Privacy Policy
Last updated October 17, 2025
Preamble
This is the Privacy Policy of the Compligate Ltd, incorporated and registered in England with company number 15376538 together with all affiliated companies and trading divisions, irrespective of location or jurisdiction (hereinafter - “Kycaid” or “we”). More information about our group can be found in Section 20 of this Privacy Policy.
To provide Services, Kycaid processes Personal data according to our Clients instructions. Clients are Controllers that determine purposes of data processing, exercise control over Users’ Personal data, and stipulate retention periods of Users’ data according to their purposes. Kycaid, in turn, is a Processor that conducts only those data processing activities that Clients request. Kycaid performs remote identity verification procedures for Clients as part of the Services Section. Before passing such procedures, Users should be properly notified by Clients in line with their privacy policies and, depending on Clients’ legal bases for data processing, may be asked to consent to such processing.
When developing and improving Services and in other cases specified in this Privacy Policy, Kycaid is the Controller of Users' Personal data.
1. Extent of policy
This Privacy Policy explains how we handle your Personal data, our commitment to keeping your information, the approach we apply to ensure proper data protection management in the course of delivering our Services. It does not regulate how Kycaid's Clients may process Users' Personal data. Clients share this information in their privacy statements, which Kycaid does not control.
For California residents, information about the application of the CCPA is available in Section 19 of this Notice.
Residents of Illinois, Washington, or Texas, should consult the “Special notice to residents of the states of Illinois, Washington, or Texas (USA)” (Section 18 of this Privacy Policy). In the event of any conflict or ambiguity between the Special Notice and the other Sections of this Privacy Policy, the Special Notice shall take precedence.
2. Terms and Meanings
Agreement - a commercial contract that regulates the Section of Kycaid’s provided to a Client, established between a Kycaid entity and that Client (or an entity representing that Client, or an entity otherwise authorized to distribute the Services to that Client);
AML/CFT - refers to the legal regulations and standards for Anti-Money Laundering / Combating the Financing of Terrorism legal, as outlined in the recommendations of the FATF, EU regulations, and national legislation;
BIPA – mean the Biometric Information Privacy Act of 2008 in Illinois, US;
CCPA – mean the California Consumer Privacy Act of 2018, Civil Code sections 1798.100;
Client - a legal entity or individual that uses, or is entitled to use, Kycaid’s Services in accordance with the respective Agreement and as authorized by the respective Kycaid entity. The Clients provide their personal data to Kycaid on behalf of the respective Client using that Client's websites/platforms;
Consent - refers to any voluntary, specific, informed and unequivocal expression of the Data Subject’s preferences, through which they indicate their agreement to the processing of their personal data, either by means of a statement or through a clear affirmative action;
Customer due diligence procedure - the process and regulations set forth by the Client in accordance with relevant laws, which include the obligations for identifying its customers, associated risks and verifying their identities (may be referred to as ‘KYC’ in this Notice);
Data Controller, or Controller - refers to a natural or legal entity, public authority, agency or any other organization that, either independently or in collaboration with others,establishes the objectives and methods for processing Personal data; for instance, Client or Kycaid when it pursues its own objectives - as defined in this Notice;
Data Processor, or Processor - a natural or legal entity, public authority, agency or other organization that handles personal data on behalf of the controller; for instance, Kycaid when it manages data for its Clients;
Data Providers - third-party service providers or governmental entities utilized to gather supplementary information required for the Section of the Services;
Data Subject - any individual whose personal data may be processed by Kycaid on behalf of the Controller (such as the Client’s customers);
eIDAS framework - a collection of regulations that encompasses the following legal scope:
- Regulation No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC;
- ETSI EN 319 401: Electronic Signatures and Infrastructures (ESI); General Policy Requirements for Trust Service Providers;
- ETSI EN 319 411-1: Electronic Signatures and Infrastructures (ESI); Policy and security requirements for Trust Service Providers issuing certificates; Part 1: General requirements;
- ETSI EN 319 411-2: Electronic Signatures and Infrastructures (ESI); Policy and security requirements for Trust Service Providers issuing certificates; Part 2: Requirements for trust service providers issuing EU qualified certificates;
- ETSI TS 119 461: Electronic Signatures and Infrastructures (ESI); Policy and security requirements for trust service components providing identity proofing of trust service subjects;
EEA - European Economic Area (the European Union Member States, Norway, Iceland and, Liechtenstein);
EU GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
Filing system – any structured collection of Personal data that can be retrieved based on defined criteria, regardless of whether it is centralised, decentralised, or distributed either functionally or geographically, used for the relevant Service Section;
Kycaid ID - a collection of technical features and associated services offered by Kycaid to Applicants, designed to help simplify identity verification and, upon request, facilitate the sharing of Personal data with Kycaid’s Clients. The commercial name of product may vary within Clients frameworks;
Livechat - a system that enables Users to engage in real-time communication with Kycaid’s support team through a chatbox on the Website page within the browser.
