Last Updated: December 29, 2021
The Jumio Showcase mobile application (“Showcase App” or “App”) is published by Jumio Corporation (“Jumio” or “we”), as the data controller, for the purpose of demonstrating and testing Jumio’s ID verification capabilities, and related online services. This Privacy Notice (“Notice”) describes how we process – or, in other words, collect, use, transmit, store, share, and delete – personal information in connection with the use of the App.
Separate notices describe our privacy practices in connection with our online website, located at www.jumio.com (the “Site”; see here) and our privacy practices in connection with other related applications that Jumio makes available on the Site and that are embedded in third-party applications and services (see here).
1. What information is collected and why
Information you submit to Jumio via the App
To demonstrate Jumio’s ID verification capabilities we collect identity verification information from the documents you submit via the App, such as images of your government-issued ID (as permitted by applicable laws), your ID number or other verification information. This information may include:
- Personal Identifiers (e.g., name, postal address, email, etc.);
- Government Identifiers (e.g., Social Security number, driver’s license number, passport number, or other similar identifiers);
- Financial Information (e.g., credit or debit card number, CVV, expiration date, etc.);
- Biometric data (e.g., scans of documents with images of a user’s face, user-submitted facial image); and
- Other data available on the documents you submit via the App.
Certain products and services require facial recognition service where Jumio collects an image of your face that you provide through the App (i.e., a selfie). Jumio will use the facial image provided to verify your identity as the person who appears on the identification document. If you have associated the App with a business account, Jumio may share the facial scans with the Jumio customer associated with the business account.
The App may also collect information about your business relationship with Jumio if you connect your business account to the App. Jumio may use your information to link the data to current customer files and information and send you account information and information about our services.
Information collected automatically when you use our App
When you use the App, we also automatically collect certain information which enables us to provide, improve and develop our App and products and services. This information may include:
- Geo-location information, inferred from IP address; and
- Log data and device Information, such as details about how you’ve used the App, IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the App.
Information collected from third parties
To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. These categories of third parties include consumer reporting agencies and fraud-prevention services.
The personal information listed above may be used by Jumio to:
- demonstrate the ID verification functionality of the App to you;
- comply with legal and/or regulatory requirements;
- improve your user experience and the quality of our App and products and services;
- improve Jumio’s ID verification capabilities;
- create new products and services or improve our existing products and services; and
- enable additional analytics and research concerning the App and Jumio’s ID verification capabilities.
Information for Illinois residents
Jumio’s collection of personal information may include biometric identifiers and/or biometric information (collectively “biometric data”). If your App is associated with a business account, Jumio may share such biometric data with the applicable customer. 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. Jumio will store your biometric data until the initial purpose for collecting or obtaining biometric data has been satisfied or within 3 years of your last interaction with us, whichever occurs first.
2. How Jumio shares personal information
Sharing for business purposes. We may provide personal information to third-party service providers to help us improve our products and services and to deliver, manage, and improve the App. We may share all the categories of information listed in this Notice with other companies including affiliates, subsidiaries, or parent companies:
- To operate our products and services or support general operations of business;
- To integrate the products and services of our business partners;
- To use third-party cloud services to process the personal information; and
- For any other legitimate business purpose.
Corporate transactions. In the event of a corporate sale, merger, reorganization, dissolution or similar event, any personal information, and data we process from you may become part of the assets we transfer or share in preparation for any such transaction. Any acquirer or successor of Jumio may continue to process personal information consistent with this Notice.
Compliance and compelled disclosures. We may share personal information:
- with public authorities to respond to subpoenas, court orders, and other legal process, or as otherwise required by law;
- to protect the rights, privacy, safety, and property of Jumio, our customers, our business partners, or others; and
- to exercise our legal rights or defend against legal claims, to enforce our contracts, to investigate, respond to and resolve problems or inquiries (including governmental inquiries), or to permit us to pursue available remedies or limit the damages that we may sustain.
Aggregated information. From time to time, Jumio may also share anonymized and/or aggregated information about users of the App, such as by publishing a report on trends in the usage of the App or products and services.
Information for California residents. Other than with your consent, Jumio does not sell your personal information as the terms “sell” and “personal information” are defined by the California Consumer Privacy Act (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 [email protected].
