Personal data protection policy – Innovatrics DOT application

Version: 20th May 2020

Innovatrics s.r.o. provides the Innovatrics DOT App through the App Store. We provide this app free of charge in order to show the verification of the identity with the Innovarics software.

Innovatrics, s.r.o. has developed this Personal Data Protection Policy (“Policy”) to demonstrate our commitment to protect our user’s privacy. The terms “Innovatrics”, “we”, “us” and “our” include Innovatrics, s.r.o. and any subsidiaries. The terms “you” and “your” refer to any individuals and entities who use or visit our services or website, such as Digital onboarding toolkit demo or any other demo web and/or mobile app (later in the policy referred as “Our Services”). Protection of your personal data is essential for us with regard to the adoption of the Regulation of the European Parliament and of the Council (EU) 2016/678 of 27 April 2016 on the protection of natural persons in the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (“GDPR”), we adopt this personal data protection policy. This policy describes our practices, information we collect, how we use that information, with whom your information are or will be shared.

1. THE CONTROLLER AND ITS CONTACT INFORMATION

The Controller is Innovatrics, s.r.o. , with its registered seat at: Pri Vinohradoch 82, 831 06 Bratislava, Slovak Republic, ID No: 36 280 712, registered in the Commercial Register of District Court Bratislava I, Section: Sro, File No. 39481/B.

If you want to communicate with us about personal data protection issues, please use the following contacts: e-mail: info@innovatrics.com or contact us on our office address: Innovatrics, s.r.o., Jarošova 1, 831 03 Braislava, Slovak Republic.

Innovatrics will address your concerns and attempt to resolve any privacy issues in a timely manner.

2.WHAT PERSONAL DATA AND INFORMATION ARE PROCCESSED, USED AND STORED

Innovatrics does not collect personal data and information. We are not interested in receiving and knowing the identity of the people whose identity documents are scanned. However, the app does need to process the personal information that is showed on the identity document via Innovatrics Optical Character Recognition technology (OCR), including:

• privacy- sensitive information such as Name, Surname, Nationality, Sex, ID Number, Date of Birth, Personal No., Date of issue, Date of Expiration, Address, Place of birth, Surname at birth, photo.
• Special category – Nationality and biometric data like face recognition for the purposes of uniquely identifying a natural person

The app processes this information locally on the smartphone and then it sends it to a server for processing. Once, the personal information is processed on the server ,it is returned back to the smartphone. The personal information that is processed is not stored on the server and/or on the smartphone or in the app.
Innovatrics uses servers under its own control.

2.1 What non-personal data and information are processed, used and stored

The app shows the verification of the identity via Innovatrics OCR. We do not process, user and/or store non-personal information such as location, device type or any other usage information.

3. HOW YOUR PERSONAL DATA ARE PROCESSED AND USED

By using the app, you agree and allow that your Personal data and information are sent to Innovatrics servers where it is processed in order to verify your identity. However, your personal information is not stored on the server, on the smartphone or in the app. Innovatrics does not collect or save any data for any purposes on the server or in the app.

3.1 The personal data we collect will be processed for the following purposes:

We process the Personal Information and based on the legal grounds and for legitimate business purposes outlined in this Policy, such as:

• Administrative Purposes – Innovatrics may process your personal information about you for its administrative purposes, including to:
  • Protect the security of our Service and Website and to prevent fraud,
  • To provide Services or Information requested,
  • Ensure internal quality control,
  • Verify individual identity,
  • Process transactions,
  • Prevent potentially prohibited or illegal activities,
  • Enforce our terms of use.

3.2 Disclosure

Innovatrics, s.r.o. will not pass on your personal data to third parties without first obtaining your consent. Please note that Innovatrics, s.r.o. does not share personal information with third parties for marketing purposes or any other purposes.

3.3 Data Transfers

Innovatrics s.r.o. does not store your Personal Information processed and used via or by Innovatrics. Thus, your personal data are not stored in the cloud or on our servers.

4. YOUR RIGHTS

As a data subject under the GDPR, you have the right (i) based on a written (including electronic) request to access your personal data (in particular, to require confirmation whether or not the date is being processed, the category of data being processed, the purpose of processing, the source of the data, and the duration of retention); (ii) to repair the incorrect or supplement the incomplete data; (iii) to restrict the processing under the Art.18 of the GDPR (e.g., if the data is incorrect or processed illegally); (iv) to obtain personal data related to you and which you have provided to the Controller in a structured, commonly used and machine readable format, and the right to transfer such data to another controller under the conditions specified in the Art. 20 of the GDPR; (v) to object in the cases referred to in the Art. 21 of the GDPR; (vi) to the erasure of data the purpose of the processing of which has ended or in the cases listed in the Art. 17 of the GDPR.

You may inquire as to whether Innovatrics is processing personal information about you, request access by sending us an email to info@innovatrics.com or use our address specified in the section 1 to contact us via post.

If you believe that your rights are being violated in the processing of personal data or that there is violation of the Personal Data Protection Act or the GDPR, you may file a motion to initiate personal data protection proceeding at the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27, Slovak Republic; www.dataprotection.gov.sk.

5. SECURITY OF YOUR INFORMATION

The security of your Personal information is important to us. We maintain appropriate safeguards and current security standards to protect your Personal information from unauthorized access, disclosure, or misuse, such as using SSL encryption.

As the processing of personal information is also done on the phone, the confidentiality of this information deepens also on the security of the phone. The app uses encrypted network connections for the communication of usage information.

However, no system can be completely secure, and we cannot ensure or warrant the security of any information you provide to us. While we take meaningful steps to secure your information, we do not promise, and you should not expect, that your Personal information will always remain secure. We do not accept liability for unintentional disclosure.

If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our services.

6. RETENTION

Innovatrics does not retain the Personal information and data that are processed.

7. CHANGES IN THIS PERSONAL DATA PROTECTION POLICY

We may change or modify this PERSONAL DATA PROTECTION POLICY at any time, in particular regarding legislative change in the area of personal data proception which may be adopted in the future.

© 2020 Innovatrics. All rights reserved.