Personal data - refers to any information that pertains to an identified or identifiable Data Subject;
Personal data breach - a breach of data security resulting in the unlawful destruction, loss, alteration, unauthorised disclosure, or access to personal data that is transmitted, stored, or otherwise processed;
Politically Exposed Persons (PEPs) - individuals who currently hold or have previously held prominent public positions PEPs can include government officials, military officers, judges, senior sporting officials, and high-ranking executives of state-owned enterprises, as well as their relatives and close associates;
Privacy Policy or Notice - this Privacy Policy available at https://kycaid.com/privacy-policy/;
Processing - any operation or series of operations carried out on personal data or collections of personal data, regardless of whether these actions are performed through automated methods. This includes activities such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Service(s) - the personal identity verification service along with associated services offered by Kycaid;
Special categories of personal data - personal data disclosing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic or biometric data used to uniquely identify a natural person, or other comparable sensitive information;
Standard Contractual Clauses - standard contractual terms and conditions adopted by the European Commission (or relevant UK authorities) that provide appropriate safeguards for data transfers from the EEA and the UK to third countries, which are signed by both the Controller and the Processor, where applicable;
Subject - the legal entity identified as the certified holder in a QWAS certificate. A Subject may also qualify as a Data Subject within the meaning of the EU/UK GDPR;
Third-Party Processors - processors authorised to perform specific processing activities under the direct instruction or authority of Kycaid;
UK GDPR - EU GDPR as incorporated into the United Kingdom’s domestic legal frameworks;
User or Applicant - any individual or whom the identity verification process (or any of its components) is conducted as part of the Services offered to a Client (may be referred to as 'you' in this Notice);
Website – www.kycaid.com.
3. Objectives of processing personal data
3.1 Execution of the Agreement
In providing services to Clients, Kycaid primarily processes Personal data as a Processor for Clients’ benefit. Kycaid handles Personal data to carry out Agreements, including the specified Services, obligations under those Agreements, and associated rights, as well as to exercise rights, fulfill obligations established by legal acts and processing Users' requests.
Kycaid collects and further processes Users' data for Clients, which may involve matters of compliance with applicable AML/CFT and/or other laws, as well as the Clients' internal customer due diligence procedures. When Personal Data is no longer required for its intended purpose, Kycaid, following the Client’s written instructions, transfers the data to the Clients and subsequently deletes it from its servers without retaining any backup copies.
3.2. Other objectives
Your data may be processed for purposes that reflect Kycaid’s legitimate interests, including the following:
- Provided it is not restricted by applicable laws and we have obtained permission from our Clients, we may process certain Personal Data to enhance and improve existing Services, as well as to prevent and detect fraud and other unlawful activities, including through the use of artificial intelligence. For further details, see Section 5 (Enhancement of Services);
- Due to the nature of our Services, we monitor and prevent criminal activity, fraud, and money laundering by comparing the User-provided data against records of confirmed or suspected illegal activity, fraud, or money laundering. If any indications are found, we will notify our Clients. For further details, see Section 5 (Detection of Fraudulent Activity);
- For the purposes mentioned above, we may also carry out profiling, statistical analyses, and analytics related to AML/CFT trends, fraud detection, and prevention. Our system may compile Users’ data to produce reports and charts that Clients can use to assess the risk likelihood linked to specific characteristics;
- We may process Personal Data, including biometric information, to identify a User or a Client’s representative for the purpose of handling data subject access requests or fulfilling the Client’s request;
- Occasionally, we may be required to process or retain all or part of Personal Data for the purpose of establishing, exercising, or defending legal claims;
- When taking part in the Kycaid Travel Rule Ecosystem, we perform customer due diligence, and all data provided by Clients in questionnaires may be shared with other participants of the ecosystem in accordance with applicable legal requirements and the Kycaid Travel Rule Ecosystem Agreement, to help ensure all participants comply with AML/CFT regulations. These actions are conducted for our own purposes;
- We have our own purposes for processing, including preventing fraud and money laundering, as part of delivering services under the UK Digital Identity and Attribute Trust Framework, detailed in Section 9;
- In relation to crypto-related services, Kycaid may process Users’ Personal Data to create and maintain a wallet address book. This data is handled for the purpose of wallet attribution when Kycaid’s Clients carry out transactions in accordance with Travel Rule requirements. Wallet attribution involves linking wallet addresses to verified identities of individuals or entities, which helps identify suspicious transactions. This allows for improved monitoring of large or unusual transactions, tracing them to specific individuals, and ensuring accurate reporting to authorities. Kycaid obtains personal data for the wallet address book from its Clients and/or from publicly available sources.
We process certain Personal Data in compliance with the principles of lawfulness and accountability by ensuring a legal basis for handling specific Users’ data, as required by applicable laws. Keeping records of this legal basis is essential to demonstrate our adherence to legal obligations both within and outside the European Union and the United Kingdom.
3.3. Kycaid ID
This section applies when the procedures and technical documentation for Kycaid ID framework become available in Kycaid`s repository. Please note that the commercial name of technology could be different in the Clients frameworks, Please read Clients Policies.