Jumio will retain your Personal Information for as long as it is necessary to achieve the purposes set out in the What information is collected and why section. If your use of the App is linked to a business account, Jumio will enable the appropriate data retention requirements provided by the applicable customer.
4. Your Rights
You can exercise any of the rights described in this section consistent with applicable law by emailing [email protected]. Please note that we may ask you to verify your identity and request before taking further action on your request.
Data Access and Portability. In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
Data Deletion. In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the deletion of your personal information:
- We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Jumio may keep information for tax, legal reporting and auditing obligations.
- Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited time.
In accordance with applicable law, you may also have the right to: (i) request confirmation of whether Jumio is processing your personal information; (ii) object to or restrict our uses of your personal information; (iii) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (iv) lodge a complaint with the competent supervisory authority or regulatory agency.
We will not discriminate against you for exercising any of the above rights.
5. Information for users of the App from outside the United States
The personal information that Jumio collects through or in connection with the App 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, 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. Where Jumio transfers personal information outside of the United States, Jumio will implement appropriate contractual and technical safeguards.
European Union (“EU”) and European Economic Area (“EEA”)
We take measures to help protect your personal information when it is transferred from the European Economic Area (“EEA”) to third countries. We may rely on European Commission adequacy decisions about certain countries, as applicable (see here). Where applicable we rely on standard clauses approved by the European Commission (see here) in our contracts with third parties that receive information from both inside and outside the EEA or transfer on the basis of permissible statutory derogations.
Jumio’s representative in the EU is Jumio Software Development GmbH, Stättermayergasse 28, 1150 Vienna, Austria. Jumio’s Data Protection Officer is Dorota Kosela, who may be contacted at [email protected].
The legal basis of Jumio’s processing of your personal information includes:
- Jumio’s legitimate interest to achieve the purposes set out in What information is collected and why section and the prevailing legitimate interest of individuals whose personal data is used for a non-authentic ID document not to be become victims of identity theft (Article 6(1)(f) GDPR);
- the necessity to comply with legal obligations to which Jumio is subject (Article 6(1)(c) GDPR);
- the necessity for the establishment, exercise or defense of legal claims (Article 9(2)(f) GDPR); and
- your consent (Article 6(1)(a) and Article 9(2)(a) GDPR).
Jumio uses commercially reasonable physical, electronic, and procedural safeguards designed to protect your personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and thus Jumio cannot guarantee the absolute security of your personal information or other information. Please visit Jumio’s Information Security website to learn more.
7. Children’s Privacy
The App is not directed to children under the age of 16, and Jumio will never knowingly collect personal or other information from anyone it knows is under the age of 16. We recommend that persons over 16 but under 18 years of age ask their parents for permission before using the App or sending any information about themselves to anyone over the Internet.
8. Changes to this Notice
Technology and the Internet are rapidly changing. Jumio therefore is likely to make changes to the App in the future and therefore will need to revise this Notice to reflect those changes. When we revise the Notice, Jumio will post the new Notice at https://www.jumio.com/privacy-center/privacy-notices/, review that page periodically. If we make a material change to the Notice, you will be provided with appropriate notice. If we maintain your email address, we also may email you a copy of the revised Notice at your most recently provided email address. It is therefore important that you update your email address if it changes.
9. Contacting Jumio
If you have any questions or comments regarding our Notice, please send an email to [email protected]. If you prefer to contact us by mail, please write to Jumio Corporation, ATTN: Jumio
100 Mathilda Place, Suite 100, Sunnyvale, CA 94086.
Showcase Application Terms of Service (Ver. 01.01.22)
These Showcase Application Terms of Service (“Terms of Service”) between you (“You”) and Jumio Corporation (“Jumio”) govern your use of the Jumio Showcase mobile application and its related services and software (collectively, the “Showcase App”).
Your use of the Showcase App is subject to Your compliance with these Terms of Service.
2. AGE REQUIREMENTS FOR GENERAL USE OF THE SHOWCASE APP. Use and participation of the Showcase App is restricted to those individuals who are at least 18 years of age and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations and warranties herein.
