Privacy Policy

Online InTouch Limited (Online InTouch Ltd), PRIVACY POLICY

The General Terms below are the full legal terms that serve to protect you and make clear the privacy terms that will apply to all users of the Online InTouch Ltd service. These summary terms below are here to give you a simple explanation of what the General Terms mean in plain English.

Summary

• Personal Information: OnLine InTouch Limited (Online InTouch Ltd or we) temporarily stores your personal information when you use our service. Because of this, we take on the legal responsibilities that come with storing this information. We store your data for a maximum of 7 days before deletion from our systems.
• Deletion of Personal Information: Online InTouch Ltd completely deletes all of your personal information from our system, once the client that has used Online InTouch Ltd to verify your identity downloads this information. It is then the client's responsibility to store your personal information to meet their regulatory requirements.
• Collection and Use of Personal Information: In order to successfully deliver Online InTouch Ltd's service to our customers, we are required to collect and disclose your personal information with our Agents (either the Company requesting your Personal Information, or the entities we use to verify the information supplied) for verification purposes.
• Your Rights: You have the right to access, amend and delete your personal information. The information you are providing, is simply being provided to meet the legislative requirements for Customer Due Diligence to onboard a new Customer.
• Cookies: Our service does not use cookies to collect data.
• Security: We use highly secure cloud services by Amazon Web Services (AWS). AWS provides encryption in transit with SSL across all services.
• Third-party Links: When you click on a third-party link to another site that is not operated by us, we have no control over or responsibility for the content or privacy policies of these other sites.

General Terms

Online InTouch Ltd provides Software as a Service using electronic biometric identification technology (System) to enable Online InTouch Ltd’s business customers (Customers) to verify your identity for Anti-Money Laundering and Know Your Client purposes (Service).

This Policy applies to the use, collection and disclosure of information relating to you recorded in Online InTouch Ltd’s web application (App) or website www.Online InTouch Ltd.com (Website) in connection with the Service (Personal Information).

By using the Service, you agree to be bound by this Privacy Policy. Online InTouch Ltd reserves the right to modify or replace this Policy. Please check the Privacy Policy page at the Website periodically for changes, though we will also notify you via the Service of any changes that we consider materially impact your use of the Service or the treatment of your Personal Information. Your use of the Service following the posting of any changes to the Privacy Policy constitutes acceptance of those changes.

By accessing the Website or or using the App to verify your identity, you consent to Online InTouch Ltd collecting, using and disclosing your Personal Information.

Collection of Personal Information

The nature of the Service means that you disclose to Online InTouch Ltd and our Agents (where applicable) Personal Information.

The Personal Information we may collect or hold about you comprises:

• full name;
• gender;
• address;
• email address;
• telephone number and other contact details;
• date of birth;
• government related identifiers, such as your licence number and class, Medicare number, state or national ID card number, passport number, and birth or marriage certificate number;
• other information identifiable from scanned ID documents you provide, such as your organ donor status or photographs of your face;
• biometric information, such as video footage or photographs of your face;
• information obtained from fraud-prevention services and document verification services;
• your device ID, device type, geo-location information, connection information, IP address and standard web log information;
• Username and password
• any additional information relating to you that you provide to us directly through our Website or App or indirectly through your use of our Website or App or online presence or through other websites or accounts from which you permit us to collect information;
• information you provide to us through customer surveys; and
• any other personal information that may be required in order to facilitate your dealings with us.

We only collect Personal Information that is necessary for: (i) the purpose of providing the Service, (ii) the performance of a contract to which you are a party, (iii) which you have given consent for processing of your data, or (iv) compliance with a legal obligation to which we are subject.

The Personal Information we collect therefore differs from person to person depending on the type of identity documentation verified.

You have no obligation to provide Online InTouch Ltd with any Personal Information requested by us. However, due to the nature of the Service, if you do not to provide us with such information, we will be unable to provide you with the Service and you will be required to provide the necessary Personal and Identification Information for verification through an alternative means provided by the Customer with whom you are trying to do business.

We collect your Personal Information when you:

• request us to act on your behalf via the Website or App;
• provide information about a service issue;
• visit our Website;

We may disclose your Personal Information to our Agents:

• the Customer with whom you are establishing a relationship; and
• Government entities and other external data providers that hold your Personal Information in order to verify that the information you provided is consistent with their records.