Kycaid ID enables Applicants to use their Personal Data for identity verification with multiple Clients, including exercising their right to data portability and accessing necessary Personal Data based on their instructions via Kycaid ID. Applicants can provide documents and other required information to create a Kycaid ID and later request that Kycaid share their Personal Data with the Clients with whom they wish to verify their identity. The processing of Personal Data within Kycaid ID, including the creation of a dedicated storage space (“Data Pool Key”) for each Applicant, is conducted by Kycaid as a data controller. Once Personal Data is shared with a specific Client at the Applicant’s request, re-verification is performed by Kycaid as a data processor on behalf of its Clients. Processing within Kycaid ID also covers purposes related to Service Development and Fraud Detection, including profiling, as described above in point 3.2.
4. Kycaid’s Data Processing Principles
Kycaid complies with the Personal data protection principles set out in the EU GDPR and the UK GDPR along with other relevant laws. Under these principles, Kycaid assists Controllers in ensuring that Users’ Personal data is:
- Processed only for clearly defined and lawful purposes, without any further use that would conflict with them;
- Treated in a lawful, equitable, and open way in relation to the Data Subject;
- Kept precise and up-to-date;
- Adequate, relevant, and limited to what is necessary for the purposes of processing;
- Handled in a way that guarantees their proper security;
- Kept in a form that enables identification of Data Subjects, only for the duration required by the processing purposes;
- Not transmitted beyond the European Economic Area (EEA) or the UK without proper protection measures.
5. Data processing activities
Kycaid performs various types of automated processing, which include, but are not limited to: collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure via transmission, dissemination or other means of making data available, alignment or combination, restriction, and erasure or destruction.
• Verification of Documents
For fraud detection purposes, Kycaid processes Personal Data from photos and scanned copies of documents through automated reading and authenticity checks. These include verifying the completeness of records, detecting screenshots, and cross-checking all information from submitted documents (e.g., name, date and place of birth, signature). We also examine document security features such as embedded security chips, machine-readable zones (MRZ), barcodes, QR codes, and other components designed to validate genuine data. The system analyses these checks to assess the document’s trustworthiness.
• Biometric Data Processing
Kycaid may process biometric data to verify whether the facial images submitted correspond to the same individual as part of the Services provided to a specific Client. For this purpose, biometric processing involves extracting facial features from uploaded or recorded images and performing comparisons.
Clients typically request such biometric processing to confirm that an identity document genuinely belongs to a User by comparing the User’s facial image with the image on the identity document.
Additionally, Clients may request us to verify whether a User is alive and genuine. For this purpose, we use our Liveness check to ensure the User is not holding a mobile phone, showing signs of restraint, or attempting to deceive the system with emulators, static images, or deep fakes. Typically, Users are asked to blink, smile, or move their device during the Liveness check. In the process, we may also detect indications of fraud or other spoofing attempts by comparing Users’ facial features with known masks. At the same time, we may check for the creation of multiple identities by examining whether the User has been previously verified on behalf of a particular Client. To establish if the User is already known to a specific Client, their facial image is compared to those of other Users previously verified for that Client. Where multiple Clients are entitled to use Kycaid’s Services under the same Agreement (each having its own account or with one Client managing other Clients’ accounts), or where a single Client holds multiple accounts with Kycaid, the facial search may be conducted across all relevant accounts.
When requested by Clients, we support the authentication process. In this case, Clients may require their Users to complete a liveness check. During the procedure, the User’s face is recognized and compared with previously obtained biometric data for that User.
For each authentication attempt, the newly captured liveness facial image is compared against the User’s previously recorded biometrics.
• Video Verification and ID Processing
Typically, video identification involves a process in which the person being verified and an operator sit “face to face” via video transmission and communicate in real time. This procedure is conducted when a Client is legally required to do so (for instance, under AML/CFT regulations). To enable video identification, we provide Clients with functionality that allows them to conduct a video interview with Users during onboarding using an opening video. If preferred, the video interview may also be performed by Kycaid operators. The format, content, and structure of the interview are determined entirely by the Client’s requirements.
• Validation of Submitted Data
These data validation procedures allow Clients to verify information against databases maintained by third-party Data Providers and identify whether a User is connected to illicit activities, money laundering, or terrorism financing. For this purpose, we compare data taken from uploaded documents or submitted directly by the User with databases provided by third-party Data Providers. The specific Data Providers used depend on the Client’s requirements and the User’s location and may include ID registers, proof of address services, the Social Security Administration, and other governmental or commercial databases, consumer credit agencies, PEP lists, global and country-specific sanctions lists, as well as adverse media sources.
During the course of a Client’s relationship with its Users, we may support the Client by periodically screening Users’ data against various databases to assist in the prevention, detection, and investigation of fraud and money laundering.
