Jumio Corp. Privacy Policy for Online Services

Jumio Corporation (“Jumio”) respects the privacy of our users.  This Privacy Policy (“Policy”) describes our privacy practices concerning information collected in connection with Jumio’s payment, verification, and related online services, including but not limited to Authentication, BAM Checkout, Document Verification, Fastfill, ID Verification and Identity Verification (the “Services”). A separate policy, available here, describes our privacy practices in connection with our online website, located at www.jumio.com. Jumio makes the Services available to third parties for integration into those third parties’ websites, applications, and online services.  Jumio collects, uses, and discloses individual users’ information only as directed by these third parties and, accordingly, under applicable data protection laws, Jumio is a processor or service provider (“data processor”) of user information with respect to the Services and not a controller or business (“data controller”). Further, some features of the Services may be disabled or altered by the data controller, or the data controller may require Jumio to collect, use, disclose, or otherwise process data in ways that differ from those described below. Thus, to fully understand how your information will be handled when you use the Services, you must review not just this Policy, but also the privacy policy of the third party with whom you are dealing directly (the “Customer Data Controller”). As an exception to the above, Jumio processes personal information in the capacity of a data controller and a business to comply with its regulatory obligations. For further information please review the section “Jumio acting as a data controller” below.

Notwithstanding the above, Jumio may process certain individual users’ information in anonymized and/or aggregated form for its own purposes.

Jumio is headquartered in the United States at 395 Page Mill Road, Suite 150, Palo Alto, CA 94306.

What personal and other information Jumio collects about you

Jumio collects “personal information” about users of the Services. “Personal information” is information such as a name, email address, or identification card image, which refers to an identified or identifiable person. Jumio processes personal information on behalf of the Customer Data Controller. For its own purposes, Jumio only processes the personal information described in section “Jumio acting as a data controller” and anonymized and/or aggregated information. “Anonymized information” is information which does not relate to an identified or identifiable person or is rendered anonymous in such a manner that the person is no longer identifiable.

Personal information.  Jumio collects a wide range of personal information through the Services. This information varies depending on the Jumio application and the Customer Data Controller in question, but may include such information as name, physical address, email address, telephone number, social security number, driver’s license number, state or national ID card number, passport number, other ID card number, credit or debit card number, CVV, expiration date, and/or date of birth. In some cases, Jumio may collect a visually scanned or photographed image of your face and/or your identification card, driver’s license, passport, utility bill, bank account statement, insurance card, or credit/debit card.  This image may include your photograph and other information from the imaged document, such as your eye color, weight, height, and organ donor status.

Information for Illinois residents: Jumio’s collection of personal information may include biometric identifiers and/or biometric information (collectively “biometric data”), and Jumio may share such biometric data with the Customer Data Controller. Jumio may collect, process and store your biometric data for the purpose of verification services and long-term proof of inspection of your provided form of identification, on behalf of and as instructed by the Customer Data Controller. Jumio will store your biometric data for as long as the Customer Data Controller requests (e.g., the duration of your use of its services), which shall be no longer than the earlier of the date when (i) the Customer Data Controller ceases to have a relationship with Jumio or (ii) within three (3) years after the Customer Data Controller informs Jumio that its last interaction with you has occurred.

Facial recognition. If you agree to use our Netverify with Biometric Facial Recognition, or other facial recognition service that we offer to our business customers, Jumio will collect an image of your face that you provide through a mobile app (i.e. a selfie) and a photo or scan of your face as it appears on an identification document. Jumio will use facial recognition technology only for the purpose of verifying your identity as the person who appears on the identification document. Jumio may share the facial scans with the Jumio customer through which you used Jumio’s identity verification service. Jumio will retain your facial recognition information, including the photo of your face and photo or scan of your identification document, for the amount of time requested by the Jumio customer through which you used Jumio’s identity verification service. In no event will Jumio store your facial recognition information after Jumio ceases to have a customer relationship with the customer through which you used Jumio’s identity verification service.

Data provided by third parties.  We may receive personal or anonymized and/or aggregated information about you from the Customer Data Controller that integrates the Services into its website, application, or other online service. This information includes a customer ID, selected by the Customer Data Controller, that uniquely identifies you in the third party’s database.  For additional information, review the privacy policy of the Customer Data Controller.

At the direction of the Customer Data Controller, Jumio also might obtain information about you from other third parties, such as consumer reporting agencies and fraud-prevention services.

Cookies and other tracking data.  When you use the Services, we automatically receive and record certain information from your computer (or other device) and/or your web browser.  This may include such information as the third-party website or application into which the Services are integrated, the date and time that you use the Services, your IP address and domain name, your software and hardware attributes (including operating system, device model, and hashed device fingerprint information), and your general geographic location (e.g., your city, state, or metropolitan region; or your geolocation (GPS coordinates) if available). If you use the Authentication service, we may install little pieces of software (called: service workers) on your device to increase the speed of the next and following verifications. The service worker does not collect any data about you and does not track you.  We will process such data only as instructed by the Customer Data Controller, or as required for Jumio to meet its obligations relating to its own regulatory compliance.

