Updated on 3rd August 2021
KYC AVC UK LTD understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.verifymyage.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
2. Information About Us
Our Site is owned and operated by KYC AVC UK LTD, a Limited Company registered in England & Wales under company number 12050874. Email address: [email protected] Postal address: KYC AVC UK LTD, 206 Brickfields Business Centre 37 Cremer Street, London, England, E2 8HD. We are regulated by the Information Commissioner's Office: 12050874 / ZA529836
3. What Does This Policy Cover?
4. What Is Personal Data?
4.1. Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
4.2. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
5.1. Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 14 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.
5.2 For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.
5.3 It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
5.4 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
5.5 If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 14.
6. What Data Do You Collect and How?
6.1. Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. You may also interact with other 3rd party providers who process additional data outside that which is listed within the ‘Data Collected (Consumer)’ table below, where this is the case your data is not processed or seen by KYC AVC UK LTD.
|Data Collected (Consumer)||How We Collect the Data|
|Date of birth||Submitted by you via our Site|
|IP address||Submitted by you via our Site|
|Facial image||Submitted by you via our Site|
|Email address||Submitted by you via our Site & via the eBay or vendor website API|
|Full Name||Submitted by you via our Site & via the eBay or vendor website API|
|Full Address (Personal)||Submitted by you via our Site & via the eBay or vendor website API|
|Telephone Number||Submitted by you via our Site & via the eBay or vendor website API|
|eBay or vendor website ID||From the eBay or vendor website API|
|eBay or vendor website purchase(s)||From the eBay or vendor website API|
|Date and time of purchase(s)||From the eBay or vendor website API|
|Images of & pertinent information on government issued identification||Submitted by you via our Site|
|Credit card information||Submitted by you via our Site|
|Payment transaction information||Submitted by you via our Site|
|Bank information||Submitted by you via our Site|
|Social media information||Submitted by you via our Site|
|Voice recording||Submitted by you via our Site|
|Age verification data||Collected via the APIs of our partners|
|Data Collected (Business)||How We Collect the Data|
|eBay Seller or vendor website ID||From the eBay or vendor website API|
|Email address||Submitted by you via our Site|
|Full Name||Submitted by you via our Site|
|Full Address (Business)||Submitted by you via our Site|
|Payment information||Submitted by you via our Site|
|Business Name||Submitted by you via our Site|
|Telephone Number||Submitted by you via our Site|
|VAT Number||Submitted by you via our Site|
|Bank Details||Submitted by you via our Site|
|Company Registration Information||Submitted by you via our Site|
7. How Do You Use My Personal Data?
7.1. Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:
a.) If you are under the minimum age at which you are legally capable of giving consent for your personal data to be shared, we will seek the consent of a parent or legal guardian
|What We Do||What Data We Use||Our Lawful Basis|
|Start the verification process||eBay or vendor website ID Details of eBay or vendor website purchase(s)||We are acting as an appointed processor to the data controller under the terms of our Data Processing Agreement.|
|Registering you on our Site and communicating with you||Email address Full Name Telephone Number eBay or vendor website ID||Our legal basis for processing this data is initially as above (when received via the eBay or vendor website API) and then the consent you provide when we take you through the verification process.|
|Supplying our services to you (as a consumer making a purchase)||Date of birth. Your image. Full Address. Images of & pertinent information on government-issued identification. Credit card information. Payment transaction information. Social media information. Voice recording. Email address. Bank information.||Our legal basis for processing this data is the consent you provide.|
|Supplying our services to you (as a business seller)||(all data collected as listed under Data Collected - business, above)||Our legal basis for processing this data is fulfillment of our legal contract with you.|
7.2. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
7.3. We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 14.
The following automated decision-making method(s) may be used:
- using facial and voice biometrics and/or
- scanning and authenticating government issued identification and/or
- performing a soft credit look-up
The following non automated profiling may take place:
From time to time - we and third parties may perform manual age verification
methods for compliance purposes, these methods include:
- Evaluating government issued identification and/or
- Evaluating facial biometrics to estimate age
- From time to time - we and third parties may perform manual age verification methods for compliance purposes, these methods include:
7.4. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 14.
7.5. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
7.6. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
8.1. We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
|Type of Data||Months Held|
|Purchaser Identity Information:|
date of birth, full name, eBay or vendor website ID
|Purchaser Identity Information:|
facial image, Government issued ID image, your voice, social media information, payment transaction information, bank information
address, purchase platform, purchases information, IP address
|Device Information (Anonymous):|
model, browser, version, operating system,
email address, telephone number
business name, contact name, job title, address, telephone number, bank details, email address, VAT information, seller platform ID, company registration information, registration date, number of orders processed, order fulfilment status, sales listing information
*SLA = (Since the date of Last Verification)
^1:100 = 1% of the images are stored for a period of up to 1 month for performance auditing, otherwise not stored.
8.2. Where we believe you are a minor and you have submitted data to us, we will delete it as soon as we are able to do so.
8.3 If we are able to verify your age, for certain details you share with us, we may encode them using a highly secure one-way cryptographic hash, to use for future verification requests, and store for up to 4 years from the date of your last age verification check.
9. How and Where Do You Store or Transfer My Personal Data?
9.1 All data is stored within the EEA.
9.2. We may share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. In such cases we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK. The following safeguards are also applied to such transfers:
a) We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
9.3. Please contact us using the details below in Part 14 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
9.4. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
- procedures for dealing with data breaches (accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
10. Do You Share My Personal Data?
10.1. We share the results of our age verification service with our business customers when you make a purchase (or attempt to make a purchase) to their site and they request that we verify your age.
10.2. We may share your personal data with other companies in our group for our internal business purposes.
10.3. We may sometimes contract with third parties to supply certain services related to our age verification service. This may include sharing any data you have given us or data that we have obtained from a third party source (such as the eBay or vendor website API) to improve the accuracy of our service.
10.4. When any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
10.5. If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
10.7. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
11.1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
12. Can I Withhold Information?
12.1. You may access certain areas of Our Site without providing any personal data at all. However, to use all the features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
13.1. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
13.2. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14.
13.3. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
13.4. We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do I Contact You?
14.1. To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details.
206 Brickfields Business Centre
37 Cremer Street
15.1. We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.