Legal

Privacy Statement

Effective December 5, 2022

Updated March 22, 2024

This Privacy Statement explains the ways Vouched collects, uses, and shares information about you in connection with your access to or use of Vouched’s websites and our products and services (collectively, “Services”), and in connection with any other information we collect when you interact with us, except as outlined in the paragraph below. We hope you will take some time to read this Privacy Statement carefully.  Note that Vouched makes its ID verification and related Services available to third parties (“customers”) for integration into those third parties’ websites, applications and online services, or through the Vouched app.  For personal data Vouched collects, uses, and discloses through these Services and as directed by these customers, under applicable data protection laws, Vouched is a processor or service provider and the customer is the controller or the business with whom your information is being shared.  Vouched does not direct or control how our customers use personal data we collect on their behalf.  Therefore, to fully understand how your information will be handled when you use these Services, you must review not just this Privacy Statement, but also the privacy policies of the third party (or customer) with whom you are dealing directly.

Our Data Practices

• Information We Collect and Categories of Sources
• How We Use Your Information
• Our Lawful Bases for Processing (EEA and UK Only)
• How We Share Your Information

Other Details

• Advertising and Analytics Services Provided by Others
• International Data Transfers and Data Retention
• Your Choices
• Your Data Protection Rights
• Changes to this Statement
• Contacting Vouched

Our Data Practices

Information We Collect and Categories of Sources

Information you provide to Vouched directly

We collect the information you provide directly to us, such as the information you provide when you create a self-serve account, update your account, fill out our “contact us” form, sign up for our emails, request customer support, execute a services agreement, or otherwise communicate with us.  If you are using our Services in order to provide information to, or verify your identity with, our customers we will collect information you provide for this purpose and as requested by our customers.   The types of information we collect include identifiers (such as full name, email address, postal address, phone number, driver’s license, or other government ID, and social security number or taxpayer identification number), other personal data (such as age, gender, and geolocation), professional information (such as company name and title), and any other information you choose to provide (such as date of birth or personal data you may disclose to us in support messages). You may also provide additional information to us, such as identity documents, health or auto insurance cards, or utility bills, so that we can perform identity verification services on behalf of one of our customers.

In addition to the information you provide Vouched directly, we may use standard tracking technologies to collect device information and frequency of interaction with our Services and we may also collect facial or video images. If we collect facial or video images to verify your identity, these images may reveal inferences or special categories of data about you, and we may ask for your consent to use this data about you for a specific purpose that we communicate to you in our Biometric Policy. We may also use two-factor authentication to ensure that the person providing information has possession of the phone number associated with that identity.

Biometric Data Notice

Based on your consent, we may collect and use your biometric information for safety, security, and identification purposes. Please click here to read our Biometric Policy.

Information we collect when you use our Services

When you use our Services, we automatically collect information about you as follows:

• Log Information: We collect log files when you use our Services, which includes identifiers and electronic network activity information, such as the type of browser you use, access times, pages viewed, and your IP address.
• Approximate Location: We derive the approximate location of the device you use to access our Services from your IP address.
• Geolocation: We may collect the latitude and longitude of the device if permission has been granted. We do not implement a geofence.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect identifiers and electronic network activity information when you use our Services, including cookies. Cookies are small data files stored by your web browser, on your hard drive, or in device memory that help us improve our Services and your experience, determine usage of parts and features of our Services, and monitor for and detect potential harmful conduct.   You can find more information about how we use cookies and your related choices in our Cookie Policy.

Information we collect from other sources. If you are a customer, or as directed by a customer, we also collect information about you from other sources. For example, we may collect information from other members of your company and from vendors that help us identify new customers and/or perform our identity verification Services, including identifiers, such as your name, email address, and social media profile URL.

How We Use Your Information

We may use the information we collect for the following business and commercial purposes:

• To provide our Services to our customers;
• To operate, improve, and develop our Services;
• To verify your identity and the identities of other members of your company;
• To comply with law, such as for tax reporting purposes;
• To send you technical notices, updates, security alerts, and administrative messages;
• To respond to your comments, questions, inquiries, and customer service requests;
• To help personalize the Services experience for our customers;
• To communicate with you about products, services, offers, and events offered or sponsored by Vouched, and to provide news and other information we think may be of interest to you;
• To monitor and analyze trends, usage, and activities in connection with our Services;
• To detect and prevent fraud, malicious activity, and other illegal activities;
• To protect the rights, privacy, safety, or property of Vouched and others; and
• For any other purpose described to you when the information was collected.

