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.
In this Policy the following terms shall have the following meanings:
|“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;|
Our Site is owned and operated by KYC AVC LTD, a Limited Company registered in England & Wales under company number 12050874.
Email address: [email protected]
Postal address: KYC AVC LTD , 3rd floor, 86 - 90 Paul St, Hackney, London EC2A 4NE
We are regulated by the Information Commissioner's Office: 12050874 / ZA529836
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.
5.1. 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.
|Data Collected||How We Collect the Data|
|Date of birth||Submitted by you via our Site|
|Your image||Submitted by you via our Site|
|Voice recording||Submitted by you via our Site|
|Email address||Submitted by you via our Site & via the eBay API|
|Full Name||Submitted by you via our Site & via the eBay API|
|Full Address (Business & Personal)||Submitted by you via our Site|
|Telephone Number||Submitted by you via our Site & via the eBay API|
|Business Name||Submitted by you via our Site|
|eBay ID||From the eBay API|
|eBay purchase(s)||From the eBay API|
|Date and time of eBay purchase(s)||From the eBay API|
|Images of & pertinent information on government issued identification||Submitted by you via our Site|
|Payment information||Submitted by you via our Site|
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:
|What We Do||What Data We Use||Our Lawful Basis|
|Start the verification process||eBay ID
Date and time of eBay purchase(s)
|We receive this data from the merchant who is selling the product to you. Our lawful basis for processing this data is that it is necessary for the fulfilment of a legal contract (between us and the merchant).|
|Registering you on our Site and communicating with you||Email address
|Our legal basis for processing this data is initially as above (when received via the eBay API) and then the consent you provide when we take you through the verification process.|
|Supplying our services to you.||Date of birth
Images of & pertinent information on government issued identification.
|Our legal basis for processing this data is the consent you provide.|
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.
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.
8.1. 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 (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep It|
|Identity Information including date of birth, full name, images of face, voice recordings, government identification ID images and details.||5 years from the date of last verification|
|Contact information including address, email address, telephone number||5 years from the date of last verification|
|Business information including business name, job title, address, telephone number, bank details, email address||5 years from the date of last verification|
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.
9.1. We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are 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.
b) Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
9.2. 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.
9.3. 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:
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) from them 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 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.
11.1. 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).
12.1. 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.
13.1. 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.
14.1. 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.
Email address: [email protected]
86-90 Paul 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.