Using Personal Information

We understand the importance of using your Personal Information in a responsible and secure manner. Your Personal Information may only be used by Online InTouch Ltd under the following circumstances:

• to verify identification documents against their originating official database;
• to convey your Personal Information to our Customer who will be relying on your verified identification to meet its legal requirements (e.g. solicitor, bank);
• to deal with requests, enquiries, complaints and other customer services;
• to contact you about your account and provide support;
• to comply with any legal, government or regulatory obligation;
• to interact with organisations that Online InTouch Ltd has a business relationship with for the purpose of enabling the performance of the Service or other services you expressly require
• to better understand your needs, diagnose problems, analyse trends, improve the features and usability of the Service; and
• to keep the Service safe and secure.

In using our Service you authorise Online InTouch Ltd to pass on your Personal Information to the Customer who referred you to us in order to use the Service.

Storage of Personal Information

Your data will be held in Amazon Web Services (AWS) by Online InTouch Ltd for a maximum of seven days, following which Online InTouch Ltd will automatically and securely remove the data from the System. Your data will be removed from our System as soon as our Customer retrieves your information to store in its records.

Our Customers that you are working with, are required by the Anti-Money Laundering and Counter Terrorism Finance Act, to verify your identity before they can bring you on as a client. They use the Service to collect and verify your identity to comply with the legislation. They are also required by law to collect and store this information and are audited annually.

We will never sell your Personal Information to anyone.

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including meeting any legal, accounting or statutory reporting requirements.

OnLine InTouch has appointed a Privacy Officer who can be contacted at info@Onlineintouch.com

Your Rights

You can review your data during the workflow and update any errors that might have occurred as the data has been extracted from your identification documentation presented. After this, you will have no ability to access or review your results.

If you want to remove your Personal Information from the System once you have completed the identification process, you will need to email us at info@onlineintouch.com and we will delete it. Once your information is deleted, all your Personal Information will be deleted immediately.

You have the following rights with regard to your Personal Information:

• the right to request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you. If you contact us after 7 days, or after the Customer has downloaded the data to their system, you will need to contact the Customer directly, as Online InTouch Ltd will no longer hold your Personal Information.
• the right to request us to correct your Personal Information if it is inaccurate. You will be able to correct your Personal Information during the Service process. If you have completed the Service with the incorrect information, you must request that the Customer sends you another verification link. You may also supplement any incomplete Personal Information we have, taking into account the purposes of the processing. This will need to be provided directly to the Customer.
• the right to request deletion of your Personal Information if it has not already been saved by our Customer and deleted from our System, in which case you will need to make the request to the Customer directly. Otherwise, if
• your Personal Information is no longer necessary for the purposes for which we collected or processed it; or
• you withdraw your consent if the processing of your Personal Information is based on consent and no other legal ground exists; or
• you object to the processing of your Personal Information and we do not have an overriding legitimate ground for processing; or
• your Personal Information is unlawfully processed; or
• your Personal Information has to be deleted for compliance with a legal obligation.
• the right to object to the processing of your Personal Information. We will comply with your request, unless we have an overriding legitimate interest for processing or we need to continue processing your Personal Information to establish, exercise or defend a legal claim. However, processing is done in real time, so if you complete the verification process then your Personal Information will already have been processed.

To exercise your rights you can email a request to info@onlineintouch.com

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information or to exercise any of your other rights. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request.

Log Data

Whenever you visit the Website, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (IP) address, browser version, pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other statistics. No log data is collected on the App.

Cookies

Cookies are files with small amounts of data that are commonly used as an anonymous unique identifier. These are sent to your browser from the Website and are stored on your device's hard drive.

Our App does not collect or store cookies

Service Providers

We may employ third-parties:

• to facilitate our Service;
• to provide the Service on our behalf;
• to perform Service-related services; or
• to assist us in analysing how our Service is used.

Security

The security of your Personal Information is imperative. We endeavour to employ best practice standards to ensure unauthorised access and disclosure of your information does not occur.
Online InTouch Ltd uses a highly secure AWS cloud service to protect your data. AWS provides encryption in transit with HTTPS and SSL across all services.

Links to Other Sites

Our Service may contain links to other websites. If you click on a third-party link, you will be directed to that site. We strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact our Privacy Officer at info@onlineontouch.com