Under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (“GDPR”), Innovatrics adopts this Privacy Policy.
This Privacy Policy applies to all users (hereinafter “You”) of the IDV Demo Applications (hereinafter “Applications” or “Apps”).
This document provides information on the following:
The Data Controller is Innovatrics, s.r.o., with its registered office at Jurská 14621/19, 831 02 Bratislava, Slovak Republic, Company ID: 36 280 712, registered in the Commercial Register of the District Court Bratislava I, Section Sro., Insert No. 39481/B.
For inquiries regarding data protection, please use the following contact details:
The Applications’ functionality involves identity verification by comparing data from an identity document with a current photo of the individual who is to be remotely verified (the identity document and photo are uploaded via the Applications).
The processing purpose, as determined by the Data Controller, is to demonstrate and showcase the product (biometric digital onboarding solution) offered on the website or in dedicated mobile Applications to interested parties, clients, and potential clients, allowing them to try the IDV (Identity Verification Toolkit) product’s functionality – an online identity verification system.
Your provision of personal data is voluntary and based on prior consideration. Without providing personal data, the Applications’ functionality cannot be used.
During the verification process, a biometric algorithm is used to compare and verify identity by matching biometric data (facial images) from the identity document with a current photo (selfie) uploaded to the Application. The verification result is an automated decision made by the algorithms; however, as the purpose of processing in the Applications is not to produce decisions with legal effects, it does not constitute automated decision-making or profiling within the basis of the GDPR.
The legal basis for processing is the explicit consent of the data subject (Article 6(1)(a) GDPR in conjunction with Article 9(2)(a) GDPR), as biometric data are sensitive. The consent confirmed by checking the consent box or pressing the “Accept” button in the Applications before uploading the documents and photos will be considered Your explicit consent. This consent may be withdrawn at any time by contacting us at the addresses provided above; however, withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
If You are not the data subject whose personal data are uploaded via the Applications, You are fully responsible for ensuring that the data subject has provided their explicit consent for processing their data for this purpose and has been informed of all necessary details for decision-making and granting consent according to this Privacy Policy and the GDPR (including information on recipients of personal data).
Upon uploading a document, we process the scan of the document and personal data, the exact scope of which depends on the type of document and the issuing country. Typically, the Applications process the following data:
After uploading the current photo (selfie), this photo is also processed. We also process information on the device type used to access our service.
Your personal data is processed only for the duration of our research, but no longer than one (1) year from the date of provision. Upon expiration of this period, the data will be deleted within 60 days.
The Apps use AWS cloud solutions (hereinafter “Platform”) provided by Amazon Web Services based in Seattle, Washington, USA. The processing resources (data storage) are located within the European Union. The Amazon services used by the Apps are located in Frankfurt am Main, Germany – location EU-Central 1.
According to GDPR, the Platform provides guarantees, which can be found at https://aws.amazon.com/compliance/gdpr-center/ and also at https://aws.amazon.com/blogs/aws/aws-region-germany/.
The operator of the Platform has no access to personal data.
Personal data will not be disclosed to any third party unless legally required (e.g., in case of a supervisory authority’s audit); they will not be published or transferred to third countries or other organizations.
Innovatrics has implemented adequate technical, organizational, and security measures to protect personal data considering the risks, nature of processing, latest technology, and implementation costs.
Innovatrics supports and conducts research, development, and innovation in the field of technology, aiming not only to enhance its competitive position in the global market but also to address societal needs and expand knowledge. Innovatrics’ objective is for the results of its research and innovation to be directly applicable in economic and social practice, contributing to efficiency, safety, and credibility in technology-based processes.
The purpose of our research, and therefore the purpose of processing personal data in this instance, is the research, development, and improvement of, specifically:
For the aforementioned purposes, it is necessary to process: scans of both/all pages of specific identity documents, which will contain personal data; photographs (including selfies); short videos; and similar data, depending on the type of research project. All personal data are essentially obtained during the use of the Applications’ functionalities.
It is important to note that Your personal data itself is not of interest to Innovatrics or the company’s research. The research focuses on document characteristics—dimensions, structure, shape, color, arrangement of text and image fields, type and size of font used, etc. Additionally, Innovatrics is interested in biometrics from a technological perspective, as the goal is to develop and enhance algorithms for optical character recognition, document recognition, or improving the accuracy of digital verification and liveness detection. The outcome of these activities is a software that does not contain any personal data.
Your personal data will not be recorded in other systems nor used for any purposes other than those specified.
Innovatrics does not engage in automated decision-making or profiling within the meaning of the GDPR.
The database is maintained in electronic form on a platform provided by Amazon Web Services, Seattle, Washington, USA (“AWS”). Innovatrics exclusively utilizes zones located within the European Union. In selecting this storage solution, we considered the security measures provided by Amazon, available at https://aws.amazon.com/s3/security/. The database will be appropriately protected against unauthorized access, damage, destruction, or external attacks. Access to the database is restricted to duly trained individuals bound by a confidentiality obligation regarding personal data.
Personal data will not be disclosed to third parties unless legally required (e.g., in case of a supervisory authority’s audit); they will not be published or transferred to third countries or other organizations.
We regard conducting research as our legitimate interest; however, Your participation in our research and provision of personal data is entirely voluntary and based on Your free decision. Therefore, You are not obligated to provide us with Your personal data, nor will any consequences result from non-provision of it.
