The BindID™ solution (“BindID”, “we”, “our” or “us”) is helping online businesses that have engaged with us (“Customer”) to reduce and prevent fraud or other malicious online activity, as well as enabling a seamless online registration and authentication process. The solution is offered by Transmit Security, Inc. and its affiliates worldwide.
Please note that this Policy only applies to the BindID solution and not to other solutions or services offered by Transmit Security.
- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Security
- Data Sharing
- Cookies and Tracking Technologies
- Data Subject Rights
- Roles and Responsibilities
- Additional Information and Contact Details
1. Data Collection
The data we process regarding our End-Users is typically collected and generated through automatic means, directly from you, through your interaction with us or with our Services; from our Customers, or through third-party services.
Such data may include:
- Direct interactions and communications with us: correspondence with us (e.g., for user experience, support and training purposes), as well as chats, surveys, feedbacks, calls and video recordings, transcriptions, and analyses thereof;
- Account information: name, e-mail address, mobile phone number, and other information used for BindID self-service tenant creation;
- Services usage information: connectivity, technical and aggregated usage data, user agent, IP addresses, unique user ID, device data (such as type, OS, unique device ID, used application and browser, browser version, timestamp, time zone, locale and language settings used), number of devices registered, geolocation, telemetry, canvas sampling, device biometric authentication approval (such as via Apple ID or Samsung Pass), public keys for authentication (if applicable), communication and performance logs, session recordings, issues and bugs, and the cookies utilized on your device.
- Additional Information (“Custom Information”): We may collect additional data related to an End-User that a Customer may request to be processed by Transmit Security on their behalf in accordance with the engagement between the End-User and the Customer. This can include information the Customer deems relevant for the End-Users’ interaction with their services.
2. Data Uses
Transmit Security processes the personal data described in Section 1 as well as other types of data, as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services. These include understanding how our Services are used, and how our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use your data for the following purposes:
- to facilitate, operate, and provide our Services;
- to authenticate your identity and allow you to access and use our Services;
- to provide you with customer care, assistance and technical support services;
- to further develop, customize and improve the Services, and to improve your user experience, based on common or personal preferences, experiences and difficulties;
- to provide our Customers with information regarding shared End-Users for the purpose of registration, authentication, and fraud prevention;
- to facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
- to contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 8 below, and to facilitate, sponsor and offer certain events and promotions;
- to support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- to create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
- to comply with our legal, regulatory, compliance and contractual obligations.
3. Data Location
We and our authorized Service Providers maintain, store and process personal data in the various locations we operate around the globe, including in the US, and Israel, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
4. Data Retention
We retain your personal data for as long as it is reasonably necessary to provide you with our Services and offerings and to maintain and expand our relationship; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy, applicable laws and regulations, and where applicable, also with our Customer’s reasonable instructions and as further stipulated in our agreements with such Customer.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
5. Data Security
We and our Service Providers implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
6. Data Sharing
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Service Providers: we engage selected third-party entities and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, support and customer relation management systems; and our business, legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.
Other Customers: End-User data may be shared with additional BindID Customers for fraud prevention and if an End-User chooses to use the Services for authentication and registration purposes so as to seamlessly register to other Customers using the BindID solution. Such data may include the End-User and device registration timestamps, as well as End-Users’ last sign-in, number of devices registered, number of applications confirmed and additional technical data (if applicable).
Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Transmit Security, our End-Users, or any members of the general public.
Transmit Security Subsidiaries and Affiliated Companies; Change of Control: we may share personal data internally within our group, for the purposes described in this Policy. In addition, should Transmit Security, Inc. or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
Additional Sharing: we may share your personal data in additional manners, pursuant to your request or explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
7. Cookies and Tracking Technologies
Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
End-user authentication – cookies that are used for an instant, seamless access to BindID Customers Services, such as for BindID end-users and the devices identification.
Self-service user management – cookies that are used to allow End-users to manage their BindID account and any information associated with it via the BindID end-user management portal (a.k.a MyBindID).
For more information on the types of cookies we use, please send an e-mail to email@example.com.
8. Data Subject Rights
Individuals have rights concerning their personal data. If you wish to exercise your privacy rights under a law applicable to you, such as the EU General Data Protection Regulation (GDPR), or the CCPA, such as the right to request access, rectification, or erasure of your personal data held with Transmit Security, your right to restrict or object to such personal data’s processing, or to port such personal data – please contact us by e-mail at: firstname.lastname@example.org. Note that if you are a user using the Services on behalf of our Customer, your request should be communicated to us through the account administrator of the applicable Customer (i.e., your employer or the organization to which you are related). Please also note that if such a request will be directed to us, we will share it with the relevant Customer.
Please note that the above rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Please note that if you request to exercise your right to delete your personal data, we will delete the data from our system (subject to the above). However, some personal data may remain on our backup systems which will be deleted in accordance with our backup retention schedule.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
9. Roles and Responsibilities
Certain data protection laws and regulations, such as the GDPR or the CCPA typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Transmit Security is a “data controller” of its End-Users’ data. With respect to such data, we assume the role of a data controller (solely to the extent applicable under law), as set forth in this Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.
Customer is a “data co-controller” of the End-Users’ data. With respect to the End-Users’ data provided to Customer for registration, authentication, and fraud prevention purposes. Customer, as a co-controller, is responsible for the security, integrity and authorized use of such End-Users’ information, for providing adequate notice to their End-Users’ whose personal data may be processed (where applicable), and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws (to the extent applicable).
Transmit Security is the “data processor” of Custom Information. With respect to Custom Information of an End-User provided to Transmit Security by a Customer, we assume the role of a data processor and only process such data on behalf and in accordance with the instructions of our Customer. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing, providing data subjects with sufficient information about their personal data, and responding to Data Subject Rights requests concerning the personal data they control).
If you would like to make any requests or queries regarding Custom Information we process as a Data Processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact the relevant Customer directly.
10. Additional Information and Contact Details
Updates and Amendments: we may update and amend this Policy from time to time by posting an updated version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via Services. After such notice period, all amendments shall be deemed accepted by you.
Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and endeavor to delete personal data stored with us with regard to such a child. If you believe that we might have any such data, please contact us by e-mail at email@example.com.
EU Representative: Niels Decraene has been designated as Transmit Security’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Niels Decraene may be contacted on matters related to the processing of personal data of individuals in the EU. To make such an inquiry, please send an email to firstname.lastname@example.org If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
UK Representative: Jack Blockley has been designated as Transmit Security’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Jack Blockley may be contacted only on matters related to the processing of personal data of individuals in the UK. To make such an inquiry, please send an email to email@example.com. If you are situated in the UK, you also have the right to lodge a complaint with the Information Commissioner’s Office.
Effective Date: September 29th, 2021