Privacy Policy

In this privacy policy, we want to help you understand how and why Verify You LLC (“Company,” “we,” or “us”) collects, uses, and discloses information about you when you use our websites, mobile apps, and other online products and services (collectively, the “Services”), or when you otherwise interact with us. By using the Services, you agree to the collection and use of information as described in this Privacy Policy.

Unless otherwise stated, the Company acts as the controller of the information we collect from and about you that identifies, relates to, or could reasonably be linked to you (“personal information”) described in this Privacy Policy. In certain circumstances where we may process personal information strictly on behalf of a business customer under their instructions, we act as a processor, and a separate agreement with that customer, and not this Privacy Policy, governs our processing.

Information We Collect

Data You Provide to Us

To provide you with the Services, we may collect personal information such as:

• Name
• Photo
• Phone number
• Linked third-party accounts

We also automatically collect information about the actions you take while using the Services, including your interactions with our web and mobile applications. This includes technical data like IP address, browser type, device/session metadata, and information collected via cookies and similar technologies.

De-Identified Information

We may de-identify information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.

How We Use Your Information

We use information about you to:

• Provide, maintain, and improve the Services;
• Research and develop new services;
• Send notices, updates, security alerts, and other support and administrative messages;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• In accordance with applicable law, communicate with you about products and services from us and our partners;
• Help protect the safety of the Services and our users, including blocking fraudulent activity and addressing abuse; and
• Comply with applicable law and our terms and policies.

Legal Bases for Processing

Where required by law (e.g., GDPR, UK GDPR, Swiss law, or Brazilian law), we rely on the following legal bases for processing personal data:

• Performance of a Contract: To provide and operate the Services, including account setup, delivering features, providing support, processing payments, and fulfilling contractual obligations.
• Legitimate Interests: To operate and improve the Services, maintain security, prevent fraud, conduct analytics, and communicate about relevant updates, provided these interests are not overridden by your rights.
• Consent: For activities like marketing communications where legally required, using cookies where legally required, and participation in optional programs. You may withdraw consent at any time.
• Legal Obligations: To comply with applicable laws, regulations, audits, and lawful requests from authorities.
• Vital Interests/Public Interest: In rare cases, to protect your safety or the safety of others.

International Data Transfers

We are based in the United States, and your information may be processed and stored in the U.S. or in other countries where our service providers operate. These jurisdictions may not provide the same level of data protection as your home country.

When we transfer personal information internationally, we implement safeguards such as the European Commission's Standard Contractual Clauses or other lawful mechanisms. By using the Services, you acknowledge that your information may be transferred to countries outside your residence.

Your Rights

Your local laws (including applicable laws in the EU, UK, Switzerland, California, Connecticut, Colorado, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Montana, Minnesota, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Virginia, Tennessee, and Texas, as well as similar U.S. state laws) may permit you to request that we:

• Provide access to and/or a copy of certain information we hold about you;
• Update information that is out of date or incorrect;
• Delete certain information that we are holding about you;
• Restrict the way that we process and disclose certain of your information;
• Prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
• Opt-out of the processing of your personal information for automated processing that results in legal or similarly significant effects (if relevant)

Your local laws may also permit you to revoke your consent to the processing of your information for certain purposes.

In addition:

California and Oregon residents can request information about the categories of personal information we collect, disclose or sell or “share” (as defined in California law) about you; California residents can request the sources of such information, the business or commercial purpose for collecting or selling or “sharing” your information; and the categories of third parties to whom we disclose information. Such information is also outlined in this Privacy Policy.

Oregon and Minnesota residents can request a list of the specific third parties, other than natural persons, to which we have disclosed personal information.

Regardless of your location, you also have the following options for managing your information:

Accessing and Updating

Manage your information in your account settings.

Account Management

Delete or modify your account via settings. Certain data may be retained to comply with legal obligations, prevent fraud, resolve disputes, or to enforce our agreements.

Marketing Preferences

Opt-out of marketing emails via unsubscribe links or account settings. We may still send service-related communications.

If you are a resident of one of the U.S. states listed above, you also have the right to opt-out of our processing or “sharing” of your information for online targeted advertising purposes. Note that these laws also allow you to opt-out of the “sale” of your information to third parties in exchange for valuable consideration. Our use of analytics or online advertising tools, as described in the “Online advertising” section above, may result in the disclosure of your information to our third-party partners, and that are subject to these opt-out rights. You can opt-out of both of these activities by following the instructions in the “Online Analytics and Advertising” section below.

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us at privacy@verifyyou.io.

How to Exercise Your Rights

If you wish to exercise your data subject rights, please contact us at privacy@verifyyou.io. We will consider all requests and provide our response within the time period stated by applicable law and as otherwise required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request. We cannot respond to your request or provide you with the information you seek if we cannot verify your identity or authority to make the request and confirm that the request relates to you and your information.

If you are a resident of Virginia, Minnesota, Montana, Oregon, Tennessee, Texas, Iowa, Indiana, Kentucky, Maryland, Nebraska, New Hampshire, New Jersey, Rhode Island, Delaware, Colorado, or Connecticut, and we deny your information request, you have the right to appeal our denial. You can exercise this right by contacting us at privacy@verifyyou.io. Your description must include your full name and the email address used for your account with us, along with a copy of the denial notice you received from us.

If you would like to submit your request through an authorized agent, we will ask the agent to provide written permission from you, and we may need to separately verify your identity as discussed above.

Biometric Information and Retention Policy

If we collect biometric information (such as facial images, ID scans, or other identifiers), we will process such information in accordance with the following:

This Biometric Information and Retention Policy applies to any individuals about whom we have collected biometric information in connection with our identity verification features and services. “Biometric information” includes “biometric identifiers” and “biometric information” as defined under applicable federal, state, and local laws governing the collection and processing of biometric information.