 

 

Our Lawful Bases for Processing (EEA and UK Only)

Our legal basis for processing the information we collect related to individuals in the European Economic Area (“EEA”) or the United Kingdom (“UK”) will depend on the information concerned and the context in which we collected or processed it. Generally, however, we will normally only collect and process information where:

• we need to fulfill our responsibilities and obligations in any contract or agreement with you;
• to comply with our legal obligations under applicable law; or
• you have given your consent to do so.

 

 

How We Share Your Information

We share information about you as follows, or as otherwise described in this Privacy Statement:

• With our customers, in accordance with our agreement to perform a service for the customers;
• With our data processors and other service providers, partners, contractors, or vendors in connection with the services they perform for us, including to protect the rights, privacy, safety, or property of Vouched or others;
• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena), including in connection with requests from law enforcement or other governmental authorities;
• In connection with a change in ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
• Between and among Vouched and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership; and
• With your consent or at your direction.

We also collect, use, and share aggregated, de-identified, or anonymized information for any purpose permitted under applicable law.

We do not sell or rent personal data that we collect.

In the preceding 12 months, we have disclosed the following categories of personal data for business purposes to the following categories of recipients:

CATEGORIES OF PERSONAL DATA

• Identifiers
• Location information
• Professional information
• Electronic network activity information
• Inferences

CATEGORIES OF PARTIES WITH WHOM PERSONAL DATA MAY BE SHARED

• Analytics services providers
• User research and survey providers
• Providers of internal collaboration and communications tools
• Email service providers
• Customer relationship management, and sales and marketing enablement providers
• Event management and hosting providers
• Customer support services providers
• Lead generation providers
• Document management services providers
• Cloud storage and data warehousing providers
• Payment services providers
• Fraud prevention, identity verification and security services providers
• Software development services providers
• Partners, contractors, and consultants in connection with the services they perform for us
• Professional advisors
• Third parties when compelled by law, such as to law enforcement or other governmental authorities

Other Details

Advertising and Analytics Services Provided by Others

When you visit our website, we allow third parties to provide analytics services and serve advertisements on our behalf across the internet, including Google Analytics. These entities use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information is used by Vouched and these third parties to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and online services, and to better understand your online activity over time and across different websites.

You can find more information about how we use cookies and your related choices in our Cookie Policy.

 

International Data Transfers and Data Retention

If you are a customer, or as directed by a customer, we may transfer the information we collect about you across international borders, including from the EEA or UK to the United States, for processing and storage. To the extent that the information we collect about you is transferred from the EEA or UK to territories/countries for which the EU Commission or UK Secretary of State (as applicable) has not made a finding that the legal framework in that territory/country provides adequate protection for individuals’ rights and freedoms for their personal data, we may transfer such data consistent with applicable data protection laws based on prior assessment of the level of data protection afforded in the context of the transfer, including through the use of the EU Commission-approved or UK Secretary of State-approved (as applicable) standard contractual clauses, if necessary in combination with additional safeguards.

We retain your personal data for no longer than necessary to achieve the purposes for which it was collected, unless a longer retention period is required under applicable law.  Where we process personal data as a “processor” on behalf of a customer (the “controller”), we follow the instructions of the controller regarding data retention. This means that we retain personal data for different periods of time based on those instructions.

 

Your Choices

• Account Information. If you are a customer, you may update information you provide to us as part of your online account by contacting us.
• Cookies. You can find more information about how we use cookies and your related choices in our Cookie Policy.
• Marketing Communications. You may opt in and opt out of receiving marketing emails from Vouched by following the instructions in those emails. If you opt out and are one of our customers, subject to limitations and exceptions provided by law, we may still send you other types of emails, such as those about your account or our ongoing business relations.

 

Your Data Protection Rights

Depending on your jurisdiction, you have certain rights under applicable law regarding the personal data we process, which may include the right to request access or deletion.