In some cases, Clients request that we perform phone or email risk scoring. When this is required, we review a User’s email address or phone number, combined with the IP address where available, along with publicly accessible information obtained from Third-Party Processors or Data Providers. Using the data mentioned above, we generate risk labels based on factors such as online registrations, domain details, delivery options, and other relevant parameters.
• Verification of payment method
Know Your Business (KYB) is a procedure that examines transaction data associated with both senders and recipients. It allows Clients to identify and report unusual or atypical behaviour and patterns indicative of money laundering, terrorist financing, fraud, or other illicit activity, by using a Third-Party Provider.
• KYB check
If a Client opts for the KYB check, we are required to verify the existence, corporate details, ownership, and control structure (including ultimate beneficial owner(s)) of a legal entity by analysing corporate documents and reviewing corporate registries, where accessible.
• Crypto transaction Monitoring
Clients may request this check to comply with their legal obligations under AML/CFT legislation. The crypto transaction check is performed continuously by the Third-Party Provider, with reporting conducted according to their specific terms and conditions.
• Crypto Travel Rule Compliance
Clients may request this check to comply with their legal obligations under AML/CFT legislation. This requires the Virtual Asset Service Provider (VASP), which may be our Client, to obtain, verify, store, and exchange specific sender and recipient transaction information with their counterparty VASPs during or prior to a transaction. During this check, we verify a User’s identity and transfer to or receive from the Client’s counterparty VASP the relevant User data using specialized messaging protocols, including the Travel Rule Protocol (TRP), Kycaid API protocol, and platforms that provide encrypted messaging and data flows.
• Detection of Fraudulent Activity
Kycaid operates a fraud detection and control system based on anti-fraud checks requested by our Clients as well as those included by default in our Services (e.g., detecting Photoshop use or calculating risk triggers). These checks involve collecting, analysing, and reusing recorded User data.
In general, Kycaid assesses whether a User’s attributes—such as geolocation (IP address), device signature (operating system and camera), email address, or mobile phone—have previously been associated with fraudulent activity, currently indicate suspicious behavior patterns, or suggest that the User may be fraudulent. At a Client’s request, we may verify information with our Data Providers in line with AML/CFT requirements, including screening for adverse media mentions or checking for residency in high-risk countries. Additionally, we examine whether Users are creating multiple identities by determining if a User has been previously verified for a particular Client using biometric data comparison methods.
All these checks are intended to assist us and our Clients in evaluating the likelihood of a User’s trustworthiness, identifying potentially fraudulent activities, and assigning an appropriate risk score when Users create multiple identities, compromise their data, or manipulate device or network information. Clients may consult the fraud detection and control system regarding the level of fraud-related risk of Users during onboarding, without accessing any Personal Data..
• Automated Decision Controls
We perform identity verification checks on behalf of Clients, but we do not make any final decisions. Our role is limited to providing Clients with reports detailing the verification process and results, including reasoning that reflects the level of fraud or other risks, if any. These findings are generated by our system and its algorithms, which combine machine learning models with human supervision and intervention. The final decision regarding User onboarding is made by a human at the Client’s side once the check results are transmitted. Clients use this information to determine whether to accept or reject a User application, request additional checks, or continue servicing the User based on their risk assessment and investigations.
The checks may be automated, semi-automated, or performed entirely by humans. When conducting these checks, we employ a complex verification system that combines human oversight with machine processing. A human intervenes if the system cannot reach a decision independently or needs to re-evaluate a system-generated verdict. This typically occurs when the data is ambiguous or the system encounters difficulties in analysing information during the verification session. In this way, we help ensure that the verification process is fair and secure for Users.
Some Kycaid checks may be fully automated due to their simplicity, the use of machine learning, or at the Client’s request. When Clients rely on these check results to make final decisions regarding Users undergoing verification, they may automate the decision-making process. In such cases, Clients are required to inform Users of the legal basis for the decision and, if necessary, obtain consent. Users have the right to appeal automated decisions by following the procedures provided by the Client.
As a service provider, we may implement different verification steps for certain Clients, which require full human supervision.
After Successful Verification
Upon successful verification, all required checks have been completed. This indicates that the data you provided is authentic, meets the specific Client’s requirements, and has been approved by the Client. You are now authorized to access and use the service for which you completed the verification process.
Upon Verification Failure
Some checks may need to be repeated with additional information. This occurs when certain data you provided do not meet a Client’s requirements, appear potentially suspicious, or indicate possible fraud (for example, if the device used to take a photo differs from the one used during the main verification, or if the information submitted is inconsistent). In such cases, we return the results to the Client with a relevant tag (e.g., 'WRONG_ADDRESS' or 'WRONG_INFO'). The service for which you initiated the verification will then review and assess the results, requesting further information from you to clarify your application. Following its risk assessment or internal policies, the Client may reject or freeze your application.
• Ongoing Data Monitoring
Client Users are monitored daily in line with existing rules, with checks for any changes in their characteristics or status. This information is then provided to the Client to support subsequent decisions regarding the User’s status. Kycaid’s role is limited to providing this information for informational purposes only.
