Privacy Policy

This Privacy Policy applies to personally identifying information accessed and processed by CycurID Technologies Inc. (“CycurID,” “imme™ ”,“we,” “us,” and “our”) in the course of our business as collected from our website (the “Site”), our web and mobile applications (the “Apps”), and our related online and offline offerings (collectively, the “Services”).

We strive to be the leaders in the personal data and identity market. Your privacy is paramount to us, and as this Privacy Policy explains, we treat your personal information quite a bit differently than some of our competitors.

Except for any binary face data required to create a Digital ID (see the paragraph entitled “Face Data” below), WE DO NOT STORE YOUR PERSONAL INFORMATION ON OUR SERVERS. Once you have set up your imme™ account (“Account”), in accordance with our Terms of Use. ALL OF YOUR PERSONAL INFORMATION IS ENCRYPTED AND STORED ON YOUR MOBILE DEVICE AND OUR SERVERS ARE WIPED OF YOUR PERSONAL INFORMATION.

Definitions

“anonymized data” or “data anonymization” is the process of either encrypting or removing personally identifiable information from data sets, so that the people whom the data describe remain anonymous.

“De-identified data” is data which has certain personal identifying characteristics deleted or masked such as personal name or date of birth.

“personal information” or “personally identifying information” means any information that is capable of identifying an individual, such as name, address, phone number, email address, birth date, images, payment information and/or other identifiers.

Personal Information We Require To Review

We review and validate the information that you voluntarily provide to us or authorize us to do so. When you use our Services, and set up an Account we need to access the following categories of personal information to verify and validate who you are and to determine if your personal identification has been compromised:

Contact Information. We will access and validate your name, email address, postal address, phone number, username.

Selfie Images. We ask you to submit selfie images to verify your identity and use it for onboarding.

Identity Information. The App allows you to store various forms of encrypted identification or identification documents and information on your mobile device. This may include your government-issued identification documents (e.g., passport, driver’s license), Social Security number, and other similar documents and information. We will access personal information contained in these documents (e.g., birthdate, gender, address, government-issued identifiers, etc.) and compare to verify your identity and ensure your personal identity has not been compromised.

Biometric Information. We 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 that you provide to us. We use this biometric information for identity verification, fraud prevention and onboarding.

Binary Face Data. More particularly, the imme™ App uses your binary face data to create a Digital ID upon successful account creation and liveness verification. The binary face data is stored on private and secure servers managed by CycurID and cannot be used in any manner to identify you. We do not share this face data with third parties. Users can deactivate their account and request for the data to be deleted.

By accepting our Terms of Use and Privacy Policy and providing us with your selfies and your identification documents, you consent to the extraction and processing of the biometric data contained therein as set forth in this Privacy Policy.

Financial Account Information. Where applicable, we work with Financial Service Providers (FSP’s) to examine and verify information from the financial institution(s) you use. This information includes, but is not limited to, a unique token issued by those FSP’s that allows us to access information from your financial accounts, account information, information about your account balances (including current and available balances), information about account transactions, including amount, date, type, quantity, price, and a description of the transaction, and other information. We may use this information provided by a FSP to verify your financial information and to construct an income/purchasing power score.

We do not store or share your any of your personal financial information in accordance with this Privacy Policy. Information accessed is for verification purposes only and is in accordance with the FSP’s Privacy Policy. All of the financial information provided by your financial institution for verification purposes is done so in accordance with their respective terms and conditions, legal disclaimers and privacy policies.

Communications with Us. We may collect personal information 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 our customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.

Interactive Features. We may offer interactive features such as commenting functionalities, forums, chat services, and social media pages. We 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.

Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in us and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

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 information.

Social Media Site. We may access/collect personal information from your social media accounts such as email address, date of birth, job, pictures in order to further validate your identity or the look for adverse media mentions when using our Services and Apps.

Non-personally Identiying Information We Collect Through Use of the Services

We may collect certain information automatically when you use the Services, engage with our social media pages, communicate with us via email, or otherwise interact with us through alternative digital services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies (as defined below) 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, Web Beacons, and Personalized Advertising. We may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on our Site that allow us to record certain pieces of information whenever you visit or interact with the Services.

