub.

5. Disclosure of Biometric Data. Your Biometric Data may be disclosed only to the extent reasonably necessary for the purposes above and under applicable law, including to: (a) the Company; (b) Sumsub entities, independent authorized distributors, and subcontractors that support Sumsub’s services and are bound by confidentiality, security, and data processing obligations; (c) external data sources, registries, and screening providers used for identification, identity verification, authentication, or fraud prevention checks; and (d) courts, regulators, law enforcement bodies, or other authorities where required by law, legal process, or a binding request. Neither the Company nor Sumsub may sell, lease or trade your Biometric Data.

6. Retention period and destruction. Your Biometric Data processed on the Company’s behalf will be retained until the earliest of: (a) the expiration or termination of the contract concluded between the Company and the relevant Sumsub entity, where such contract does not permit the Sumsub entity to conduct further processing; (b) deletion pursuant to the Company’s documented instructions; or (c) another event triggering Sumsub’s mandatory deletion obligations under applicable law. Where Sumsub independently retains Biometric Data for its own lawful purposes, it will retain that data only for as long as reasonably necessary for those disclosed purposes and no longer than permitted by applicable law. In particular: for Illinois residents, the maximum retention period for Biometric Data is three (3) years from the date of your last interaction with the Sumsub system or a shorter period if the processing purpose is satisfied earlier; for Texas residents, Biometric Data will be destroyed within a reasonable time and no later than one (1) year after the purpose for collecting it expires; and for Washington residents, Biometric Data will not be retained longer than is reasonably necessary to provide the requested services to the Company, prevent fraud or security threats, or comply with legal obligations. Sumsub’s data retention and destruction practices are described in its Privacy Notice.

7. International transfers. Where your Biometric Data is transferred internationally, Sumsub will use lawful transfer mechanisms and safeguards required by applicable law, which may include adequacy decisions, standard contractual clauses, the EU-U.S. Data Privacy Framework where applicable, or other legally recognized safeguards. Additional information is available in the Sumsub Privacy Notice.

8. Your choices and rights. You may withdraw this Consent in relation to the Biometric Data processing conducted by Sumsub at any time by contacting Sumsub at [email protected]. Withdrawal will not affect processing that took place before withdrawal and may mean that you cannot complete identity verification, use certain account features, or continue using a service that requires biometric verification unless the Company offers a non-biometric alternative. Requests relating to the Company’s processing of your data should generally be directed to the Company. Requests relating to Sumsub’s own processing may be directed to Sumsub.

9. Consent statement. By selecting “I agree,” checking the relevant box, clicking the confirmation button, or making similar affirmative action, you confirm that: (a) you have read this Consent and had an opportunity to review the Sumsub Privacy Notice; (b) you were informed in writing about how your Biometric Data would be collected, stored, used, and otherwise processed; (c) you were informed of the specific processing purposes and retention terms described above; (d) you know the Company’s identity; and (e) you knowingly, voluntarily, and expressly provide your informed written consent, including electronic consent where permitted by law, to the collection, storage, use, disclosure, destruction, and other processing of your Biometric Data as described in this Consent.

Sumsub Privacy Notice (Service Delivery): https://sumsub.com/privacy-notice-service/