Privacy Notice - Banqup ID

1. Introduction

We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses the Banqup ID App and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”). Please read this Privacy Notice carefully and ensure that you understand it.

This policy applies where we are acting as a data controller with respect to the personal data of our Banqup ID users; in other words, where we determine the purposes and means of the processing of that personal data.

 

2. Information about us

The Banqup ID App and underlying functionalities is an initiative of Unifiedpost Payments, a limited liability company incorporated and existing under Belgium Law with registered address at Avenue Reine Astrid 92 A, 1310 la Hulpe Belgium and with company number 0649.860.804 referred to as “Unifiedpost Payments” or “we” or ‘us’).

Questions regarding this Privacy Notice can be regarded to the following contact details:  
Data Protection Officer: Mathias Baert
Email address: gdpr@unifiedpost.com

Postal address: Avenue Reine Astrid 92 A, 1310 La Hulpe, Belgium

 

3. What is personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in section 5 of this Privacy Notice.

 

4. What are my rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in section 11.
  • The right to access the personal data we hold about you. Section 10 will tell you how to do this.
    The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in section 11 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in section 11 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to withdraw your consent at any time to a certain data processing activity.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
  • Rights in automated decision making and profiling: We do not use your personal data this way. 

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in in section 11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in section 11.

 

5. What personal data do we process?

In this section we have set out: 

  • the general categories of personal data that we may process;
  • the purposes for which we may process personal data; and
  • the legal bases of the processing.

Depending upon your use of our Banqup ID App, we may collect some or all of the following personal data:

Account data 
We may process your account data ("account data"). The account data includes your email address and phone number. The account data may be processed for the purposes of providing our services (register or identify yourself in the Banqup ID App, login into the application and communicate with you). The legal basis for this processing is the performance of a contract between you and us. 

Identity data
We may process your personal data that are provided in the course of the use of our services ("identity data"). This personal data will be provided by you in the Banqup ID app or can be provided by the (local) identity provider to the extent that you would request the (local) identity provider to provide us with such personal data. Depending on the identification means you choose, the identity data may include all the information available on your official identity document such as your name, date of birth, nationality and national registry number (NRN). The identity data may be processed for the purposes of proving your identity (strong customer authentication) within the entire Unifiedpost ecosystem avoiding to repeatedly ask identification related personal data. 

The legal basis for processing is your consent. Note that if you do not give your consent, you will not be able to use the Banqup ID for the purpose of login in onto the Unifiedpost applications (e.g. Banqup). It remains however possible to create and account and/or login via these applications.

Please also note that when you rely on Banqup ID for identification/authorisation in relation to UPP payment account, Unifiedpost Payments may process and share your personal data with financial or tax authorities on the basis of our AML or other legal obligation UPP will not further process the collected personal data for any other purpose not foreseen in the applicable legislation on this basis.

Biometric data (special category of personal data)
As part of the identity verification process, we may process biometric data through a selfie or video for the purpose of comparing the picture taken from the official identification document presented by you or the (local) identity provider with the liveness check. This biometric data will not be stored but is created and used for the duration of this comparison process. The legal basis for this processing is your explicit consent. 

Metadata 
We may process Metadata containing personal data collected by Banqup ID for the logging operation, evaluation, and improvement of Banqup ID App (e.g. Measuring the frequency of use of the Banqup ID App or investigating crash reports). The legal basis for processing such data is our legitimate interests.

Other
In case of successful identification verification, Unifiedpost Payments will generate technical data which can uniquely identify you. This technical data may consist of a token or security key(s). The legal basis for this processing is the execution of the agreement.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in section 11. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the GDPR (or other applicable data protection laws) and your legal rights.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

 

6. Do you share my personal data?

Use of processor(s)
We are free to rely on data processors (which may include any member of the Unifiedpost group). A processor is the natural or legal person who processes your personal data upon request and on behalf of us, the controller. The processor is required to ensure the security and confidentiality of the personal data. The processor will always act on our instructions. We rely on processors for hosting purposes, and identity verification.

With a view to the optimal protection of your personal data, we have made the necessary contractual arrangements with our processors to ensure that they apply the highest privacy standards. In any event, data processors shall be required to ensure the security and confidentiality of the personal data.

In addition to the above, we may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Transfer of personal data to third parties
In addition to the specific disclosures of personal data set out in this section 7, we may disclose your personal data to identity services providers and where such disclosure is necessary for compliance with a legal obligation to which we are subject. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

7. International transfers of your personal data

We will only store or transfer your personal data within the European Economic Area (the "EEA"). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

 

8. How long will you keep my personal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept until you delete your account or as long as required by mandatory law. Your data personal data will therefore be kept for the following periods:
 
 Type of Data  How long we keep it
 Account data  By deleting the account, the account will be wiped from the backend and then uninstalling the mobile app will remove the user specific data.
 Identity data  3 years unless the account is terminated earlier in which case the data will be deleted.
 Biometric data  Only used during the processing to establish the identity, then discarded. 

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.

 

9. Security of personal data

The security of your personal data is essential to us, and to protect your data we will take appropriate technical and organisational precautions. 

 

  • Encryption 
We encrypt all the data we store with different keys. When you provide personal data online, we use the industry standard for encryption on the Internet – Transport Layer Security (TLS) technology – to help protect the data that you provide. This internet encryption standard scrambles data as they are transferred from your device to our server. We also use digital certificates to ensure that you are connected to authentic channels.

 

  • Data Storage
Email and phone number are stored in the application. All the other personal data, whether used actively or archived, is stored on a server and not the App itself. We use secured servers located  in the European Economic Area to store the data.

 

  • Restricted Access
Internal access to the personal data is limited on a strict ‘need-to-know’ basis. Only authorized personnel, whose activity will be monitored to prevent any misuse, will be able to access the personal data.

 

10. How can I access my personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
 
All subject access requests should be made in writing and sent to the email or postal addresses shown in section 11 (How do I exercise my rights?).
 
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
 
We will respond to your subject access request within 15 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

11. How do I exercise my rights?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:  
Email address: gdpr@unifiedpost.com

 

12. Personal data of children

The Banqup ID App targets persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data. 

 

13. Changes to this Privacy Notice

We reserve the right to change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change the functionalities in the Banqup ID App in a way that affects personal data protection and privacy.

We will inform you of any such change via the Banqup ID App and/or other channels which we deem appropriate at least 30 days before the change becomes effective. Such information will contain the change itself and the reason why we made such change and the date when such change becomes effective. In the event that you have any questions in relation to such change, you may contact us using the details in section 11.