We also use cookies in connection with the Services.  For further information please refer to the section entitled “Cookies” below.

Cookies

What are cookies? Cookies are small files that are stored on your computer or other device by your web browser.  A cookie allows Jumio to recognize whether you have used the Services before and may store user preferences and other information.

How are cookies used? For example, cookies can be used to collect information about your use of the Services during your current session and over time, your computer or other device’s operating system and browser type, your Internet service provider, your domain name and IP address, and your general geographic location or geolocation. We process personal information generated by cookies only as instructed by the Customer Data Controller.

What kind of cookies are used on the Website? Our website primarily uses the following types of cookies:

 

Cookie NameCookie TypePurpose
__gaPersistent cookieThis cookie is used to distinguish users and expires after 2 years.
__gatSession cookieThis cookie is used to throttle the request rate and expires after 10 minutes.

 

“Session cookies” are temporary bits of information which are deleted when you exit your web browser. Session cookies are typically used to improve navigation and to collect web statistics.

“Persistent cookies” are more permanent bits of information that are stored and remain on your computer until they are deleted by you. This type of cookie stores information on your computer for a number of purposes; such as saving your passwords. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.

How do you avoid cookies? If you are concerned about having cookies on your computer or device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it.  You can also delete cookies from your computer.  However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.

How Jumio uses the personal and anonymized/aggregated information that we collect

In general, Jumio uses the personal and anonymized and/or aggregated information that we collect in connection with the Services as discussed in this section of the Policy.

Other than as described under the section “Jumio acting as a data controller” personal information is used by Jumio only as directed by the Customer Data Controller that integrates the Services into its website, application, or other online service.  Subject to the privacy policy of the Customer Data Controller, we use your personal information as follows on behalf of the Customer Data Controller.

Jumio may use your personal information to provide the Services.  For example, we might use your credit card information or ID card information to populate an online form, or to verify your identity in connection with your use of another online service.  We also may use your personal information to fulfill the terms of any agreement between us and the Customer Data Controller; to complete a transaction that you initiate; to deliver confirmations, account information, notifications, and similar operational communications; and to comply with legal and/or regulatory requirements.

Anonymized and/or aggregated information that we collect in connection with the Services is used by Jumio for its own purposes to perform analytics and research concerning the Services.

We process the provided personal information manually, by our specially trained verification agents or automatically with the use of our software and machine learning capabilities. When we process the personal information automatically, we apply especially the following criteria:

  • Checks on the integrity and quality of the photographs;
  • Checks on the integrity and recognition of the document;
  • Extracting and analysis of text, graphical layout, and any other available information on the document, face photographs and face maps, background;
  • Analysis of results of all the steps combined, considering multiple variables, predictions and confidence values for a final score;
  • Lookups against known images as well as known cases;
  • In case of identity verification, your selfie is compared to the photo on the document and is used to ensure your liveness in the selfie.

Please reach out to the Customer Data Controller responsible for your personal information with any inquiries regarding the rights you may have in case your personal information is subject to automated decision-making.

How Jumio shares personal and anonymized/aggregated information with other entities

In general, Jumio shares the personal and anonymized and/or aggregated information that we collect in connection with the Services as discussed below.

Other than as described under the section “Jumio acting as a data controller” below, Jumio shares personal information only as directed by the Customer Data Controller, and thus the following language is subject to the privacy policy of the Customer Data Controller.

Customer Data Controller.  We share the personal and pseudonymized information that we collect on behalf of a particular Customer Data Controller with that Customer Data Controller.

Jumio service providers.  Jumio also uses third-party service providers to help us deliver, manage, and improve the Services.  These service providers may collect and/or use your personal information or anonymized and/or aggregated information to assist us in achieving the purposes discussed above in the section entitled “How Jumio uses the personal and anonymized /aggregated information that we collect.”

We also may share your personal information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; or to meet the terms of any agreement that you have with us or our partners.

Analytics providers.  We partner with certain other third parties to collect anonymized and/or aggregated information and engage in analysis, auditing, research, and reporting.

Legal purposes.  We also may use or share your personal information with third parties when we have reason to believe that doing so is necessary:

  • to comply with applicable law or a court order, subpoena, or other legal process;
  • to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • to establish, protect, or exercise our legal rights or defend against legal claims; or
  • to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated information.  From time to time, Jumio may also share anonymized and/or aggregated information about users of the Services, such as by publishing a report on trends in the usage of the Services.

Information for California residents. Jumio processes your personal information on behalf of the Customer Data Controller pursuant to a written agreement for verification services. As such, Jumio acts as a service provider to the Customer Data Controller. Moreover, Jumio does not sell your personal information as the terms “sell” and “personal information” are defined by the California Consumer Privacy Act (the “CCPA”) and, in providing its services to the Customer Data Controller, Jumio will not retain, use, or disclose your personal information to any other third parties that would constitute “selling” as the term is defined by the CCPA. Any questions or requests regarding Jumio’s processing of your personal information in respect of your rights under the CCPA should be directed to the Customer Data Controller that is responsible for your personal information.

