Civic Technologies, Inc. (“Civic,” “we,” “us,” and “our”) provides a software-as-a-service permissioning product (the “Civic Pass Product”) to website and software platform developers, owners, and operators (the “Customer”). Customer integrates the Civic Pass Product with the Customer owned or operated website or software platform (“Customer Property”) to control access to the Customer Property. An end user that accesses or otherwise uses a Customer Property, whether on their own behalf or on behalf of any third party, is a “Customer Property User”. The Civic Pass Product enables the verification of Customer Property User’s identities (as further defined below). Civic may process Customer Property User Information itself to perform Verification, or Civic may facilitate the transfer of Customer Property User Information to a Third Party Processor to perform Verification. With respect to any Customer Property User, “Verification” means (1) confirmation that the provided Verification Data matches the applicable Identity Document and other identity information collected, (2) Verification Data was screened against Sanction, Politically Exposed Person (“PEP”), and Adverse Media Listings, (3) the Customer Property User’s IP address was checked, (4) the Customer Property User’s cryptocurrency wallet ownership was confirmed, and/or (5) the Customer Property User’s business information was confirmed.
IMPORTANT: Part of our Services involve determining your eligibility to receive a Civic Pass. We determine this eligibility by automatically comparing your Personal Data, including biometric information, against criteria set by the Customer. By using the Services, you explicitly consent to this automated decision-making, including our use of biometric information in making this decision. In some cases, you may be able to object to this sort of automated decision-making by contacting us.
PERSONAL DATA WE COLLECT
When you use our Services, we collect information that alone or in combination with other information in our possession personally identifies you (“Personal Data”). The Personal Data collected during these interactions may vary based on what you choose to share with us and whether you create an account, but it will generally include:
Information You Provide to Us.
Contact Information. We will collect your name, email address, postal address, phone number, username, and other information which may be used to contact or locate you. If you are representing a company, we will collect the company name, company website URL, company representative’s contact information, company address, registration number, and information about the beneficial owners.
Selfie Images. We ask you to submit selfie images to verify your identity and provide our Services.
Identity Information. Civic allows you to store various forms of identification or identification documents and information via the App. This may include your government-issued identification documents (e.g., passport, driver’s license), Social Security number, and other similar documents and information. Civic will also collect Personal Data contained in these documents (e.g., birthdate, gender, address, government-issued identifiers, etc.).
Company Documents. We may collect entity formation documents and other related information to perform due diligence on a company. Typically this requires collecting government-issued identification documents for Executive Officers and Directors, Shareholders, and individuals managing the account on behalf of the company.
Biometric Information. We and our service providers may use facial recognition technology to extract biometric information contained in facial images that you provide to the Services. For example, we may compare the face on your government-issued photo ID against a selfie image that you provide to us. We use this biometric information for identity verification and fraud prevention.
Wallet Information. As you use the Services, we might collect information about your cryptocurrency wallet(s) to link your Civic Pass to or perform proof of wallet ownership checks.
Communications with Us. We may collect Personal Data from you such as email address, phone number, or mailing address when you request information about our Services, sign up for our newsletter, request customer or technical support, or otherwise communicate with us.
Customer Service and Support. If you interact with Civic’s customer service and support, we may collect the information you provide to our representatives.
Interactive Features. Civic may offer interactive features such as commenting functionalities, forums, chat services, and social media pages. Civic and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and may not be subject to the privacy protections referenced herein.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Data.
Information We Collect Through Your Use of the Services.
We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, access times, location information (including inferred location based off your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with your account and the devices you use.
Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.
Analytics. We may use Google Analytics and other service providers to collect information regarding behavior and demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You may be able opt out of Google’s collection and processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.
Information from Other Sources.
HOW WE USE YOUR INFORMATION.
We may process Personal Data for a variety of business purposes. Under certain data privacy laws, our use of your data may be allowed under certain legal bases. The legal bases for processing Personal Data are
- Consent – your freely given, specific, informed and unambiguous indication of your wishes by which you agree to the processing of Personal Data.
- Contract – We need to process your Personal Data for performance of a contract or processes the information at your request prior to entering into a contract.
- Legal Obligation – Processing is necessary to comply with a legal obligation.
- Vital Interests – your (or someone else’s) health, safety or other vital interests require processing Personal Data.
