VRIFY Technology Inc. and its affiliates (“VRIFY”, “we”, “us” or “our”) are committed to protecting the privacy of all individuals who: (i) visit any websites or mobile sites offered by VRIFY, including without limitation vrify.com, and including all subdomains, present and future (the “Website”); (ii) use the mobile application that VRIFY makes available from time to time (the “Application”); and (iii) use any of its services, including the content development, technology development, project management, hosting and other services made available from time to time (the “Client Services”). We call the Website, the Application and the Client Services together the “Services”.
Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is an individual that can be identified, directly or indirectly, be referenced to an identifier such as: a name, an identification number, specific location data, an online identifier, or other attributes specific to that natural person.
Personal information does not include information that has been anonymized or aggregated in such a way that it can no longer be used to identify a specific natural person, whether on its own or in combination with other information.
The personal information that we collect falls into two broad categories: Account Data and Content.
Account data (“Account Data”) is personal information you provide us, or that we collect from you and your devices in connection with your access to and use of our Services (such as when you provide us information to register for an account, or information we collect about your browser when you connect to one of our Services, etc.). In legal terms, we collect and use this Account Data as a data controller.
There are two general categories of Account Data we collect in order to provide you with the Services.
The content (the “Content”) which you upload or otherwise make available (including through us in connection with the Client Services), download, or view on our Services (defined as “Content” in our User Terms and “Client Content” and “Client Information” in our Client Terms) may, but does not necessarily, contain personal information. When we refer to “Content” in this notice, we mean the personal information in Content that we process. We only process Content at your direction. In legal terms, we act as data processors for the personal information included in the Content. Our obligations and commitments as it relates to our processing of Content on behalf of our users is outlined in the section below called Content - VRIFY as a Data Processor.
We use, store, and process Account Data as a data controller to provide, understand, improve and develop our Services, keep our Services safe and to comply with our legal obligations. More particularly, we use it to:
We also use non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Services with a view to introducing improvements and improving usability of the Services. We may share this type of statistical data so that our partners also understand how often people use the Services, so that they, too, may provide you with an optimal experience.
Our legal basis for collecting and using Account Data as a data controller will depend on the specific context in which we collect it. However, as a data controller, we will collect personal information from you where:
In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process Account Data, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide Account Data to comply with a legal requirement we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interest which are not already described in this notice, we will make clear to you at the relevant time what those legitimate interests are.
As a user, you may update or correct most of your Account Data by logging in to your account to edit your profile or organization record. To make a request to have Account Data returned to you, removed, or to make additional corrections, please email our privacy team. Requests to access, correct, or remove your information will be handled within 30 days and may be subject to a fee as permitted by applicable law.
Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws with regards to the personal information VRIFY holds about you as a data controller, including:
If you would like to exercise such rights, please contact us. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
You, as a VRIFY user or client, control how Content is generated, requested, submitted or published and processed on our Services. When you use our Services, you may view, create, and analyze Content which may ultimately be published on the Services. The Content that flows through our Services may include personal information of all types, including but not limited to the following categories:
As the user or client, you are the data controller of your Content and we are the data processor for such Content. Where we process Content, we do so at your direction and on your behalf in accordance with the instructions you give us through the Services. We may, in limited circumstances process Content for the purposes of improving the Services and functionalities users ask for as part of their VRIFY experience.
If you are using the Services by invitation of a VRIFY customer, whether that customer is your employer, another organization, or an individual, that customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of Content, which may apply to your use of the Services. Please check with the customer about the policies and settings it has in place.
In several instances, the Content published via VRIFY will not be in VRIFY’s custody, and any Content that has been shared or otherwise made available by you via the Services may continue to be available to third parties and the public at large.
An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete Content stored or processed by us on behalf of a user or client should direct his/her query to the VRIFY client (the data controller). Upon receipt of a request from one of our users or clients for us to remove the data, we will respond to their request within 30 days. Please note however that we may need to retain certain information on our systems for as long as you maintain an account for our Services, for record keeping purposes, to comply with our legal obligations, to resolve disputes, enforce our Terms, or as required or authorized by applicable law. Please refer How Long We Keep Personal Information section below for further detail.
Under EU law, VRIfy is a data processor of Content generated, requested or published via the Services. We process this Content in accordance with the instructions of our users and clients. Because our users and clients control how their Content is collected and used by them, our users and clients are, in legal terms, the controllers of the Content that they process through our Services and are responsible for complying with applicable data protection laws, including the GDPR.
Except as provided in this privacy notice, VRIFY does not share any personal information gathered via the Services with third parties. We may however share Account Data or Content under the following circumstances:
We retain your Account Data for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, or enforcing our Terms.
We retain Content for as long as needed to provide the Services, or until you ask us to delete it pursuant to the Terms. We retain and use this Content as necessary to comply with our legal obligations, resolve disputes, and enforce the Terms.
Please note that certain personal information may need to be retained by VRIFY for a period of time following the cancellation of your account where this is necessary for our legitimate business purposes or required or authorized by applicable law. Our specific retention periods for personal information are documented in our internal retention policies and any applicable retention schedules that we maintain as required by applicable law.
After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner, according to our data retention and deletion policies.
VRIFY follows industry best practices to protect personal information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Account Data and Content we collect, use, process and store, and the current state of technology.
VRIFY Technology Inc., the entity which provides the Services, is a Canadian company with its head-office located in Vancouver, British Columbia. For the purposes of EU data protection law, Canada is considered a country which provides adequate protections for personal information, as confirmed by the European Commission in Commission Decision 2002/2/EC.
The Services are mainly provided from our offices in Canada. VRIFY uses third-party service providers (such as managed hosting providers, card processors, CRM systems, sub-processors of Content and technology partners) to provide the necessary software, networking, infrastructure and other services that we use to operate the Services. These third party providers may process, or store, personal information on servers outside of the EEA, including in Canada or the US.
Also, by the very nature of the Services provided, the data that is viewed, collected, stored or posted on or through the Services also needs to flow from wherever you are located in the world, to where our the same data is stored.
Whenever we transfer personal information from data subjects located in the EEA to a third-party service provider located in a country that has been deemed inadequate, whether that personal information is contained in Account Data or in Content, we do so with and approved legal adequacy mechanisms in place. For any transfers of personal information to the US, we rely on either the third-party’s registration in the EU-US Privacy Shield or on the implementation of the EU’s Standard Contractual Clauses.
By using any of the Services, or submitting or collecting any personal information via the Services, you authorize VRIFY and its authorized service partners to use and process Content and Account Data (including any personal information) in these countries.
You may opt out of marketing communications sent by VRIFY by following the unsubscribe instructions included in each marketing email.
We may use Account Data to customize advertising that we direct to you, utilizing third parties. The Network Advertising Initiative has developed a tool that may help you understand which third parties have currently enabled cookies for your browser and opt-out of those cookies.
Our Services are not intended for use by children and should only be accessed by individuals of at least 18 years old.
Changes to this Privacy Notice
VRIFY reserves the right to make changes to its privacy notice at any time. Innovation in software happens quickly and laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. If we do make changes to the privacy notice, we will post them to this page, so we encourage you to stay informed by checking back here periodically.
VRIFY is headquartered in Vancouver, British Columbia, in Canada. You can contact our Privacy Team via email.
Or via mail:
VRIFY Technology Inc.
401 – 353 Water St.
Vancouver, BC, Canada
© VRIFY Technology Inc. 2023