3. LICENSE; RESTRICTIONS ON USE.
a. License to You. Subject to Your compliance with these Terms of Service, Jumio grants You a worldwide, non-exclusive, non-transferable, non-assignable, revocable license to access and use the Showcase App solely for Your personal use. Jumio reserves all rights in the Showcase App not expressly granted in this Section.
b. License to Jumio. You grant Jumio a worldwide, perpetual, irrevocable, royalty-free license to use, reproduce, modify, create derivative works from, distribute, transmit, and display the information You transmit to the Showcase App (including any rights specifically pertaining to biometric information) to develop, provide and improve the Showcase App, including the right to grant equivalent rights to Jumio’s service providers in order to provide the services under the Showcase App and data Jumio derives from your use of the Showcase App, in anonymized and aggregated form, to compile statistics regarding the Showcase App and to develop and improve the Showcase App including through machine learning techniques.
c. Restrictions on Use. You agree that you will not:
i. attempt to interfere with or disrupt the Showcase App or attempt to gain access to, or conduct penetration tests of, any systems or networks that connect to the Showcase App (except as required to use the Showcase App);
ii. decompile, disassemble, or otherwise reverse engineer or attempt to reconstruct or discover, in any way, any source code, programming, algorithms, design structure or interoperability interfaces of the Showcase App, for any purpose;
iii. remove or modify any of the Showcase App’s identification markings, including copyright, trademark and other intellectual property notices;
iv. make any modification or enhancement to the Showcase App;
v. copy, sell, resell, OEM, lease, assign, distribute or transfer in any manner, in whole or in part, the Showcase App or use the Showcase App for any purpose other than Your personal use;
vi. use the Showcase App or any Jumio information to develop or distribute a competing product or service for either for Your own use or third party use, re-use the results, or otherwise use the results provided by the Showcase App to create a digital identity or other identification of users independent of the Showcase App; and
vii. allow unauthorized persons to access the Showcase App.
4. INTELLECTUAL PROPERTY OWNERSHIP. As between You and Jumio, Jumio owns the Showcase App and all copies, improvements, modifications and derivative works thereof, and all Intellectual Property Rights (as defined below) relating thereto are and shall remain the exclusive property of Jumio or its licensors. You agree that the Showcase App constitutes and contains valuable proprietary information and trade secrets of Jumio. “Intellectual Property Rights means all intellectual property rights protected by law throughout the world, including all copyrights, trademark rights, patent rights (including the right to apply for), patent applications (including the right to claim priority under applicable international conventions), inventions (whether or not patentable), know-how and trade secrets, as may exist now and hereafter come into existence.
5. DISCLAIMER OF WARRANTIES. EXCEPT AS EXPRESSLY PROVIDED HEREIN, THE SHOWCASE APP IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, JUMIO SPECIFICALLY DISCLAIMS ALL OTHER WARRANTIES, EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, GOOD TITLE, NONINFRINGEMENT, OR SATISFACTORY QUALITY REGARDLESS OF WHETHER IMPOSED BY CONTRACT, STATUTE, COURSE OF DEALING, CUSTOM OR USAGE, OR OTHERWISE. JUMIO DOES NOT MAKE ANY REPRESENTATIONS OR WARRANTIES THAT ACCESS TO THE SHOWCASE APP WILL BE CONTINUOUS, UNINTERRUPTED, TIMELY, OR ERROR-FREE. Without limiting the foregoing, You assume sole responsibility and liability for results obtained from use of the Showcase App and Jumio shall have no liability for any claims, losses or damages caused by errors or omissions in any information You provide to Jumio.
6. LIMITATION OF LIABILITY You acknowledge and agree that Jumio will not be liable under any circumstance to You or any other party, person, or entity for any damages or losses that may result from the following: (i) termination, suspension, loss or modification of the Showcase App; (ii) use or inability to use the Showcase App; (iii) access delays or access interruptions to the Showcase App; (iv) data non-delivery, mis-delivery, corruption, destruction or other modification; (vi) loss or liability resulting from errors, omissions or misstatements in any and all information or services provided; (vii) loss or liability resulting from unauthorized use or misuse of Your username or password; (viii) violation of any third party rights, including, but not limited to, rights of publicity, rights of privacy, intellectual property rights and any other proprietary rights; and (ix) any other matter relating to Your use of the Showcase App.