In certain jurisdictions, including the EEA and UK, and subject to certain limitations and exceptions, you may have the right to: (i) know how we process your personal data; (ii) request access to or rectification of your personal data; (iii) object to, or request that we restrict, the processing of your personal data; (iv) request that we delete your personal data; (v) request that we provide the personal data you provided to us in a structured, commonly used and machine-readable format, for transmission to another controller; (vi) revoke consent at any time where our processing is based on your consent; (vii) not be subject to a decision based solely on automated processing (profiling) if the processing has a legal effect on you, unless it is necessary for entering into a contract or contractual performance and is authorized by law or based on your explicit consent; and (viii) lodge a complaint with your local supervisory authority (if you’re in the EEA, please see https://edpb.europa.eu/about-edpb/board/members_en, and if you’re in the UK, please see www.ico.org.uk for contact details). Where we process personal data as a “processor” on behalf of a customer (the “controller”), you or Vouched may need to contact the controller regarding these rights.

For Residents of California

If you are a resident of California, subject to limitations and exceptions provided by law, you have the right to: (i) request access to the categories and specific pieces of personal data collected about you in the last twelve months (including personal data disclosed for business purposes and the categories of third parties to whom the personal data was disclosed for a business purpose); (ii) request access to the categories of personal data we sold or shared about you, the categories of third parties to whom the personal data was sold or shared, by category of information,  (iii) request deletion of your personal data; (iv) correct inaccuracies in your personal data; (v) opt-out of any sales of your personal data if a business is engaged in selling your information; and (vi) not be discriminated against for exercising these rights. As we do not sell your personal data, there is no need to submit a request to opt-out.

We will not disclose your personal data to third parties for them to use for their direct marketing purposes unless you agree to us making that disclosure. If you would like to opt-out of our disclosure of your personal data to third parties for their direct marketing purposes, please contact us as described in the “Contacting Vouched” section below.

As described above in “Your Choices,” if you are one of our customers, you can conveniently access your online account information by logging into your account or by contacting us. To otherwise exercise your data protection rights, where applicable, please contact us as described in the “Contacting Vouched” section below. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us as described in the “Contacting Vouched” section below.

As we only perform identity verification services as directed by and on behalf of a customer, you or Vouched may need to contact the customer regarding these rights.

For Residents of Colorado

Consumers may exercise their rights by contacting us as described in the “Contacting Vouched” section below. If 45 days after you send us a request, we have not responded to your request or asked for additional time to respond to your request, you have the right to appeal our failure to take action. To appeal our failure to take action, contact us as described in the “Contacting Vouched” section below.

For Residents of Connecticut

Consumers may exercise their rights by contacting us as described in the “Contacting Vouched” section below. If we inform you that we decline to take action regarding your request, you have the right to appeal our failure to take action by contacting us as described in the “Contacting Vouched” section below within 45 days of receiving our decision.

We encrypt social security numbers in transit, process the social security number, and then delete the social security number. We do not store social security numbers. We limit access to social security numbers to employees that need such access to perform a job function.

For Residents of Utah

Consumers may exercise their rights by contacting us as described in the “Contacting Vouched” section below.

If you would like to opt-out of our use of (1) personal data that reveals your racial or ethnic origin (unless in a video), religious beliefs, sexual orientation, citizenship or immigration status or medical information; (2) genetic or biometric information, if used to identify you; or (3) specific geolocation information, please contact us through the contact information listed below.

For Residents of Virginia

If you are a resident of Virginia, subject to limitations and exceptions provided by law, you have the right to: (i) request access to your personal data in our possession, to either view or transfer it; (ii) confirm our use of your personal data, (iii) request deletion of your personal data; (iv) correct inaccuracies in your personal data; (v) opt-out of a business’ use of your personal data for targeted advertising, the sale of your personal data, or for certain profiling uses; and (vi) the right to appeal our failure to take action if we inform you that we decline to take action regarding your request. To appeal our failure to take action, contact us as described in the “Contacting Vouched” section below within 45 days of receiving our decision.

As we only perform identity verification services as directed by and on behalf of a customer, you or Vouched may need to contact the customer regarding these rights.

 

Changes to this Statement

We may update or change this Privacy Statement periodically. If we make any updates or changes, we will notify you by updating the effective date at the top of this Statement. We may also provide notice of any changes through other means, such as placing a notice on our legal changelog at https://Vouched.id/company/legal/legal-changelog or sending you an email. We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our data practices and the choices available to you.

 

Contacting Vouched

If you have any questions about this Privacy Statement, or our privacy practices generally, please contact us at [email protected] or by mail at:

Woolly Labs, Inc.  DBA Vouched

Attn: Legal

506 2nd Avenue, Suite 1400

Seattle, Washington 98104 U.S.A.

 

If you are in the EEA, you may also contact our representative at:

ePrivacy GmbH

Große Bleichen 21

20354 Hamburg

Germany