Last Updated: February 19, 2015
"Personal Information" means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller. WHAT TYPES OF INFORMATION DOES IDIFIER GATHER ABOUT ITS USERS?
1. Information that you give us
We receive, store and process information that you make available to us when accessing or using our Platform. Examples include when you:
fill in any form on the Platform, such as when you register or update the details of your user account;
access or use the Platform, such as to upload your ID documents, bill documents, create Profile Links, audit ID information, post comments or reviews, or communicate with other users;
link your account on a third party site (e.g., Facebook) to your IDifier, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you; and
communicate with IDifier.
2. Mobile Data
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details.
3. Log Data
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with IDifier or logged in to your IDifier account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.
4. Cookies, and other Tracking Technologies
Our Platform may use social plugins which are provided and operated by third-party companies, such as Facebook's Like Button.
We use and process Information about you for the following general purposes:
to enable you to access and use the Platform;
to operate, protect, improve and optimize the Platform, IDifier's business, and our users' experience, such as to perform analytics, conduct research, and for advertising and marketing;
to help create and maintain a trusted and safer environment on the Platform, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;
to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
where we have your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information sent on behalf of our business partners that we think you may find interesting. You will be able to unsubscribe or opt-out from receiving these communications in your settings (in the "Account" section) when you login to your IDifier account;
to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by IDifier or our business partners; and
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
HOW IDIFIER USES AND PROCESSES USER COMMUNICATIONS
We may review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Guests to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug product offerings. We will not review, scan, or analyze your communications for sending third party marketing messages to you. We will also not sell these reviews or analyses of communications to third parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that IDifier, in its sole discretion, may review, scan, analyze, and store your communications, whether done manually or through automated means.
WHEN IDIFIER DISCLOSES OR SHARES PERSONAL INFORMATION, AND TO WHOM
IMPORTANT: When you use the Platform, your data may be sent to the European Union and possibly other countries We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area ("EEA") including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
Your Personal Information may be disclosed as follows:
Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for identity verification purposes.
You may link your account on a third party social networking site to your IDifier account. We refer to a person's contacts on these third party sites as "Friends". When you create this linkage:
some of the information you provide to us from the linking of your accounts may be published on your IDifier account profile;
your activities on the Platform may be displayed to your Friends on the Platform and/or that third party site;
the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes.
The publication and display of information that you provide to IDifier through this linkage is subject to your settings and authorizations on the Platform and the third party site.
We may distribute parts of the Platform for display on sites operated by IDifier's business partners, using technologies such as HTML widgets.
We may also engage third party companies and individuals, who may be located outside of the EEA, to provide services to us, including services to help verify your identification or to conduct checks against databases such as public government databases (where legally allowed). We may provide Personal Information about you to these third parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. We will ensure that such third parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.
You acknowledge, consent and agree that IDifier may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) respond to claims asserted against IDifier; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, (d) for fraud prevention, risk assessment, investigation, user support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of IDifier, its users or members of the public. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless prohibited by law or by the government request, or if doing so would be futile or ineffective.
We may also publish, disclose and use Aggregated Information and non-personal information for industry analysis, demographic profiling, marketing and advertising, and other business purposes.
BUSINESS TRANSFERS BY IDIFIER
HOW TO CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR IDIFIER ACCOUNT
You may review, update, correct or delete the Personal Information in your IDifier account by logging in to your account. If you would like to cancel your IDifier account entirely, you can do so by logging in to your account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your IDifier account is cancelled.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have implemented reasonable administrative, technical, and physical security measures to protect your Personal Information against the unauthorized access, destruction or alteration of your information. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
Referral service and requesting for references The Platform provides a referral service that allows you to invite other users to use the Platform.
firstname.lastname@example.org FOR USERS RESIDING IN THE EU ONLY: YOUR RIGHTS TO REVIEW AND UPDATE INFORMATION
If you reside in the EU, you may request in writing copies of your Personal Information held by us. We will provide you with a copy of the Personal Information held by us as soon as practicable and in any event not more than 40 days after the request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom). We may also request proof of identification to verify your access request. All requests should be addressed to our Data Protection Compliance Officer (to be determined).
IDifier uses "cookies" in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.
Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies. IDifier cookies and third party cookies
We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes. There are two types of cookies used on the Platform, namely and "persistent cookies" . "session cookies" Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform. Other technologies
The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
Uses for IDifier cookies
to enable, facilitate and streamline the functioning of the Platform across different webpages and browser sessions.
to simplify your access to and use of the Platform and make it more seamless.
to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
to show you content (which may include advertisements) that is more relevant to you.
Uses for third party cookies
http://www.networkadvertising.org/ choices/) and/or the Digital Advertising Alliance ( http://www.aboutads.info/ choices/). You may also be able to control advertising cookies provided by publishers, for example Google's Ad Preference Manager ( https://www.google.com/ settings/ads/onweb/). Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Platform - it just will not be tailored to your interests. In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the IDifier mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app. Disabling Cookies
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser's toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website (
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