Smile Identity Privacy Policy

We collect information from you directly when you provide it to us through the Services. We may also collect information about you from third parties pursuant to your permission or consent. We further automatically collect certain information about you and your smartphone or other device when you use, access, or interact with our Services. Additionally, we collect information when you use any of the devices related to our ID verification and KYC services.

Personal information provided directly by you through the Site. We collect personal information from users who create an account on the Site, login to their account on the Site, or apply to a job with us. We may collect the following categories of information from these users:

• Full name
• The password you create for your account
• Email address
• Phone number
• Organization name
• Information about your customers
• Payment card information
• Resume information (including experiences and education information)
• Any personal information you provide in your cover letter
• Information we collect through your social media profiles or personal website

Personal information collected through our identity verification or KYC services. Additionally, we may collect the following categories of information about users who are subject to our identity verification or KYC services through our partners:

• Full name
• Contact Information
• Biometric information (facial geometry)
• Government ID number (from a national database)
• A photo of your face (selfie)

Server logs. Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Site on a particular time and day and collect information such as your device ID or IP address.

Cookies. We also use cookies on the Site. Cookies are small files that are stored on your device through the Site. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your device’s operating system, your device ID, IP address, and your general geographic location.

Pixel tags. A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email.

SDKs and mobile advertising IDs. Our Services may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your activity. In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your mobile device over time for advertising purposes.

Third-party plugins. Our Site may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.

Third-party online tracking. We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set pixels and mobile advertising IDs through the Site. This information may be used for a variety of purposes, including analytics and interest-based advertising, as discussed below (see the section entitled “With Whom and Why We Share Your Information”).

Aggregated or de-identified information. We may also share aggregated or de-identified information about users of the Services, such as by publishing a report on trends in the usage of the Services. Such aggregated or de-identified information will not identify you personally.

We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.

The purposes for which we use your information include to:

• Provide you with our Services;
• Respond to your questions or requests concerning the Services;
• Fulfill the terms of any agreement you have with us;
• Fulfill your requests for our Services or otherwise complete a transaction that you initiate;
• Send you information about our Services and other topics that are likely to be interest to you, including newsletters, updates, or other communications, including promotional emails;
• Improve our artificial intelligence and machine learning;
• Deliver confirmations, account information, notifications, and similar operational communications;
• Improve your user experience and the quality of our products and Services;
• Comply with legal and/or regulatory requirements;
• Aggregate and de-identify information;
• Serve advertisements;
• Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services;
• Create new products and Services; and
• Manage our business.

We share your information with third parties for a variety of purposes, as described below.

Businesses who sign up for our Services. If you are subject to our Identity Verification or KYC services, we may share information about your identity verification status with the businesses who utilize those services from us (and with whom you have a direct business relationship). In addition to this privacy policy, the information that is collected from you in those contexts may also be governed by those businesses’ privacy policies.

Third-party service providers. Smile Identity uses third-party service providers that perform Services on our behalf, including web-hosting companies, and mailing vendors. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above. We may also share your information with third parties when necessary to fulfill your requests for Services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access device IDs and IP addresses from your device.

Interest-based Advertising. The Services also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties, such as Facebook, may use the fact that you visited our App to target online ads to you about our Services. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your mobile activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Site currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

You may also opt-out of interest-based by adjusting the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads). Additionally, you may opt out for companies that participate in the Digital Advertising Alliance's AppChoices tool by downloading it here and following the instructions in the app.

Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

• To comply with applicable law or a court order, subpoena, or other legal process;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
• To establish, protect, or exercise our legal rights or defend against legal claims; or
• To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

If you wish to access, correct, or delete the personal information we have on file, you may contact us at compliance@smileidentity.com

If you are a resident of the EU, UK, or another jurisdiction with an applicable privacy law, you may have certain rights available to you. These rights may include:

• The right to be informed about our data collection practices;
• The right to access and rectify your data;
• The right to erase or delete your data;
• The right to data portability;
• The right to restrict and object to the processing of your data (including for direct marketing purposes);
• The right to opt-out of marketing emails and text messages;
• The right to limit our use of any automated decision-making processes;
• The right to lodge a complaint to your local data protection authority; and
• The right to withdraw consent (to the extent applicable).

To exercise any of the rights listed above, please contact us via email at complinace@smileidenityty.com. We will respond to your request as soon as reasonably possible but no longer than 30 days.

We employ physical, technical, and administrative procedures to safeguard the personal information we collect both online and offline. However, no website or platform is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.

We employ physical, technical, and administrative procedures to safeguard the personal information we collect both online and offline. However, no website or platform is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

The information that we collect through or in connection with the Services is transferred to and processed in the United States of America for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. However, we comply with all applicable laws regarding international data transfers.

By using the Services or by providing any information to us, you expressly consent to such transfer and processing.

Content on this Services is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.

We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Services, so you should review this page periodically.

Should you have any questions or concerns about this Policy, you can contact us by email at compliance@smileidentity.com .