• Enhancement of Services
Our Clients rely on our Services to determine whether the person undergoing identity verification is genuine, as well as to detect impersonation or spoofing attempts, preventing money laundering, terrorist financing, fraud, and other activities of public concern. As a service provider, we are therefore responsible for delivering high-quality services. Accordingly, where authorized by our Clients and not prohibited by applicable law, we, as a Data Controller, use Personal data to develop and enhance our Services by improving algorithms, testing new verification methods, and creating new products and services.
We accomplish this in two ways. First, we deploy a system that identifies specific patterns in data and makes predictions on new datasets using these patterns through algorithm training, commonly referred to as 'machine learning.’ Machine learning helps create models from the information provided by Users, such as indicators of potentially false data, and selects the most effective models for integration into our system. Service development also involves continuous improvement and evaluation. We review our service delivery methods to ensure compliance with Clients’ requirements and proper functionality by testing and refining new features. Additionally, we provide initial and ongoing training for our analysts to oversee these processes, preventing automatic decisions by machine learning models. This is especially important while the models are still under development and not yet fully capable of performing these tasks independently.
• Reusable Know Your Customer (KYC)
In this model, our Clients may collaborate to streamline and accelerate verification for mutual Users who have already completed KYC via Kycaid. Clients may request Kycaid to establish a data flow that shares previously verified Kycaid KYC data between different services. Kycaid provides this functionality only after confirming that the Clients have all required legal arrangements in place. Users are asked for their consent before any data is shared.
6. Personal Data Processed by Kycaid
Depending on the specific Service provided to Clients, we may collect and process the following types of Personal data from Users:
| Types of personal data | Sample Data |
|---|---|
| General data | Full name, sex, personal identification code or number, date of birth, legal capacity, nationality and citizenship, location (street, city, country, and postcode). |
| Identification Document Information | Document type, issuing country, number, expiry date, MRZ, embedded barcode information (depending on the document), and security features. |
| Biometrical data | Facial characteristics. |
| Facial image data | Photos of the user’s face (including selfies), images or scans of the face on identification documents, videos, and audio recordings. |
| Contact details | Phone number, address and e-mail address |
| Banking details | Cardholder’s name, expiration date, first six and last four digits of the card number. If the Client uses Enable Banking: account details, balances, credit limits, and transaction history. |
| Credit Data | If the Client uses TransUnion of Canada Inc.: credit information records |
| Technical data | Information about dates, times, and activities within the Services; IP address and domain name; hardware and software characteristics (e.g., camera type and name); and general geographic location (e.g., city, country) of the User’s device. |
| Transaction data | Full names of both sender and recipient, their addresses, and the unique identifiers of the counterparties as provided by Kycaid and the respective Client. |
| Crypto transaction data (Crypto Travel Rule Solution and Wallet Address) | Full names of sender and recipient, sender’s physical (geographical) address, national ID or customer identification number (not the transaction number) uniquely identifying the originator to the ordering institution, date and place of birth, recipient account number (e.g., wallet address), wallet address hash, asset type, blockchain, creation and update dates, VASP ID owner, source type, source provider, and client ID. |
| Geolocation data | IP address. |
| Unique identifier | ID assigned to the Applicant solely for the purpose of identifying the User within the Kycaid system. |
| Publicly Available Information | Information about a person’s status as a Politically Exposed Person (PEP) or inclusion on sanctions lists. |
| Device Behavior Information | User ID, device fingerprint (screen size, user agent, browser, incognito mode, device type, operating system, geolocation), screen resolution, session language settings, operating system verification, window focus/blur activity, and time of day. |
| Supplementary information | Data submitted by the User during interactions with Kycaid (e.g., requests, reports). |
7. Legal Basis for Personal Data Processing
When our Company is tasked by its Clients to carry out identity verification procedures for their Users, the processing of Personal data by Kycaid is based on the legal grounds relied upon by those Clients under their Agreements. In accordance with Article 6 of the EU and UK GDPR, Controllers must have a valid legal basis for processing Personal data. The majority of our Clients rely on the following legal grounds for such processing:
- 1.
Article 6 (1)(a) of the GDPR: “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”;
- 2.
Article 6(1)(c) of the GDPR: “[personal data] processing is necessary for compliance with a legal obligation to which the controller is subject”;
- 3.
Article 6(1)(e) of the GDPR: “[personal data] processing is necessary for the performance of a task carried out in the public interest”;
We may handle your Special Categories of Personal data when a Client has a valid legal basis for such processing. Clients processing biometric data to uniquely identify a User typically rely on the following legal grounds:
- 1.
Article 9(2)(a) of the GDPR: “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provides that the prohibition referred to in paragraph 1 may not be lifted by the data subject”;
- 2.
Article 9(2)(g) of the GDPR: “processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject”;
For the exact legal basis of processing Special categories of personal data, please refer to the privacy policy of the Client whose services you want to use.