- Public Interest – We need to process Personal Data to carry out a task that’s in the public interest.
- Legitimate Interest – Processing Personal Data is in our legitimate interests.
We may process your Personal data for the purposes below for each purpose, the legal basis for our processing is listed in parentheses:
To provide the Services, Products, or Information Requested.
- Fulfill our contract with you (Consent, Contract);
- Verify your identity (Consent, Contract, Legitimate Interest);
- Manage your information (Consent, Contract, Legitimate Interest);
- Send you SMS messages for purposes of authentication (Consent, Contract, Legitimate Interest);
- Process your payment card and/or other financial information to facilitate your use of the Services;
- Respond to questions, comments, and other requests (Consent; Contract);
- Provide access to certain areas, functionalities, and features of our Services (Consent, Contract); and
- Answer requests for customer or technical support (Consent, Contract, Legitimate Interest).
- Research and development (including marketing research), network and information security, and prevention of fraud or misuse of our Service (Consent, Contract, Legal Obligation, Legitimate Interest);
- Measure interest and engagement in the Services;
- Develop new products and services;
- Improve our products and services (Consent, Legitimate Interest);
- Ensure internal quality control and safety (Consent, Legitimate Interest);
- Verify company information and individual identity (Consent, Legal Obligation, Legitimate Interest);
- Carry out audits (Consent, Legal Obligation, Legitimate Interest);
- Communicate with you about activities on the Services and changes to our agreements (Consent, Legitimate Interest);
- Prevent and prosecute potentially prohibited or illegal activities (Legal Obligation; Legitimate Interest);
- Respond to regulatory requests (Legal Obligation Legitimate Interest);
- Enforce our agreements (Legal Obligation, Legitimate Interest); and
- Comply with our legal obligations (Legal Obligation; Legitimate Interest).
De-identified and Aggregated Information Use. We may use Personal Data and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, or other analyses we create. De-identified and/or aggregated information is not Personal Data, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
Technologies. Our uses of Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular behavior, prevent fraudulent activity, and improve security or that allow you to make use of the Services functions.
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services.
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services and keeping track of your specified preferences or past pages viewed.
Consent. Civic may use Personal Data for other purposes that are disclosed to you at the time you provide Personal Data or with your consent.
HOW WE DISCLOSE YOUR INFORMATION.
We may disclose any of the Personal Data we collect about you as set forth below:
Notice Regarding Use of Blockchain. The holdings and transactions associated with a wallet address are publicly available on the blockchain. Therefore, information about your holdings and transactions will be accessible to third parties due to the nature of the blockchain.
Customers. We may share certain Personal Data, such as Contact Information and Identity Information, with Customers that require or request this Personal Data of their Customer Property Users for their own internal legal, business, or other purposes.
Service Providers. We may share any Personal Data we collect about you with our third-party service providers. The types of service providers to whom we entrust Personal Data include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) identity verification and know – your – customer services; (iv) marketing and advertising; (v) payment processing and other similar services; (vi) customer service activities; and (vii) the provision of IT and related services. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
Affiliates. We may share Personal Data with our affiliated entities that control us, are controlled by us, or are under common control with us.
Business Partners. We may provide Personal Data to business partners to provide you with a product or service you have requested. We may also provide Personal Data to business partners with whom we jointly offer products or services.
Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Data if we believe doing so is required or appropriate to: (i) comply with a legal obligation, including law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or legal liability, or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be shared, sold or transferred as part of such a transaction as permitted by law and/or contract.
INTERNATIONAL DATA TRANSFERS.
General. In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. You can also contact us at email@example.com or using the contact information listed below to ask us to update or correct your Personal Data. You may have the right to object to or opt out of certain uses of your Personal Data. Where you have consented to the processing of your Personal Data, you may withdraw that consent at any time by contacting us at firstname.lastname@example.org or using the contact information listed below.
Mobile Devices. We may send you push notifications through our App. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. With your permission, we may also collect precise location information if you use our App. You may opt-out of this collection by changing the settings on your mobile device.
Technologies and Personalized Advertising. If you would like to opt-out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at https://optout.networkadvertising.org/, https://www.youronlinechoices.eu/, and https://optout.aboutads.info/.
Please note you must separately opt out in each browser and on each device.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
SECURITY OF YOUR INFORMATION.
