PRIVACY POLICY OF THE “IDENTT” APPLICATION

1. Definitions:
   1.1 Application – the mobile application “IDENTT” made available in the Google Play and App Store app stores, which supports the identity verification process at a Partner by enabling local OCR reading of data from an identity document. In addition, it allows the User to perform a preview reading of data from an identity document, where such data remains locally on the User’s mobile device.
   1.2 IDENTT – the entity providing the tool in the form of the Application in order to support the identity verification process at a Partner. Identt sp. z o.o., with its registered office in Wrocław (50-416), ul. Gen. Romualda Traugutta 45, entered in the Register of Entrepreneurs of the National Court Register by the District Court for Wrocław-Fabryczna in Wrocław, 6th Commercial Division of the National Court Register, under KRS number 0000586371, NIP 8982215099, REGON 363017634, with a share capital of PLN 100,000.00.
   1.3 Partner – an entity that cooperates with IDENTT within the identity verification process. These are most often organizations such as banks, telecommunications operators, loan companies, financial institutions, and others, with whom IDENTT has concluded cooperation agreements in order to support the identity verification process at the Partner.
   1.4 User – a natural person whose identity, at the request of the Partner, is to be verified using, among other things, the Application.
2. The controller of personal data in connection with the use of the Application as part of the identity verification process at a Partner is the specific Partner. IDENTT acts as a data processor, processing personal data on behalf of the Partner and in accordance with the Partner’s instructions contained in the data processing agreement concluded between IDENTT and the Partner. IDENTT supports the identity verification process and provides the Partner with information about the verification, while the final decision is always made by the Partner.
3. The identity and contact details of the specific Partner are consistent with the identity of the Partner from whom the User received the link to the Application and are also included in the privacy policy provided by the Partner, which should be made available prior to the commencement of the identity verification support process.
4. Use of the Application is possible in two variants:
   4.1 Variant No. 1 – identity verification process initiated by the Partner from whom you received a redirection to the Application
   In this case, you were redirected to the Application via a dedicated link received from the Partner during the identity verification process. In the Application, you will perform a reading of data from the electronic layer of an identity card or passport compliant with ICAO 9309. The data is read locally on your device within the Application. IDENTT does not process the data as a personal data controller. The data read in the Application is processed by IDENTT as a data processor acting on behalf of the Partner, who is the personal data controller. IDENTT supports the identity verification process, while the Partner makes the final decision regarding the outcome of the verification of your identity. Detailed information about the Partner (name, address, contact details, link to the privacy policy) will be provided by the Partner to IDENTT prior to the redirection to the Application.
   4.2 Variant No. 2 – data preview on your device, i.e. independent use of the Application by the User, without the involvement of a Partner from whom the User may have received a link to the Application. In this case, the User downloaded the Application independently from the app store (Google Play or App Store). The User performed a reading of data from the electronic layer of an identity document (identity card or passport) and then previewed it in the Application. This data is not transmitted anywhere; only a local preview on the mobile device is possible. The data remains exclusively on the User’s device and is not transmitted to either IDENTT or the Partner. After the preview is completed, the data is automatically deleted from the Application.
5. Zakres przetwarzanych danych może się różnić w zależności od wariantu:
   5.1 Variant 1 – identity verification process – within this variant, the following data is processed:
   5.1.1 data read from the electronic layer of the identity document, e.g. first name, last name, PESEL number or another identification number, document series and number, date of issue, date of expiry, nationality, document photo, and other fields in accordance with the document;
   5.1.2 metadata – Application activity logs, error logs, IP address to the extent necessary, type of device, operating system, application version, analytical data for the purpose of ensuring security and proper operation of the Application.
   Variant 2 – data preview on the device – within this variant:
   5.2.1 data read from the electronic layer of the document remains locally on your device and is not transmitted to IDENTT or the Partner, and after the preview is completed, the data is immediately deleted from the Application’s memory.
6. Detailed information on the purposes and methods of processing personal data, as well as the rights of the User, can be found in the privacy policies of the Partners who have commissioned the identity verification process using the Application.