When Kycaid pursues its objectives, as outlined in Section 3 of this Notice, it relies on Article 6(1)(f) of the GDPR – legitimate interest. This legitimate interest stems from the essential need to conduct internal analysis and continuously develop and enhance Kycaid’s Services, which Clients use to detect fraud and unlawful activities, prevent money laundering, terrorist financing, and other actions considered of significant public interest in some jurisdictions. In such cases, Kycaid relies on its legitimate interests only if the Client has granted permission to process data for Kycaid’s purposes.
When Kycaid acts as a data controller to provide Applicants with Kycaid ID, the processing of standard Personal data is based on the necessity to perform a contract with the Applicant (Article 6(1)(b) of the GDPR). Biometric data processing within the Kycaid ID Section is carried out on the basis of the Applicant’s explicit consent (Article 9(2)(a) of the GDPR).
Kycaid may be subject to a “litigation hold” requirement, including an ongoing legal claim, judicial procedure, or other legal obligation. In such cases, Kycaid relies on the legal basis under Article 6(1)(c) of the GDPR, which provides that processing Personal data is necessary to fulfill a legal obligation to which Kycaid is bound.
8. Processing personal Data of Children
Kycaid may handle Personal data of children, defined as individuals below the age of majority according to the national laws of the Client’s country of incorporation, provided that the person with parental responsibility has given consent, or in cases where the child is legally able to consent to processing themselves under applicable national laws. As the data controller, the Client is responsible for determining when parental consent is necessary, considering the type of Personal data collected, and for ensuring compliance with regulatory requirements and age limits regarding data processing without parental consent in the jurisdictions where the Client operates and collects data. If Kycaid becomes aware that a child’s Personal data has been submitted without the required parental consent (for example, during an internal audit), such data may be removed without undue delay.
9. eID-Based Identity Verification
This part of the Privacy Policy describes how data is processed within the services related to issuing a qualified electronic signature or seal, enabling an entity to establish a business relationship through the eIDAS repository framework.
This section is applicable once the procedures and relevant documentation for the eIDAS framework are made publicly available in Kycaid’s repository.
Scope of services
Prior to establishing a relationship with a Client, the User must have successfully completed an identity verification procedure using any of the available Kycaid methods. Successfully passing the Know-Your-Business (KYB) verification enables access to Kycaid’s repository framework
Data storage
The requirement to retain Personal data is established in line with the eIDAS framework regulations, together with applicable national laws, to ensure the security and proper functioning of the provided services.
Application of the Privacy Policy to this section
The Privacy Policy provisions describing the relationship in which Kycaid acts as a processor on behalf of a Client (the data controller) may also apply to the relationship outlined in this section, upon the Client’s request. This ensures compliance with the Client’s applicable AML/CFT, anti-fraud laws and regulations, age-related restrictions, and other legal or regulatory requirements, as well as the Client’s customer due diligence procedures in accordance with the laws governing the intended business relationship.
All other sections of the Privacy Policy remain applicable to this section unless explicitly stated otherwise.
10. Duration of Personal Data Storage
The duration of data retention is determined by the specific purpose of processing. Clients decide how long Personal data should be kept and when it should be deleted. Typically, in accordance with AML/CFT requirements, regulated financial institutions must retain User data for five years following the end of the Client–User relationship or the date of a one-off transaction. In certain jurisdictions, the mandatory retention period may be longer.
Please note that if you, as a User, wish to request the deletion of Personal data you provided for a specific Client, such requests should be submitted directly to the Client responsible for your verification process. For further guidance, refer to Section 11.
Generally, Personal data, including biometric information, is retained and stored by Kycaid and will be permanently deleted according to the Client’s instructions once the Client’s initial purpose or the retention period required by applicable law has expired, but not exceeding the duration of the contractual relationship with the Client.
When Kycaid determines compatible purposes independently or is subject to a legal requirement, Personal data, including biometric data, will be deleted once Kycaid’s purposes for collecting such data have been fulfilled. For residents of Texas, this occurs one (1) year after the purpose’s expiration, or five (5) years from the date the data was submitted to the Kycaid system, whichever comes first. For residents of Illinois, the retention period for Personal data, including biometric information, is three (3) years from the date the data was submitted to the Kycaid system.
Data Deletion and Destruction Policy
Personal data is only deleted after (a) receiving a data deletion request from the applicant in accordance with the applicable Client or Data Subject procedures, or (b) once the purpose for which the data was collected has been fulfilled, including the termination of the agreement with the Client or the expiration of the retention period required by law.
To remove data from the Kycaid Identity Verification System (Dashboard and storage space), a method is used to locate the applicant’s unique identifier (Applicant ID) within the database. This database contains references, or object IDs, linked to the applicant’s Personal data stored in the system. The deletion of biometric data ensures it is irrecoverable, even through forensic recovery techniques.
When deleting data from equipment, measures are applied according to the device’s specific operating system. If the goal is to make the information unrecoverable, deletion should be performed by the owner of the data (usually the creator) using mechanisms such as the “empty trash” function. If these methods are insufficient given the sensitivity of the information and it could potentially be recovered, the storage medium must be completely destroyed (e.g., shredded, disintegrated, pulverised, or incinerated in a licensed facility) in the presence of the data owner.
