Privacy

WE SCAN

Privacy Policy

Last updated: April 4, 2018

This is the privacy policy (“Privacy Policy”) that governs how WeScan LLC, a Delaware limited liability company, and its affiliates (“WeScan“, “WE SCAN” “we“, “our” or “us“), uses Personal Data (defined below) that we collect, receive and store about individuals in connection with the use of our website: https://www.wescanids.com/, and any other website that we operate (each, together with its sub-domains, content and services, a “Site“), our products that collect Personal Data (“Products”), and our software that processes, stores, and uses Personal Data collected (“Software” and, collectively, with our Products, our “Services”).

You may choose whether or not to provide or disclose Personal Data in connection with your use of our Site. If you choose not to provide the Personal Data we request, you may still visit and use parts of our Site, but may be unable to access or use certain features, options, programs, and services.  Our Site may contain links to third-party websites and services that are not owned or controlled by WeScan. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk.

1. Introduction.

We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using our Site or in connection with our Services. As used in this Privacy Policy, “Personal Data” means any information that may be used, either alone or in combination with other information, to personally identify an individual.

2. Changes to this Privacy Policy.

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE.

3. Information Collected.

We may receive and/or collect Personal Data in the following ways:

3.1. Personal Data You Provide To Us On Our Site. If you send us a “Contact Us” request or feedback or when you sign in to your user profile, you may be required to provide us with certain information that may constitute Personal Data, such as:

• Your name;
• Email address;
• User ID;
• Password; and
• Communications you send to us.

3.2. Personal Data We Collect Through Our Services. WeScan receives Personal Data whenever our business-class users (“Clients”) use our Services in connection with verification activities that rely on government-issued identification (“ID”) as an input. Specifically, our Services involve our Products: (i) reading the magnetic stripe or the PDF417 barcode printed on the front or back of an ID card, (ii) decoding the data contained in an ID card and transforming it into Personal Data; and (iii) transmitting the Personal Data directly to WeScan for further processing by our proprietary Software. The types of Personal Data we process through our Services include:

• Name;
• ID number;
• Age (at the time of scan);
• Gender (if available);
• Address; and
• Date of Birth

WeScan processes, stores and uses all Personal Data received from a Client in accordance with our Client Personal Information Use and Retention Policy as modified from time to time, and all applicable laws, statutes, rules, regulations, orders, decisions, interpretations, opinions, industry self-regulatory principles and guidelines, and other requirements, whether promulgated by the United States or any other applicable jurisdiction. For more information on retention of Personal Data, please review Section 6 of this Privacy Policy.

3.3. Information Collected Automatically. Certain information on our Site is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of our Site. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers (described in Section 5, below) may use cookies or other methods to gather information regarding your use of our Site. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Site with any of your Personal Data that they may have. The use of such information by a third party depends on the privacy policy of that third party.

1. a) Log Files On Our Site. The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.
2. b) Cookies.  We use cookies to make interactions with our Site easy and meaningful. When you visit our Site, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to a promotional offer, opening an account, or filling out a web form, you remain anonymous to us.

We may use cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate our Site, but you may not be able to successfully use all of the features of our Site

The following sets out how we may use different categories of cookies and your options for managing cookies’ settings:

c) Other Tracking Technologies. When you visit our Site, we may collect your IP addresses to track and aggregate non-Personal Data. For example, we may use IP addresses to monitor the regions from which you navigate our Sites.

We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Site and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Site. We may use web beacons to operate and improve our Site and email communications.

4. The Purposes For Which We Use Personal Data.

If you submit or we collect Personal Data through our Site or Services, then such Personal Data may be used in the following ways: (i) to provide, analyze, administer, and improve our Site, (ii) to contact you in connection with our Site, notifications, events, programs or offerings that you may have registered for, (iii) to send you updates and promotional materials that you have registered for, (iv) to identify and authenticate your access to the parts of our Site that you are authorized to access; (v) to verify your identity, age, or for some other verification purpose in connection with our Services and as requested by our Clients, and (vi) to protect our rights and/or our property and to ensure the technical functionality and security of our Site.

