Privacy Policy

User Consent

This is where you have given Us explicit consent to process Personal Data for a given purpose. For example, if you create a User Account on ZinID or where the Client has obtained consent from you.

Contractual Necessity

This is where We have to process Personal Data to meet Our contractual obligaMons to you.

Legal Obligation

This is where We have to process Personal Data in order to comply with the law.

Protection of vital interests

This is where We are constrained to process your Personal Data in order to protect your interests or those of another person, such as to prevent idenMty then.

Public Interest

This is where there is an overriding public interest or We have been vested with an official public mandate to take certain acMon in the interest of the public.

A legitimate business interest:

This means Our interest in conducMng and managing Our Services to enable Us to give you the best service or product and the best and most secure experience. We make sure we consider and balance any potenMal impact on you and your rights before We process your Personal Data for Our legiMmate interests. We do not use your Personal Data for acMviMes where Our interests are overridden by the impact on you unless we have your consent or are otherwise required or permiWed to by law.

Other Legal Purposes:

• Where it’s not prohibited by applicable laws and provided we have permission from our Clients, we may process some personal data, including biometrics, to develop and improve identity verificaMon services to prevent and detect fraud and other illicit activity as part of substantial public interest via machine learning;

• Given the nature of our Services, we are to detect and prevent criminal acMvity, fraud, and money laundering by checking the provided User data against records of confirmed or suspected illegal acMvity, fraud or money laundering. If any sign of this appears, we will inform our Clients of this.

• In connecMon with the purpose above, we may also conduct profiling, staMsMcal analysis, and analyMcs in AML/CFT tendency, fraud detecMon, and prevention. Our system may aggregate Users’ data to generate reports and charts our Clients may use when assuming the risk likelihood associated with specific characterisMcs;

• We can process Personal data, including biometric data, to idenMfy a User or a Client’s representaMve for idenMficaMon purposes to process data subject access request or the Client’s request accordingly;

• We sometimes may be obliged to process or retain all or part of Personal data for the establishment, exercise, or defence of legal claims;

If we disclose your Personal Data, to the extent reasonably pracMcable and permissible, we will require its recipients to comply with adequate privacy and confidenMality requirements and security standards.

Zinary applies the principle of “data minimizaMon” to the collected Personal Data, so that the Personal Data collected by Us is anonymized by default.

Onboarding and Compliance

When onboarding users, ZinID employs an AI-driven platform designed to streamline and secure the onboarding process. This platform serves as a centralized Know Your Customer (KYC) validaMon and management system, allowing users to securely store, manage, and share their credentials, documents, and idenntity informaMon. Users are assigned a unique eight-digit ID number and a biometric identfier, enabling them to easily retrieve and reuse their informaMon across multiple pladorms. ZinID also applies real-Mme authenMcaMon and re- verificaMon features to maintain the protecMon and accuracy of digital records for both customers and businesses, enhancing the overall user experience and security.

Fraud detection

• ZinID implements a fraud detecMon and control network based on the anti-fraud checks required by our Clients and those included in our Services by default. Such checks require collecting, analysing, and re-using recorded User data.

• Generally, ZinID verifies whether a User’s attributes—geolocation (IP address), device signature (operaMng system and camera name), email address, or mobile phone—have previously been involved in or related to any fraudulent acMvity or may currently signal suspicious behaviour paWerns and otherwise point out that the User is fake. At a Client’s order, we may check informaMon with our Data Providers on AML/CFT regulaMons requirements, such as screening through adverse media mentions match or checking for residency in high-risk countries.

Fraud Scoring on IP Adress

ZinID evaluates the risk level of users by analysing their IP addresses, with fraud scores ranging from 0% to 100%. For every Mme a user aWempts to sign up on a Client’s pladorm through ZinID, ZinID collects the user's IP address and performs a fraud assessment on the IP address. Based on this assessment, the IP address is assigned a fraud score. This score helps in monitoring and reporMng potenMal fraudulent acMviMes linked to the IP address. If a user with a high fraud score tries to onboard to a new pladorm, ZinID will automaMcally flag the user's registraMon and keep the vendor informed of the high risk user. This feature is intended to safeguard Client’s systems by miMgaMng the risks associated with fraudulent acMviMes.

IdenIty VerificaIon Checks

• We conduct identity verificaMon checks on behalf of Clients; however, we do not make any final decisions. Our role is to provide Clients with reports containing informaMon about the idenMty verificaMon process and results (with the reasoning behind them reflecMng the level of fraud or another risk, if any). The reasons are derived from the work of our system and its algorithms, including those based on a symbiosis of machine learning models and human supervision and intervention. The final decision on a User onboarding is made by a human on the Client’s side when the checks' result is transmiWed to the particular Client. Clients consider this informaMon while deciding to accept or decline a User applicaMon, request further checks, or conMnue to service that User following their risk assessment and investigations.

• Certain ZinID checks may be fully automated due to simplicity, using machine learning, or Clients’ request. When Clients use check results to make final decisions regarding Users undergoing verificaMon, Clients may automate the final decision-making process. When Clients make automated decisions, including those based on our check results, they shall inform you of the legal grounds and, if necessary, obtain your consent. Any User can appeal automated decisions by reviewing the methods provided on a Client's side.

• This means we may automaMcally decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true idenMty. You have rights in relaMon to automated decision making as set out in clause 19.

• If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, our Clients may refuse to provide the services or financing you have requested, or to employ you, or they may stop providing exisMng services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

KYC and Re-KYC ValidaIon

The ZinID system has a feature that allows for an ongoing KYC. The KYC feature not only verifies provided data with existing data, but also conMnues to revalidate such data across the network each time an identity is presented and re-presented within the network for KYC. Therefore, the system allows for continuous revalidation of identity across all platforms to make sure that changes or updates to a user's data is reflected across the entire network instantly. With this feature we will periodically update KYC information across the entire ZinID network, allowing us to complete the task of updating accurate customer data and ensuring compliance with regulatory requirements in real Mme on behalf of the Clients.