For data stored on removable media, the appropriate sanitisation tools and settings are used—either clearing or purging. If purging does not guarantee sufficient security due to the sensitivity of the information, the removable media must be fully destroyed (e.g., shredded, crushed, disintegrated, pulverised, or incinerated in a licensed facility).
Handling sensitive data on any equipment, removable media, or mobile devices is strictly prohibited.
Requests to delete all or part of a User’s Personal data are processed within 30 days, a timeframe determined by the complexity of Kycaid’s systems and technologies used for data processing.
For processing purposes beyond those described above, Kycaid applies retention periods that take into account the volume, nature, and sensitivity of the Personal data, as well as the specific purposes for which the data may be lawfully processed.
When developing and enhancing identity verification services aimed at preventing and identifying fraud or other illicit activities, Personal data will be stored in a pseudonymised form for the duration necessary to fine-tune and select the most effective algorithms and models for fraud detection. Certain records may also be retained if they relate to confirmed fraudulent applications or accounts, or for the purpose of demonstrating compliance with legal obligations both within and outside the EU and the UK. For instance, logs of consent activity are kept according to periods established by legal limitation rules, relevant regulatory requirements, contractual obligations, and industry standards.
If the data retention is related to the establishment, exercise, or defence of legal claims (“litigation hold”), the data will be retained only for the duration of the specific proceedings or circumstance.
In all instances, Personal data is not kept beyond the period for which a lawful basis for processing exists.
11. Your Rights as a Data Subject
Upon receiving a written request from a Client, Kycaid provides assistance in enabling the Client to facilitate the exercise of Data Subjects’ rights. In accordance with applicable privacy legislation, you are entitled to the following rights:
- to receive confirmation regarding whether your personal data are being processed;
- to have your personal data rectified, meaning to correct inaccurate information or complete incomplete data;
- to request the erasure of your personal data (the “right to be forgotten”). Please note
that this right is not absolute and applies only if:
- your personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- you object to the processing and there are no overriding legitimate grounds for the Client’s processing;
- your personal data have been processed unlawfully.
- to restrict the processing of your personal data where:
- the accuracy of the personal data is contested (for the period during which the Client can verify its accuracy);
- the processing is unlawful, and you object to the erasure of the personal data and request the restriction of their use instead;
- the Client no longer needs the personal data for the purposes of processing, but it is required by you to establish, exercise, or defend legal claims;
- you have objected to the processing pending verification of whether the Client’s legitimate grounds override yours.
- to be informed about the rectification or erasure of your personal data, or the restriction of their processing;
- to data portability, meaning the right to receive your personal data in a suitable format so that you can provide it to another party or request the transfer of your personal data from one controller to another;
- to object to the processing of your personal data when such processing is based on the legal grounds of public interest or legitimate interest, as specified in points (e) and (f) of Article 6(1) of the GDPR;
- not to be subject to a decision based exclusively on automated processing, unless one of
the following applies:
- the decision is necessary for entering into or performing a contract between you and the Data Controller;
- the decision is permitted by the law applicable to the Data Controller and such law also provides appropriate safeguards for your rights, freedoms and legitimate interests;
- the decision is based on your explicit consent;
- to lodge a complaint with a supervisory authority. If you wish to raise a complaint regarding the processing conducted by one of our Clients (i.e., the service for which you underwent verification), please use the channels indicated in that Client’s privacy policy. If your concern relates to Kycaid’s own processing activities (you can verify this it here), you may submit a complaint using the following link.
To exercise any of the rights above, or to request that Kycaid forward your inquiry to the relevant Client, please send an email to [email protected]. We will respond with details on the measures taken within one month of receiving your request. If necessary, and depending on the complexity or volume of requests, this period may be extended by up to two additional months. In such cases, we will notify you of the extension and provide the reasons within one month of receiving your request.
Please note that when you request the exercise of any of the rights described above, we may need to verify that you are the legitimate owner of the data or otherwise authorized to make the request, either due to a Client’s instructions or our own legal obligations.
Kycaid ensures that submitting a request to access your Personal data is free of charge, except in cases where requests are manifestly unfounded, excessive, or repetitive, in which case a reasonable fee may apply.
12. Revoking consent and raising an objection to the legitimate interest mechanism
Kycaid assists Controllers (Clients) with providing mechanisms for withdrawal of consent (Article 7(3) EU
GDPR and UK GDPR) and objection to processing based on legitimate interests (Article 21(1) EU GDPR and UK
GDPR).
Depending on the legal grounds a Client relies on for processing (e.g., consent or legitimate interest),
the right to withdraw consent or to object to processing may be exercised.
Kycaid does not independently decide on such requests, as it acts solely in accordance with the written instructions of Clients, who remain the controllers of the Personal data. Kycaid’s role is limited to forwarding a User’s request to the relevant Client for whom the verification was performed.