5. How We Disclose Personal Data.

We do not sell, lease, rent or otherwise disclose the Personal Data collected from our Site to third parties unless otherwise stated below or with your consent.

5.1. Our Clients. We transfer Personal Data to our Clients to allow our Clients to fulfill their business purposes and to comply with applicable laws, rules, and regulations in their jurisdiction related to the purposes for which we collect Personal Data.  We use commercially reasonable efforts to limit the amount of Personal Data transferred to our Clients to the minimum amount necessary to fulfill their business purposes through technical and logical safeguards and reasonable retention periods. Additionally, we require Clients to comply with our Client Personal Information Use and Retention Policy and other policies as applicable. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers as well as any transfer restriction that is specified in an agreement between WeScan and a customer.

5.2. Our Third Party Providers. We transfer Personal Data to our third party service providers to perform tasks on our behalf and to assist us in providing our Site. For example, we employ Amazon Web Services for data retention and storage purposes. Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Data. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers as well as any transfer restriction that is specified in an agreement between WeScan and a customer.

5.3 Business Partners. From time to time, we may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from us, we may share Personal Data collected in connection with your purchase or expression of interest with our joint promotion partner(s). We do not control our business partners’ use of Personal Data we collect, and their use of the information will be in accordance with their own privacy policies.

5.4. Affiliates: We may transfer Personal Data to our subsidiaries and affiliated companies (each an “Affiliate”), but only for the purpose of providing our Site and Services. Our Affiliates are required to process any such Personal Data in compliance with this Privacy Policy. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers as well as any transfer restriction that is specified in an agreement between WeScan and a customer.

5.5. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third party entity that acquires or is merged with as part of a merger, acquisition, sale, or other change of control.

5.6. Other Disclosures. We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of WeScan, our users, or the public.

6. Retention of Personal Data.

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 4 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law.

When we collect Personal Data through our Services, our retention period may be limited to a predetermined timeframe (for example, 48 hours or 30 days). In other cases, we may retain your Personal Data permanently. If we retain your Personal Data permanently, we will only retain the following types of information: Name, ID Number, Address, Gender (if available) and Age (at the time of Scan). Our retention periods depend on the type of Personal Data involved and the scope of Services delivered to our Client. Please review our Client Personal Information Use and Retention Policy for more information. When we collect your Personal Data through our Services, we employ industry-standard security measures (such as converting your ID Number into a cryptographic hash) to protect your Personal Data. Please review Section 7 for more information on our Data Security.

7. Data Security.

The security of Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. For example, WeScan uses commercially reasonable technical safeguards to ensure that all Personal Data is encrypted in transit from the Client to WeScan’s computer and IT systems. WeScan has in place administrative and physical safeguards, to ensure only the necessary users have access to Client Personal Data However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

8. Children’s Privacy.

Our Site is not intended for children under the age of 13. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 13 years of age.

9. How We Respond to Do Not Track Signals.

At this time, WeScan is unable to universally respond to “Do Not Track” or other “opt-out” mechanisms that have been activated by a user through their web browser, and except as otherwise provided herein, does not alter its policies if a user activates such mechanism.

10. Your California Privacy Rights.

If you are a California resident and have provided Personal Data to WeScan through the Site, you are entitled by law to request certain information regarding any disclosure that may have been made by WeScan to third parties of Personal Data for their direct marketing purposes. To make such a request, send an email to support@wescanids.com specifying that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. WeScan is required to respond to only one request per customer each year, and is not required to respond to requests made by means other than through the above email address. We will not share Personal Data about you with third parties for their direct marketing purposes if you request that we do not do so. If you would like more information about not having your information used by third parties, or if you would like to make such an opt-out request, you may send us an email at support@wescanids.com. You may also request to opt-out of an advertiser’s use of cookies by visiting the Network Advertising Initiative or the Digital Advertising Alliance. You may request to opt-out of Google’s use of cookies by visiting www.google.com/ads/preferences. All applicable terms on these websites will apply to your request to opt-out in addition to this Privacy Policy. When contacting us, please indicate your name, address, email address, and what Personal Data you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of Personal Data or for processing this request.

11. Contacting Us

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to support@wescanids.com.