When you create an account, we may ask you to submit (or we may ask your permission to take) a photo of you using your mobile device. We, and our service providers who assist us under contract in performing the identity verification procedures, may use facial recognition technologies to verify human features and that you are not a machine or bot. Facial recognition technology involves the processing of biometric information about the unique features of your facial geography to perform the verification.

We, and our service providers, will only use your biometric information to provide the Services. It is our policy to protect, use, transmit, store, and destroy your biometric information in accordance with applicable laws and by using appropriate technical and organizational measures that are the same as or more protective than the manner in which we protect, use, transmit, and store other confidential and sensitive information. We will only disclose your biometric information to other entities with your consent, or where required by applicable law, including in response to legal process (such as a subpoena or warrant).

We, and our service providers, will retain your biometric information only until the first of the following occurs:

• The initial purpose for collecting or obtaining your biometric information has been satisfied;
• Within three (3) years of your last interaction with us.

Following this timeframe, we, and our service providers, will delete and permanently destroy your biometric information.

Use of Cookies

We use cookies and similar technologies for essential platform functions, personalization, analytics, and advertising. Some cookies are strictly necessary, while others are optional and only used with your consent (where legally required). You can manage cookies through your browser or device settings, industry opt-out tools, or our platform controls.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

Online Analytics and Advertising

Online Analytics

We may use third-party analytics services on our Services (e.g., Google Analytics). These service providers may set and access their own cookies, pixel tags, and similar technologies on our Services and on third-party services to collect information that can be used to track users over time and across services. These analytics services help us understand how users arrive at and use our Services.

If you do not want Google Analytics to collect and use information about your use of our websites, then you can install an opt-out in your web browser. You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google's Ads Settings.

Online Advertising

We strive to provide you with relevant, value-added content in our online advertisements. We work with online analytics and advertising partners to: (1) better understand the use of our Services so that we can improve our Services; and (2) deliver our advertisements that are more tailored to you both on our Services and on third-party Services.

Our partners may also place cookies, pixel tags, and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on these services in order to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our Services to identify products and services you might be interested in and to recognize your device so they can show you relevant advertisements while you are using our Services and other services.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link or the Digital Advertising Alliance's Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs.

How We Disclose Your Information

We may disclose information about you:

• With your consent or at your direction;
• With linked third-party services (if you connect your account);
• With vendors and service providers performing services for us (including customer service, payment processing, data privacy management solution providers, shipping, sales and marketing, product design and development, data storage, security, fraud prevention, research, and legal services);
• To comply with law or legal processes;
• In emergencies, to protect safety;
• To enforce our rights or protect our Services;
• Within our corporate affiliates; or
• In an aggregated or de-identified form.

Business Transfers

As we continue to develop our business, we may engage in transactions with other companies regarding the purchase or sale of a business. We may disclose your information as part of, or in contemplation of, such transactions. If a portion or all of our assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets.

How We Protect Your Information and Information Retention

We use a variety of technical and organizational measures to secure your information. For example, we use HTTPS while information is being transmitted. We also enforce technical and administrative access controls to limit which of our employees have access to non-public personal information. However, no system can be guaranteed 100% secure.

We store the information we collect for as long as it is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes and/or if we believe doing so is in accordance with, or as required by, any applicable law. For example, if you violate our policies and your account is suspended or banned, we may store the identifiers used to create the account (such as phone number) to prevent you from creating new accounts.

No Children

No one under 13 (or the minimum age required by local law outside the U.S.) is permitted to use the Services. If we become aware that we have collected personal information without legally valid parental consent from children under an age where such consent is required, we will take reasonable steps to delete it as soon as possible.

Links to Third-Party Websites and Services

The Services may contain links to third-party websites and online services. This Privacy Policy does not apply to the practices of other websites and online services, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those other websites. Please see the applicable privacy policies for such other sites and services for information about their practices.

Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via email, by providing notice through the Services, or by updating the “Last Updated” at the top of this policy. If you do not agree to any amendment Policy, you must stop using the Services.

Additional Information for California Residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about:

• The purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and
• The categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information.

Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across distinct online services, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We “share” information with our advertising partners to provide more relevant and tailored advertising to you regarding our Services. Moreover, our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” under the CCPA.

The chart below summarizes how we collect, use and share personal information by reference to the statutory categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy.

Your California privacy rights. As a California resident, you have the rights listed above in the “Your Rights” section of the Privacy Policy.

Your Choices Regarding “Sharing” and “Selling”

You have the right to opt-out of our sale/sharing of your personal information for purposes of online analytics and advertising by following the instructions in the “Online Analytics and Advertising” section above.

Other CCPA Rights

Financial incentives. If we offer any financial incentives in exchange for your personal information (e.g., discount coupons in exchange for your email address), we will provide you with appropriate information about such incentives so that you can make an informed decision as to whether to participate.

Right to Limit. The CCPA allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt-out under the CCPA (e.g., we only collect and process biometric information and government IDs for purposes of identity verification).

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, which is why we describe a variety of opt-out mechanisms above. However, we do not currently recognize or respond to browser-initiated DNT signals.

California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt-out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide maintain a policy of providing a cost-free means for consumers to opt-out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes, but if you want to opt-out of potential future disclosures, please email us at privacy@verifyyou.io.

Contact Us

If you have questions about this Privacy Policy, our data practices, or would like to exercise your rights, please contact us at:

Email: privacy@verifyyou.io

Mail: Verify You, LLC, 440 Monticello Ave, Suite 1802, Norfolk, Virginia 23510-2670

If you are located in the EU, UK, or Switzerland, you have the right to lodge a complaint with your local data protection authority if you believe our processing of your information is unlawful.