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. 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 can 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.

Third parties may also collect information via tracking technologies when you interact with our Services. Third parties will generally include (though not necessarily be limited to) search engines, providers of measurement and analytics services, social media networks, and advertising companies. The use of these Technologies and any information about you that third parties might collect using those Technologies is governed by each third party’s specific privacy policy, not this one. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. This Privacy Policy only addresses the use and disclosure of information that you provide or allow access to during the sign up process either on the App or the Site. The Services, the Site or the App may contain links to other websites/applications and other websites/applications may reference or link to our Services, Site or App. These third party services are not controlled by us and we are not at any time or in any way responsible for the information practices of any third parties. We encourage you to read the privacy policies of each website and application with which you 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.

Information From Other sources

We may collect information about you from additional online and offline sources including commercially available third-party sources, such as consumer reporting agencies, various social media sites for the purposes of verifying eligibility and securely offering our Services to you. We may combine this information with the personal and other information we have collected about you under this Privacy Policy.

We do not knowingly collect your personal information from a third party unless you consent.

We do not knowingly collect your personal information from a third party unless you consent. Notwithstanding the above, we reserve the right to collect your personal information from any third party without your consent if such collection is otherwise exempted, required or permitted by applicable laws to do so. For example, we may collect your personal information without your consent from the following third parties:

• Your authorized representative(s) (for example, your authorized agents, legal representatives or family members that you have authorized to speak to us on your behalf);
• Organization(s) to whom you have previously consented to collect your personal information;
• Public sources in which your personal information is publicly available.

If we collect your personal information from a third party to whom you have previously consented as regards collecting your personal information, we will only process that information for the specific purpose for which it was provided to us in accordance with this Privacy Policy and the policy under which that information was originally collected.

Why We Collect Personal Information and How it may be Used

We may use personal information (prior it to being erased from our servers) submitted by our customers and users as necessary to provide the Services, including updating, enhancing, securing and maintaining the Services and to carry out our contractual obligations to you and our customers.

More particularly, we process personal information for a variety of business purposes, including:
• To provide the Services, products, or information requested.
• Fulfill our contract with you.
• Verify your identity
• Manage your information and IDs.
• Process your payment card and/or other financial information to facilitate your use of the services.
• Respond to questions, comments and other requests.
• Answer requests for customer or technical support.
• Pursue legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention.
• Measure interest and engagement in the Services.
• Develop new products and services.
• Improve our products and Services.
• Ensure internal quality control and safety.
• Carry out audits.
• Communicate with you about activities on the Services and changes to our agreements.
• Prevent and prosecute potentially prohibited or illegal activities.
• Enforce our agreements and comply with our legal obligations.

De-identified and Aggregated Information Use. De-identified and Aggregated Information Use. We may use personal information 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 aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. An example of De- identified and Aggregated Information would be: imme™ has “X” number of female users who reside in Toronto, Canada between the ages of 19 years to 29 years.

Technologies: Our uses of such Technologies fall into the following general categories:

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. We will process your personal information as set out in this Privacy Policy only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed.

By using our Sites, applications, Products and Services, or otherwise by choosing to provide us with your personal information (such as your selfies and identification documents) you acknowledge and consent to the accessing, extraction, and processing of your personal information in accordance with this Privacy Policy and as may be further identified when the personal information is collected. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.

If you do not consent to the processing of your personal information in accordance with this Privacy Policy, please do not access or continue to use any of the Sites, applications, Products and Services or otherwise provide any personal information to us.

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences on your devices, (ii) deleting your Account and ceasing use of our applications, products and services, or (iii) opting out of the use of your personal information such as unsubscribing to any newsletter or mailing list subscription that we provide through the Sites, applications, products and services. However, if you withdraw or change your consent, we may not be able to provide you with the Services.

How we disclose your information

Your personal information may be accessed by or disclosed only to our employees who have a need to know such information as a result of a request by regulatory or law enforcement authorities. Such employees may include staffs from our legal, compliance and/or IT departments.

