General information and contact details
If you have any questions about how your personal data is used by GBG, please contact our Data Protection Officer by email at DPO@gbgplc.com or call (+44) 01244 657277.
GBG review our Privacy Notice on an annual basis, sooner if changes to regulation require it or we change the way we process personal data.
You may only use the Demo App for the purpose of evaluating GBG’s technology. You shall not be entitled to make any commercial benefit from the Demo App or any materials derived from its use.
This Demo App and all intellectual property rights in it are owned by GBG, our licensors or both (as applicable). Intellectual property rights means rights such as: copyright, trademarks, domain names, design rights, database rights, patents and all other intellectual property rights of any kind whether or not they are registered or unregistered (anywhere in the world). We reserve all of our rights in any intellectual property in connection with our Demo App.
You must not:
- Use the Demo App for any unlawful purpose or activity;
- Use the Demo App in any way that does or could potentially breach a legal duty to anyone else (including a duty of confidentiality), infringe a person’s right to privacy or may infringe the intellectual property rights (e.g. copyright, trademarks, patents, database rights, know-how and design rights) of anyone else (including ours);
- Distribute, license, sell, rent, lease or otherwise deal in or encumber the Demo App;
- Modify, add to, or otherwise enhance the Demo App; or
- Infringe or copy our code or the content or the design of the Demo App.
GBG may suspend or terminate operation of the Demo App at any time as we see fit. While we try to make sure that the Demo App is available for your use, we do not guarantee that the Demo App will be available at all times nor do we guarantee uninterrupted use of the Demo App.
What information GBG is collecting on you
GBG’s customers access our products and services to prevent and detect fraud. The Demo App is designed to demonstrate the functionality of GBG IDscan’s Mobile Journey Capture Service, which can be used as part of a customer on-boarding process. This includes:
- Identity document and A4 document capture and processing.
- Face match, which provides instant validation of facial features between the photograph on an identity document and the image captured as part of the mobile journey.
- A liveness test, which verifies that the person using the device is live and not using a static image, and that they match the presented identity document.
You must only supply an identity document or A4 document belonging to you or belonging to another individual (i) who is present at the time the document is scanned using the Demo App, (ii) who has been made aware of this Privacy Notice and (iii) who has provided their verbal consent for their personal data to be processed by GBG.
The personal data extracted from the document will vary according to the journey configuration, the country/area profile that is chosen (if none is selected the default is the UK) and whether the offline or online setting is used, and will be a combination of some or all of the information held on the document presented during the demonstration.
Lawful bases for processing
Since providing your identity and/or A4 document(s) in order to test the Demo App is completely voluntary, GBG will rely on consent as the lawful basis for processing under Article 6(1)(a) of the General Data Protection Regulation (GDPR).
If you wish the mobile journey to be configured to test the app’s face match and/or liveness test capabilities, your biometric data will be processed. This is special category data under the GDPR, and GBG will rely on explicit consent under Article 9(2)(a) to process such data.
Where, how and why GBG is storing your information
If the Demo App is used in its online setting, the document images collected are stored in GBG’s demo database. All the data uploaded to our servers as part of a demo are deleted within 24 hours or sooner if you request it.
If you choose to use the Demo App’s offline setting, the validation of the documents and extraction of the personal data occurs on device and no images or extracted data are stored once you end the journey.
Use by GBG and third parties
Your identity or A4 document will only be used by GBG as set out in this Privacy Notice and GBG shall not disclose or permit the disclosure of your document(s) to any third party.
Please rest assured that GBG will implement and maintain appropriate technical and organisational security measures against unauthorised or unlawful processing of your document(s).
International data transfers
GBG’s demonstration database is managed and supported by GBG’s Cloud Operations and Infrastructure teams, which are based in Turkey. Controller-processor standard contractual clauses are in place with our Turkish office.
GBG shall at all times process your personal data in accordance with its obligations under applicable data protection laws including the GDPR and the UK Data Protection Act 2018. If you require further information or wish to exercise any of your rights under the GDPR, you can email us at email@example.com, call us on (+44) 01244 657277, make a request in person during or after the demonstration, or send a letter to the address provided at the start of this Privacy Notice.
Access to your information
You can find out what personal information we hold about you (if any) by making a Subject Access Request.
If you change your mind, you can withdraw your consent to allow GBG to process your personal data at any time during or after the demonstration. Please note that no data collected during a demonstration is stored by GBG for longer than 24 hours.
Right to restriction of processing
You have the right to request that we restrict the processing of your personal data where one of the grounds contained in Article 18 of the GDPR applies.
Right to erasure
You are entitled to request GBG delete your personal data at any time during the demonstration. Please note that no data collected during a demonstration is stored by GBG for longer than 24 hours.
How to contact us if you’re not happy
If you have any questions about how your personal data is used by GBG or wish to make a complaint, you can contact our Data Protection Officer by email at DPO@gbgplc.com or call 01244 657277.
What to do if you remain dissatisfied
If you remain dissatisfied with GBG’s response to your complaint, you have the right to refer the matter to the Information Commissioner’s Office (ICO), who will investigate your complaint and will give an independent ruling on the issues you have raised. Contact details for the ICO are available here.