Security

Jumio uses commercially reasonable physical, electronic, and procedural safeguards designed to protect your personal information against loss or unauthorized access, use, modification, or deletion. Among other things, Jumio encrypts sensitive information both in transit and at rest.  Jumio regularly conducts security audits, vulnerability scans, and penetration tests to ensure compliance with industry security practices and standards.  However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information.  Moreover, we cannot guarantee the safety of your information when in the possession of other parties, such as the Customer Data Controller.

Reviewing and updating your information

With the exception of Jumio acting as a data controller (please see below), Jumio will grant you access to your personal information only as directed by the Customer Data Controller that integrates the Services into its website, application, or online service.  Jumio also will retain your personal information as directed by the Customer Data Controller and, accordingly, we may retain your personal information for as short as a few minutes or longer as directed by the Customer Data Controller.

Thus, if you want to learn more about the personal information that Jumio has about you, or you would like to submit a request to update or change that information, please contact the Customer Data Controller. You also may reach us by email at privacy@jumio.com.

Jumio acting as a data controller

  1. Processing of GPS coordinates and IP addresses

Jumio acts as a data controller when processing GPS coordinates and IP addresses collected when rendering its services to Customers Data Controllers.

The data subjects whose personal information is processed are end-users using the Services.

Purpose and legal basis for processing

The purpose of processing is to provide legal notices to data subjects and allow them to grant their informed consent relating to the use of biometric information by Jumio in connection with the Services, as required under the laws applicable to Jumio concerning the respective user (e.g. the Illinois Biometric Information Privacy Act or “BIPA”).

Jumio processes the personal information – GPS coordinates and IP addresses – on the basis of Article 6(1)(f) GDPR, specifically:

(i)     the prevailing legitimate interest of Jumio to comply with its legal obligations in jurisdictions outside of the European Union;

(ii)    the prevailing legitimate interest of data subjects using Jumio’s services to be notified of biometric information processing by Jumio and express their consent, under the laws applicable to Jumio concerning the respective user.

Recipients of the personal information

  1. The personal information is entrusted to data processors acting on Jumio’s behalf, providing hosting services, technical staff and relevant technical infrastructure. In such case the processors shall process personal information on the basis of an agreement with Jumio and exclusively in accordance with Jumio’s instructions.
  2. The personal information may be received by competent state authorities operating on the basis of generally applicable legal provisions.
  3. Jumio’s authorized employees and contractors may have access to the personal information.

The period for which the personal information will be stored

GPS coordinates and IP addresses will only be stored for the period necessary to establish the location of the data subject and deleted immediately afterwards. 

Data subjects’ rights in regard to personal information – GPS coordinates and IP addresses

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.

We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request. If we are unable to verify your identity, we will not be able to fulfill your request.

California Residents

For purposes of the California Consumer Privacy Act, Jumio does not “sell” personal information.

California residents have the right not to receive discriminatory treatment by Jumio for the exercise of their rights conferred by the California Consumer Privacy Act.

Data Subjects Located in the European Economic Area – Supervisory Authority

If you are located in the European Economic Area, you have the right to file a complaint with the supervisory authority – Austrian Data Protection Authority (Österreichische Datenschutzbehörde). To exercise your rights please contact us at the address provided below.

Additional information for users of the Services from outside the United States

The personal information that Jumio collects through or in connection with the Services is transferred to and processed in the United States for the purposes described above.  Jumio also may subcontract the processing of your data to, or otherwise share your data with, its affiliates or third parties in the United States or 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 only transfer your personal information to countries where the EU Commission has decided that they have an adequate level of data protection or we take measures to ensure that all recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC).

Children’s Privacy

The Services are not directed to children under the age of 13, and Jumio will never knowingly collect personal or other information from anyone it knows is under the age of 13. We recommend that persons over 13 but under 18 years of age ask their parents for permission before using the Services or sending any information about themselves to anyone over the Internet.

Changes to this Policy

Technology and the Internet are rapidly changing.  Jumio therefore is likely to make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes.  When we revise the Policy, Jumio will post the new Policy on the Jumio website’s home page (www.jumio.com), so you should review that page periodically.  If we make a material change to the Policy, you will be provided with appropriate notice.  If we maintain your email address, we also may email you a copy of the revised Policy at your most recently provided email address.  It is therefore important that you update your email address if it changes.

Questions or comments

If you have any questions or comments regarding our Policy, please mail or email us at:

Jumio Corporation
395 Page Mill Road, Suite 150
Palo Alto, CA 94306

Email: privacy@jumio.com

The Data Protection Officer can be reached by email at: privacy@jumio.com

We may request that you confirm your identity in order to continue with your request.

 

Effective date: December 23, 2019