WE DO NOT SELL YOUR PERSONAL INFORMATION (INCLUDING PLATFORM ACTIVITY AS DEFINED BELOW) OR DISCLOSE IT TO ANY THIRD PARTY MARKETERS. However, information may be shared or disclosed to the parties in the following circumstances:

Business Partners. We may provide de-identified personal information to business partners to provide you with a product or service you have requested or might be interested.

APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with 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 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.

General. You may have the right to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as described below. Upon receiving direction to opt out we will delete all of your personal information from our servers.

Email & Text Communications. We will not send you any marketing or related commercial electronic messages unless you have provided us with explicit consent to send you such emails, which may include commercial electronic messages regarding products or services you have requested. You will always have the option to use the unsubscribe link found at the bottom of any email you receive from us.

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 the App. You may opt-out of this collection by changing the settings on your mobile device.

Affiliates. We may transfer personal information to our affiliates from time to time as permitted by this Privacy Policy.

Business Transactions. We may be involved, from time to time, in transactions to sell all or part of our business or assets or merge with other businesses. Certain information may be relevant to such transactions, in which case we may disclose this information to other parties involved in the transaction. In such cases, the information that is shared is limited to what is necessary to accomplish the transaction, and we take appropriate steps to protect the information from improper use or disclosure. Upon completion of the transaction, your information may be transferred to the purchaser, to be used in the same manner that it was used by us.

Individual rights in personal information

For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information which we hold about you , subject to certain exceptions prescribed by law and technical restrictions inherent in the blockchain. If you would like to exercise any of these rights, please contact [email protected].

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

If you are a California resident, you have the right not to receive discriminatory treatment by us for the exercise of your rights conferred by the California Consumer Privacy Act.

Data Retention

We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, protect against fraud, enforce our agreements, and comply with applicable laws. We delete your biometric information once your account has been set up.

Security of Your Information

We take the steps that we deem are commercially reasonable in an effort to ensure that your information, including data about your interests and payment behavior (the “Platform Activity”) is treated securely and in accordance with this Privacy Policy. The internet is inherently unsecure and we cannot guarantee that any information transacted or transmitted over the internet will ever be 100% secure nor that such information will be secure while in transit to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure of any information transmitted over the internet.

By using the Services or providing personal information 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.

We do not share the Platform Activity with third party service providers that do not need such Platform Activity to provide their specific services to you.

Audit, Regulatory, Legal Enforcement

From time to time we may be requested by law enforcement, governmental agencies, or authorized third parties to verify our verification and validation procedures and to comply with generally accepted Know Your Customer and Anti-Money Laundering protocols, as well as other legal and industry compliance regulations. We may contact you and request you to open your encrypted personally identifying information for review by these parties. Failure to comply with these requests will result in the immediate cessation of Services provided by us and the immediate deletion of your Account. Failure to comply with such requests may be deemed to be a violation of our Terms of Use.

Children’s Information

The Services are not directed to minors under the age of 18 and anyone under the age of 18 may not use the Site without express consent from that individual’s parent or legal guardian. We reserve the right to not grant access to minors under the age of 18. We do not knowingly collect personally identifying information from anyone under the age of 18, and no part of the Site is designed to attract anyone under the age of 18. Because we do not intentionally collect any information from children under the age of 18, we also do not knowingly distribute such information to third parties nor knowingly distribute aggregated and anonymized information. If you have reason to believe that a child under 18 years of age has provided us with information, please contact us at [email protected] and we will immediately take steps to delete such information, subject to and in compliance with applicable law.

Supervisory Authority

If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Limited Liability

Please review our Terms of Use for limitation of Liability.

Changes to Our Privacy Policy

The personal identity market and related technology are rapidly changing. Therefore, from time to time, we will have to revise this Privacy Policy to reflect those changes. Any changes to this Privacy Policy will be posted by us to the Site and Apps, so you should review these pages periodically. If we make a material change to the Privacy Policy, you will be provided with appropriate notice. If we maintain your email address, we also may email you a copy of the revised Privacy Policy at your most recently provided email address. It is therefore important that you update your email address if it changes.

This Privacy Policy was last updated on February 1, 2022.

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at [email protected].