IN NO EVENT SHALL JUMIO BE LIABLE TO YOU OR ANY OTHER PARTY FOR ANY INCIDENTAL, SPECIAL, EXEMPLARY OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING LOSS OF INCOME, DATA, PROFITS, REVENUE OR BUSINESS INTERRUPTION, EVEN IF SUCH PARTY WAS ADVISED, OR SHOULD HAVE KNOWN, OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL JUMIO’S TOTAL AGGREGATE LIABILITY TO YOU EXCEED FIVE HUNDRED DOLLARS ($500) REGARDLESS OF THE FORM OR THEORY OF THE CLAIM.
7. ARBITRATIONS OF DISPUTES. “Disputes” are defined as any claim, controversy, or dispute between you and Jumio, its processors, suppliers or licensors (or their respective affiliates, agents, directors or employees), including any claims relating in any way to these Terms of Service.
You and Jumio agree to arbitrate any and all Disputes by a neutral arbitrator who has the power to award the same individual damages and individual relief that a court can. ANY ARBITRATION UNDER THESE GENERAL TERMS WILL ONLY BE ON AN INDIVIDUAL BASIS; CLASS ARBITRATIONS, CLASS ACTIONS, REPRESENTATIVE ACTIONS, AND CONSOLIDATION WITH OTHER ARBITRATIONS ARE NOT PERMITTED. YOU WAIVE ANY RIGHT TO HAVE YOUR CASE DECIDED BY A JURY AND YOU WAIVE ANY RIGHT TO PARTICIPATE IN A CLASS ACTION AGAINST JUMIO. If any provision of this arbitration agreement is found unenforceable, the unenforceable provision will be severed, and the remaining arbitration terms will be enforced (but in no case will there be a class or representative arbitration). All Disputes will be resolved finally and exclusively by binding individual arbitration with a single arbitrator (the “Arbitrator”) administered by the American Arbitration Association (https://www.adr.org) according to this Section and the applicable arbitration rules for that forum. The Arbitrator shall be responsible for determining all threshold arbitrability issues, including issues relating to whether the Showcase App’s Terms of Service (or any aspect thereof) are enforceable, unconscionable or illusory and any defense to arbitration, including waiver, delay, laches, or estoppel. Any arbitration hearing will occur in Santa Clara, California, or another mutually agreeable location. The arbitrator’s award will be binding on the parties and may be entered as a judgment in any court of competent jurisdiction. While an arbitrator may award declaratory or injunctive relief, the Arbitrator may do so only with respect to the individual party seeking relief and only to the extent necessary to provide relief warranted by the individual party’s claim.
8.1 NOTICE. All written notices required under this Agreement shall be sent by registered or certified mail (return receipt requested), personal delivery, or overnight commercial carrier to Jumio at the address set forth below. The notice will be effective as of the date of delivery.
100 Mathilda Place, Suite 100
Sunnyvale, CA 94086
Attn: General Counsel
|With a copy to: [email protected]
Alternatively, Jumio may also communicate with You by email sent to the most recent email address provided to Jumio by You or by direct mail to Your last known mailing address. All notices shall be effective upon transmission by us. However, in no event shall we be liable to You for choosing to send notice in one manner or format over another.
8.2 EXPORT CONTROL. You agree that your use of the Showcase App is subject to your compliance with all export control laws including, without limitation, the United States Export Control Act, any regulation thereunder, and any similar United States law or regulation.
8.3 THIRD PARTY BENEFICIARIES. There are no third-party beneficiaries to this Agreement.
8.4 SEVERABILITY. If any provision of these terms of Service is determined by a court of competent jurisdiction to be invalid or unenforceable, it will be severable from the remainder of these Terms of Service, will not cause the invalidity or unenforceability of the remainder of these Terms of Service, and will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under applicable law.
8.5 WAIVER. Neither party waives any rights by delaying or failing to exercise such rights at any time.
8.6. GOVERNING LAW. Subject to and without waiver of the arbitration provision above, You agree that these Terms of Service shall be construed according to and governed by the laws of the State of California, U.S.A., without giving effect to its rules regarding conflicts of law. The United Nations Convention on Contracts for the International Sale of Goods is expressly disclaimed. The Parties agree to exclusive jurisdiction of the state or federal courts located in Santa Clara County, California, U.S.A.