Digital Onboarding Demo
How identity documents, biometric data, and device information are handled during demonstration, evaluation, and testing.
We value your trust and are dedicated to protecting your privacy. This Privacy Policy outlines how we collect, use, share, retain, delete, and safeguard your information when you access or use our TOPPAN Security demos.
By ticking the checkbox before using the app, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data, including face and biometric data used for identity verification, as described in this Privacy Policy.
TOPPAN SECURITY uses this mobile App to capture selfie and identity document data for the Digital Onboarding Demo (the “Services”). For the purpose of processing personal data through the App, TOPPAN Security acts as the data controller. Required data is securely transmitted to TOPPAN Security’s backend services for identity verification processing.
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 end user of the Digital Onboarding Demo mobile application or related online services.
Important
In order to access our Services and benefit from the features offered through the App, we require your consent. You will be asked to provide your consent by ticking a dedicated consent checkbox when you first open the App. You may withdraw your consent at any time without affecting the lawfulness of the processing carried out prior to such withdrawal. You also have the right to exercise your data protection rights as described in Section “Your Data Protection Rights” of this Privacy Notice.
Where required by applicable law, we will provide additional notice and obtain clear and conspicuous consent before collecting or processing face and biometric data.
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.
The term "personal data" means any information that relates to you and can identify you, directly or indirectly. This may include information such as your name, contact details, identity document information, facial images, biometric data, and other information collected through the App.
This Privacy Notice applies to the operation of our Digital Onboarding Demo mobile application ("TOPPAN Security – Digital Onboarding Demo") and any related web-based portal that directly links to this notice when you access the Privacy Notice within the application.
This Demo application is intended strictly for internal demonstration, evaluation, testing, and product validation purposes and is not connected to any live banking system, financial institution, or production environment. We only collect and process the minimum amount of personal data necessary to operate, test, and evaluate the Demo application, and such data will not be used for any other purpose.
What the APP Does
The mobile App captures identity documents and a selfie as part of the Digital Onboarding Demo. The required data is securely transmitted to TOPPAN Security’s backend services for identity verification processing.
Face and Biometric Data
This may include:
- Facial images captured from the user's selfie;
- Facial images contained in identity documents provided during the verification process, such as passports or identity cards;
- Biometric information generated or processed for facial recognition and liveness detection.
The facial image captured from the user's selfie may be compared with the facial image contained in the identity document to perform one-to-one facial matching as part of the identity verification process.
Face and biometric data may also be processed to perform liveness detection to determine whether the captured facial image represents a live person.
Purpose of Processing Face Data
Face and biometric data is used to perform facial matching and liveness detection for identity verification, and to support demonstration, testing, troubleshooting, and product validation.
Face and biometric data will not be used for advertising, marketing, user profiling, or any other purpose unrelated to the identity verification functionality of the Digital Onboarding Demo.
Face Data Consent
Where required by applicable law, users will be informed and asked for consent before face or biometric data is collected or processed.
Collection, Use and Disclosure of Your Personal Data:
Types of Personal Data we collect and How we process them
When you use the Digital Onboarding Demo Platform, we may collect personal data necessary to demonstrate identity verification functionality.
This may include your:
- Full name;
- Date of birth;
- Nationality;
- Residential address;
- Identification document details;
- Identification document images;
- Facial images;
- Biometric data;
- Device information;
- Contact details where required.
Such data is processed for demonstration, testing, troubleshooting, security monitoring, compliance obligations, product validation, and product improvement purposes.
Sharing and Disclosure of Face and Biometric Data
Required data may be processed by TOPPAN Security’s backend services and authorized service providers supporting the verification functions.
We do not sell face or biometric data.
Face and biometric data is not sold or shared for advertising or other unrelated purposes.
Storage and Security of Face Data
Face and biometric data is stored and processed within TOPPAN Security's designated backend infrastructure.
We take appropriate technical and organizational measures to protect face and biometric data and other personal information against unauthorized access, use, disclosure, alteration, loss, or destruction.
Access to face and biometric data is restricted to authorized personnel and systems that require access for legitimate business purposes.
Retention and Deletion of Face and Biometric Data
Face and biometric data collected through the Digital Onboarding Demo will be retained for a maximum period of 30 days from the date of collection.
The face and biometric data will be automatically deleted after the 30-day retention period, unless a longer retention period is required or permitted by applicable law.
Other personal data and demo records may be retained for the period necessary to fulfill their respective purposes, including demonstration, testing, troubleshooting, security, compliance, reporting, and product improvement.
When personal data is no longer necessary for the stated purposes or reaches the applicable retention period, TOPPAN Security will securely delete or otherwise dispose of the data in accordance with our data deletion procedures.
Your Data Protection Rights
Subject to applicable laws and regulations, you may have the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete personal data;
- request deletion of your personal data, including face and biometric data;
- withdraw your consent to the processing of your personal data where applicable; and
- exercise other applicable data protection rights.
To exercise your data protection rights, please contact us at:
Upon receiving a valid deletion request, TOPPAN Security will process the request in accordance with applicable laws and our data deletion procedures.
Please note that certain information may need to be retained where required or permitted by applicable law.
Data Security
We will take every reasonable precaution to protect the information we collect from you, including physical, technical, and organizational measures designed to safeguard the information against loss, misuse, unauthorized access, disclosure, alteration, or destruction.
Access to this information is protected through appropriate security controls both online and offline.
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 review this Privacy Notice periodically within the Digital Onboarding Demo application to stay informed of any updates.
Enforcement & Dispute Resolution
We will regularly review how we are meeting privacy objectives.
If you have questions, requests, or complaints about our privacy practices, you may contact us by emailing:
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 the Hong Kong Mediation Center. 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.