As a data subject under GDPR, You have the right:
(i) Upon a written (including electronic) request, to access Your personal data (particularly, You may request confirmation of whether data is being processed, categories of data processed, purpose of processing, source of data, and retention period);
(ii) To rectify inaccurate data and complete incomplete data;
(iii) To restrict processing under Article 18 GDPR (e.g., if data is inaccurate or unlawfully processed);
(iv) To obtain personal data You provided to the Data Controller in a structured, commonly used, and machine-readable format and to transfer it to another controller, under the conditions set out in Article 20 GDPR;
(v) If we process personal data based on Your consent, You have the right to withdraw Your consent at any time; the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal;
(vi) To object in cases specified in Article 21 GDPR (especially against processing for legitimate interests or direct marketing);
(vii) To request the deletion of data where the purpose of processing has ended or in cases specified in Article 17 GDPR.
You may exercise Your rights through our contact details provided above.
If You believe that the processing of personal data violates Your rights or the Data Protection Act or GDPR, You may submit a complaint to Innovatrics, s.r.o. at Jurská 14621/19, 831 02 Bratislava, Slovak Republic; www.innovatrics.com, gdpr@innovatrics.com or to the Slovak Republic’s Office for Personal Data Protection at Hraničná 12, 820 07 Bratislava 27, Slovak Republic; www.dataprotection.gov.sk, statny.dozor@pdp.gov.sk.
The applications placed on the website https://dot.innovatrics.com/, in Google Play Store operated by Google, Mountain View, California, USA and in The App Store operated by Apple, Cupertino, California, USA (hereinafter “Applications” or “Apps”) are operated by
Innovatrics, s.r.o. with registered office at Jurská 14621/19, 831 02 Bratislava, Slovak Republic, Company ID: 36 280 712, registered in the Slovak Republic, by the Commercial Register of the District Court Bratislava I, Section Sro., Insert No. 39481/B.
The term “we” used throughout the Applications and/or these terms of use refers to Innovatrics, s.r.o.
For inquiries regarding data protection, please use the following contact details:
These terms apply to all users of the Applications (hereinafter “You”).
The purpose of the Applications is exclusively to present and demonstrate to interested parties, clients and potential clients the most state-of-the-art solution in the field of biometrics and digital onboarding. In the Apps, Innovatrics provides an opportunity to test the functionality of the IDV solution (identity verification toolkit) – a system for online identity verification. Please note that the Apps are not intended for any provision of services to third parties, do not sell or license any product, serve exclusively as a presentation and demonstration tool and are not intended for regular use. Any use of the Apps for any other purpose, whether commercial or non-commercial, that is not expressly permitted in these terms is expressly prohibited. If You are interested in our product, please contact us at the above contacts.
By accessing the Applications and by any use of the Innovatrics website and its subdomains (including, but not limited to, reading on the site, reviewing its content, using registration or communication forms, using its functionalities, downloading any materials etc.) You agree to accept the following binding terms of use and bind Yourself to abide by these terms of use.
If You do not agree with any of these terms or You do not fulfill the terms mentioned below, do not use the Applications. We are not responsible for any damages or harms that You or third parties incur, or may incur by unauthorized access to the Apps or by non-fulfilling of any of the terms of use of the Apps.
These Applications use cookies. For more details please see our Cookies Policy.
by using the Applications, You acknowledge and consider that:
YOUR OBLIGATIONS
As a user of the Applications, You acknowledge and agree to be bound by the following terms:
The Applications are provided “as is” without any warranty or assurance. We do not guarantee in particular that the Applications or the use thereof or results provided, will meet Your specific requirements, ideas or will be available continuously and uninterruptedly, on a safe, reliable or faultless basis.
Occasionally there may be information on our Apps that contains typographical errors, inaccuracies or omissions. We reserve the right to correct any such errors, inaccuracies or omissions.
The information published in the Apps cannot in any way be regarded as a service, advice or consultation of a legal, economic, technical or other professional nature. Innovatrics is not responsible for any damages caused by the incompleteness, outdatedness of the information or misstatement provided by the Applications.
The Apps and the product contain recognition component(s). Please note that recognitions are inherently statistical processes, and that recognition errors are inherent in the processes. In particular, we do not guarantee that the technology used guarantees 100% face recognition and that the person will be recognized, identified or correctly verified according to the data on the identification document. Neither Innovatrics nor our suppliers are liable for any damages caused by using this technology or by errors in recognition processes.
Innovatrics nor any other person involved in the operation of the Applications are not liable for any damages, losses, loss of profits or consequential, incidental or extraordinary damages caused by the use of the Apps, incorrect or unauthorized use of the Apps, the impossibility of using the Apps, an error on the part of user or Innovatrics, loss of data, records, or denial or cancellation of access to the Apps for any reason.
Applicable law and jurisdiction. The use of the Applications is governed by laws of the Slovak Republic, without regard to its conflict of law principles. Any disputes arising out of these terms of use are subject to the exclusive jurisdiction of the courts of the Slovak Republic.
Innovatrics reserves the right, at its sole discretion, to suspend the availability of the Applications; In this case – if possible – users will be informed in the Applications or by another form of communication.
Innovatrics reserves the right, at its sole discretion, without notice and without any obligation to compensate for any damages or other harm, to terminate or suspend Your access to the Applications at any time.
Innovatrics reserves the right, at its sole discretion, without notice and without any obligation to compensate for any damages or other harm, to delete any content posted or sent to the Applications by the user.
We may change or modify these terms of use at our discretion at any time. If we do so, we will notify You either by posting the modified terms of use in the Applications or by other appropriate means of communication.
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