iDenKey/iDenFace Privacy Notice
TOPPAN Security provides digital identity verification and authentication services via our proprietary recognition tools, iDenFace™ and iDenKey™. The terms “TOPPAN Security,” “we,” “us,” “our,” and “ours,” when used in this privacy notice (“Privacy Notice”), include subsidiaries, divisions, branches, affiliates, or companies under the control of TOPPAN Security. The terms “you,” “your,” and “yours,” when used in this Privacy Notice, mean any user of these Online Services.
IMPORTANT: BY SUBMITTING PERSONAL DATA TO US AND/OR BY USING OUR ONLINE SERVICES, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW.
Scope of Privacy Notice
This Privacy Notice describes our current policies and practices with regard to personal data collected by us from you directly and/or through our Online Services (as defined below) and this website from “contact us.” The term “personal data” refers to personally identifiable information about you. This Privacy Notice applies to the operation of our Online Services via our App “iDenFace™ Authenticator” and “iDenKey™” that directly link to this notice when you click on the Privacy Notice link.
Online Services
We provide digital identity verification and authentication services via our proprietary tools, iDenFace™ and iDenKey™ (“Online Services”). These Online Services are available to you through our iDenFace™ SDK and iDenKey SDK. By downloading and accessing the App and providing us with your personal information in the Online Services, you agree to the use of your personal data and contact information in accordance with this Privacy Notice. We may contact you regarding updates, modifications, and additional service offerings. Your access to these Online Services will be retained and used for support, transition, maintenance, service improvements, and technical development, as well as to comply with reporting, audit, and data retention requirements.
Notification of Changes to This Notice
TOPPAN Security is continually improving our methods of communication and adding new functionality and features to our existing services. Because of these ongoing changes, changes in the law, and the changing nature of technology, our data practices may change. We encourage you to check this page frequently and anytime you submit personal information via our Online Services.
Collection, Use, and Disclosure of Your Personal Data
TOPPAN Security as a Data Processor
From time to time, TOPPAN Security may be required to process data that you have uploaded, stored, and shared with TOPPAN Security for troubleshooting or further development or improvement of our Online Services internally or with trusted partners. TOPPAN Security does not review or analyze the content of the data. However, it may contain personal data, which TOPPAN Security uses/processes to facilitate the troubleshooting, development, or improvement of our Online Services.
Toppan Security as a Data Controller
When you use our products and services or request information, we may request certain personal data about you such as your name, an uploaded photo of your face, your address, e-mail address, and telephone number. We may also ask for demographic information to enable us to provide you with a personalized service. The information you provide is either manually or electronically stored in our databases. We may share your personal data under these limited circumstances:
• In order to provide you with the requested information on products or services, your personal data may be shared with other companies within our group of companies and third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have consented. For example, sometimes a third party may have access to your personal data in order to support our information technology, to supplement, update, or correct the data or provide additional publicly available data, or to handle mailings on our behalf. TOPPAN Security requires that all third-party processors process your personal data with the same level of protection and in a manner consistent with the uses agreed upon in this Privacy Notice.
• We will keep your contact details on our database and we may use your personal data for marketing purposes and market research. If you do not wish to receive e-mails or post from us for these purposes, please let us know by following the “unsubscribe” procedure described herein.
• We may use your personal data to administer our iDenFace™ Authenticator App and Online Services and help us improve our services.
• We may share your personal data with other companies within our group of companies, who may contact you about their products or services that may interest you.
• We may disclose the information in our databases and server logs to comply with a legal requirement, for the administration of justice, for the purposes of national security only to the extent that is strictly necessary and proportionate, to interact with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or our Online Services, to take precautions against legal liability, or in the event of our sale, merger, reorganization, dissolution or similar event.
• In the event of a corporate sale, merger, reorganization, dissolution or similar event, your personal data may be part of an asset transfer or sale.
Retention
TOPPAN Security retains personal data only as long as necessary to fulfill the stated purposes or as legally required, and thereafter securely destroys such information.
When personal data is no longer necessary or relevant for the stated purpose or to fulfill a legal or business requirement, it shall be securely destroyed. TOPPAN Security will either physically or electronically erase the personal data.
Data Security
We will take every sensible precaution to protect the information we collect from you including physical, technical and organizational procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure. Access to this information is protected both online and offline.
Anonymous data collected through this Online
Services
In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Online Services. For example, our Web server automatically logs which pages of our Online Services, our visitors view, their IP addresses and which Web browsers our visitors use. This technology does not identify you personally; it enables us to compile statistics about our visitors and their use of our Online Services. Our Online Services contain hyperlinks to other pages on our Online Services. We may use technology to track how often these links are used and which pages on our Online Services our visitors choose to view.
Cookies
In order to collect the anonymous data described herein, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information that is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.
Enforcement & Dispute Resolution
We will regularly review how we meet privacy objectives. If you have questions, requests, or complaints about our privacy practices, you may contact us by e-mailing info@toppansecurity.com. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, we agree to participate in the dispute resolution procedures established by the Hong Kong Mediation Center. If necessary, you may submit a complaint to: http://www.mediationcentre.org.hk/en. Under certain conditions, you may invoke binding arbitration.
Any dispute arising from or in connection with this Privacy Notice shall be submitted to the Hong Kong Mediation Center for mediation, which shall be conducted in accordance with the Center’s Mediation Rules in effect at the time of the mediation.