Privacy Notice

TOPPAN IDGATE CO., LTD (“Toppan iDGate”) provides digital identity verification and authentication services via our facial recognition tools iDenFace™ and iDenCard™. The terms “Toppan iDGate,” “we,” “us,” “our” and “ours” when used in this privacy notice (“Privacy Notice”) includes subsidiaries, divisions, branches, affiliates or companies under the control of Toppan iDGate. The terms “you,” “your” and “yours” when used in this Privacy Notice means any user of this Online Services.

IMPORTANT: BY SUBMITTING PERSONAL DATA TO US AND/OR BY USING OUR ONLINE SERVICES, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW.

Scope of Privacy Notice

This Privacy Notice describes our current policies and practices with regard to personal data collected by us from you directly and/or through our Online Services (as defined below). The term “personal data” refers to personally identifiable information about you. This Privacy Notice applies only to the operation of our Online Services via our App “iDenFace™ Authenticator” that directly links to this notice when you click on the Privacy Notice link.

Online Services

We provide digital identity verification and authentication services via our facial recognition tools: iDenFace™ and iDenCard™ (“Online Services”). These Online Services are available to you through our iDenFace™ Authenticator App. By downloading and accessing our iDenFace™ Authenticator App and providing us with your facial profile and personal information in our Online Services, you are agreeing to the use of your personal data and contact information in accordance with this Privacy Notice. We may contact you regarding updates, modifications and additional service offerings. Your access to these Online Services will be retained and used for support, transition, maintenance, service improvements and technical development, as well as to comply with reporting, audit and data retention requirements.

Notification of changes to this Notice

Toppan iDGate is continually improving our methods of communication and adding new functionality and features to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices may change. We encourage you to check this page frequently and anytime you submit personal information via our Online Services or the iDenFace™ Authenticator App.

Collection, Use and Disclosure of your personal data

iDGate as a Data Processor

From time to time, Toppan iDGate may be required to process data that you have uploaded, stored and shared with Toppan iDGate for troubleshooting or further development or improvement of our Online Services internally or with trusted partners. Toppan iDGate does not review or analyze the content of the data. However, it may contain personal data which Toppan iDGate uses/processes to facilitate the troubleshooting, development or improvement of our Online Services.

iDGate as a Data Controller

When you use our products and services or request information, we may request certain personal data about you such as your name, an uploaded photo of your face, your address, e-mail address, and telephone number. We may also ask for demographic information to enable us to provide you with a personalized service. The information you provide is either manually or electronically stored in our databases. We may share your personal data under these limited circumstances:

• In order to provide you with the requested information on products or services, your personal data may be shared with other companies within our group of companies and third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have consented. For example, sometimes a third party may have access to your personal data in order to support our information technology, to supplement, update, or correct the data or provide additional publicly available data, or to handle mailings on our behalf. Toppan iDGate™ requires that all third-party processors process your personal data with the same level of protection and in a manner consistent with the uses agreed upon in this Notice.

• We will keep your contact details on our database and we may use your personal data for marketing purposes and market research. If you do not wish to receive e-mails or post from us for these purposes, please let us know by following the “unsubscribe” procedure described herein.

• We may use your personal data to administer our iDenFace™ Authenticator App and Online Services and help us improve our services.

• We may share your personal data with other companies within our group of companies, who may contact you about their products or services that may interest you.

• We may disclose the information in our databases and server logs to comply with a legal requirement, for the administration of justice, for the purposes of national security only to the extent that is strictly necessary and proportionate, to interact with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or our Online Services, to take precautions against legal liability, or in the event of our sale, merger, reorganization, dissolution or similar event.

• In the event of a corporate sale, merger, reorganization, dissolution or similar event, your personal data may be part of an asset transfer or sale.

Retention

Toppan iDGate retains personal data only as long as necessary to fulfill the stated purposes or as legally required, and thereafter securely destroys such information.

When personal data is no longer necessary or relevant for the stated purpose or to fulfill a legal or business requirement, it shall be securely destroyed. Toppan iDGate will either physically or electronically erase the personal data.

Data Security

We will take every sensible precaution to protect the information we collect from you including physical, technical and organizational procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure. Access to this information is protected both online and off-line.

Anonymous data collected through this Online Services

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Online Services. For example, our Web server automatically logs which pages of our Online Services our visitors view, their IP addresses and which Web browsers our visitors use. This technology does not identify you personally; it enables us to compile statistics about our visitors and their use of our Online Services. Our Online Services contain hyperlinks to other pages on our Online Services. We may use technology to track how often these links are used and which pages on our Online Services our visitors choose to view.

Cookies

In order to collect the anonymous data described herein, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.

Server Location

Toppan iDGate has data servers located in Taiwan and Hong Kong. If you are visiting our Online Services from a country other than the country in which our servers are located, the various communications may result in the transfer of information across international boundaries. If you are accessing our Online Services, the content data will be stored in accordance with the terms and conditions outlined in an agreement. Any personal data will be protected in accordance with this Privacy Notice as well as with adequate protections in place in compliance with applicable laws and standards. By visiting our Online Services and communicating electronically with us, you consent to the processing and transfer of your data as set out in this Privacy Notice.

Enforcement & Dispute Resolution

We will regularly review how we are meeting privacy objectives. If you have questions, requests or complaints about our privacy practices, you may contact us by e-mailing info@toppanidgate.com. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, we agree to participate in the dispute resolution procedures established by the Hong Kong Mediation Center. If necessary, you may submit a complaint to: http://www.mediationcentre.org.hk/en/home. Under certain conditions, you may invoke binding arbitration.

Any dispute arising from or in connection with this privacy notice shall be submitted to Hong Kong Mediation Center for mediation, which shall be conducted in accordance with the Center Mediation Rules in effect at the time of the mediation.

Contact us; mail unsubscribe

If you no longer wish to receive electronic mail, please click the “unsubscribe” link located at the bottom of the e-mail, or, by writing to us at: Toppan iDGate Co., Ltd, info@toppanidgate.com, [Add], Attn: [Name the party to attend on Toppan iDGate’s side/“Opt-Out List Master@IDGate” – *make sure we provide email and designation of person overseeing the opt out for app users.