By using the Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an email to you.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect Personal Data from children. If you learn that your child has provided us with Personal Data without your consent, you may contact us at email@example.com. If we learn that we have collected any child’s Personal Data in violation of applicable law, we will promptly take steps to delete such information.
INTERNATIONAL PRIVACY RIGHTS.
Under certain data privacy laws, including the General Data Protection Regulation for users in the EEA, you may have the right to exercise certain privacy rights available to you under applicable data protection laws. We will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.
- Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain Personal Data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
- Right of access and/or portability. You may have the right to access the Personal Data that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or “port” that data to another provider.
- Right of erasure. In certain circumstances, you may have the right to the erasure of Personal Data that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
- Right to object to processing. You may have the right to request that Civic stop processing your Personal Data and/or to stop sending you marketing communications.
- Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal information.
- Right to restrict processing. You may have the right to request that we restrict processing of your Personal Data in certain circumstances (for example, where you believe that the Personal Data we hold about you is not accurate or lawfully held).
- Right to a manual review of automated decisions. If we have determined you are not eligible to receive a Civic Pass or if your Civic Pass was frozen or revoked based on our automatic decision-making procedures, you may have the right to request a manual review.
- Right to lodge a complaint to your local Data Protection Authority. If you are an EEA resident, you have the right to complain to a data protection authority about our collection and use of your Personal Data.
RESIDENTS OF CALIFORNIA
This section is applicable to residents of California. If you are a resident of California, you have certain rights described below. The following do not apply to individuals who do not live in California on a permanent basis.
Rights Provided By California Civil Code Section 1798.83
A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. We do not disclose personal information to any third party for their direct marketing purposes.
Rights Under the California Consumer Privacy Act
In the past 12 months we have collected the following categories of information about you:
- Identifiers such as your name, address, identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Financial, credit card, or debit card information.
- Characteristics of protected classifications under California or federal law, such as your age and national origin.
- Biometric information.
- Internet or other electronic network activity information.
- Geolocation data.
- Audio, electronic, visual, thermal, olfactory, or similar information.
All such information was collected from sources as described in the section “Personal Data We Collect” and for the purposes described in the section “How We Use Information We Collect”. We only disclose such information to third parties as described in the section “How We Disclose Your Information”. We do not sell personal information.
Under the CCPA, California residents have the following rights:
- Right to know about personal information collected, disclosed, or sold. California residents have the right to request that we disclose what personal information it collects, uses, discloses, and sells. This is called the “Right to Know”. Under the Right to Know, you can request a listing of the types of personal information we have collected about you, the sources of that information, how we use the information (e.g., our business or commercial purposes for collecting or selling personal information), other individuals and business with whom we share personal information, and the specific pieces of personal information that we have collected about you. In certain cases, a Request to Know may be denied, for example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.
- Right to request deletion of personal information about you. California consumers have a right to request the deletion of their personal information that we have collected or maintain. In certain cases, a request for deletion may be denied, for example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing services. If we deny your request, we will explain why we denied it and delete any other information that is not protected from deletion.
- Right to opt-out of the sale of personal information. California consumers have a right to opt-out of the sale of their personal information by businesses. We do not sell personal information, however, so opt-out is not relevant.
- Right to non-discrimination for the exercise of a consumer’s privacy rights. You have a right not to receive discriminatory treatment by us for exercising any of your privacy rights conferred by the CCPA. We will not discriminate against any California consumer because such person exercised any of the consumer’s rights under CCPA, including, but not limited to:
- Denying goods or services.
- Charging different prices or rates for goods and services, including through the use of discounts or other benefits or imposing penalties.
- Providing a different level or quality of goods or services.
- Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, charge a different price or rate, or provide a different level or quality of goods or services, if that difference is related to the value provided to you by your data.
If you would like, you may designate an authorized agent to make a request under the CCPA on your behalf. We will deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us.
HOW TO EXERCISE YOUR RIGHTS
To exercise any of the rights above including under the CCPA, contact us at firstname.lastname@example.org or using the contact information listed below. Please identify yourself and specify your request. If you have a password protected account, we may generally use your account information to verify your identity. If not, we may ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.
We use commercially reasonable efforts to delete your Personal Data as required but may retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.
Civic Technologies Inc.
Attn: Data Protection Officer
548 Market St #45306
San Francisco, CA 94104-5401