To withdraw your consent or object to processing by Kycaid, you can submit your request by sending an email to: [email protected]. Please note that to object to processing based on legitimate interest, your grounds must outweigh ours. Due to the critical role of identity verification and fraud prevention in the global financial system—considered a matter of public interest—it is uncommon that we will have no compelling reason to continue processing Personal data despite an objection.
In most cases, there are more appropriate alternatives than fully stopping the processing. For instance, it would be unsafe to hide records of prior fraudulent activity, as this could allow someone to impersonate another person and misappropriate funds.
13. Duties
13.1. Kycaid’s Duties and the DPO
Kycaid is responsible for implementing and maintaining policies and procedures to ensure compliance with both the EU GDPR and UK GDPR. You can contact our Data Protection Officer (DPO) at: [email protected].
13.2. Data Protection Officer (DPO) Responsibilities
Kycaid’s Data Protection Officer is tasked with:
- Investigating and responding to data protection complaints, including handling Data Subject requests;
- Developing guidance and promoting adherence to this Privacy Policy;
- Managing, recording, and reporting any Personal data breaches promptly and appropriately;
- Ensuring compliance with the EU GDPR, UK GDPR, and the Data Protection Act 2018.
13.3. Kycaid Staff Duties
Kycaid staff involved in Personal data processing comply with the requirements of this Privacy Policy and other internal rules. This staff ensures:
- Preventing any unauthorized disclosure of Personal data, whether verbally or in writing, accidentally or intentionally;
- Keeping all Personal data securely;
- Immediately reporting any data protection breaches to management and the Data Protection Officer;
- Seeking guidance from the Data Protection Officer whenever there is uncertainty regarding a data protection matter.
- Promptly directing any queries, requests, or complaints regarding data protection to the Data Protection Officer;
13.4. Third-Party Processors operating on behalf of Kycaid
When Kycaid engages third-party companies to process Personal data on its behalf, Kycaid retains responsibility for ensuring the security and proper use of that data. Prior to engagement, Kycaid verifies that the Third-Party Processor provides adequate guarantees for data protection. Specifically, a written agreement is established outlining the types of Personal data to be processed, the purposes of processing, and including provisions for Personal data protection.
14. Particular actions to guarantee data security
Kycaid implements concrete measures to protect Personal Data, including, but not limited to, the following:
- Kycaid’s specially designed API interface (iFrame) allows Data Subjects to submit their Personal Data directly to Kycaid’s secure servers;
- Whenever applicable, the processing of Personal Data is carried out in accordance with relevant Agreements, Non-Disclosure Agreements, and Data Processing Agreements that comply with the EU GDPR and the UK GDPR;
- All Personal Data is stored securely on Google Cloud servers located in secure European data centres, including those in Belgium, meeting high-level security standards;
- Staff involved in Personal Data processing are officially authorised, undergo mandatory background checks where required, and participate in regular training.
- Personal Data is encrypted at all times;
- For certain types of Personal Data (e.g., children’s Personal Data or sensitive data under applicable laws) that may be unlawfully processed, Kycaid takes all necessary steps to promptly identify and either delete or, where appropriate, encrypt such data upon submission;
- Kycaid conducts regular internal and external audits of data protection and information security, along with vulnerability assessments. Compliance with the EU GDPR, the UK GDPR, ISO/IEC 27001, SOC 2 Type 2, and PCI DSS standards is continuously verified;
- Physical, software, and network security measures, as described below, are implemented to ensure comprehensive protection.
15. Disclosure of Personal Data
15.1 Third Parties
With the Client’s consent, Kycaid may engage third parties to perform data processing activities, which include the following categories:
- Third-party processors, as reasonably required, to carry out a section of the Service under an Agreement with the respective Client that engages them to process certain data;
- Data providers, when their services are necessary for the provision of a section of the Service under an Agreement with the respective Client.
Kycaid requires that third parties respect the security of Personal Data and handle it in accordance with applicable law. Furthermore, third parties are generally restricted to accessing or using Personal Data solely for the purpose of providing services to Kycaid and must give reasonable assurances that they will safeguard the data appropriately, in line with Section 13.4 of this Notice.
In some cases, certain third-party subprocessors may engage specific data providers who are permitted to maintain and use the data for their own legitimate purposes.
15.2. Recipients
Where required by law, Kycaid may need to disclose Personal Data to recipients, which include the following categories:
- Governmental and regulatory authorities, judicial bodies, investigative bodies, sworn bailiffs, and notaries, based on written and specific requests or in accordance with legal obligations binding on Kycaid or its Clients. Such disclosures are made in strict compliance with the derogations provided under the EU GDPR and the UK GDPR;
- Other Clients, where there is a legitimate interest or other legal basis, obtained consent, or where Kycaid has been instructed to share the information on behalf of our Clients as outlined above.
16. Managing Personal data breaches
In the event of a Personal Data breach, or if a breach is suspected, it must be reported immediately to the Data Protection Officer (DPO) or a company director. Where applicable, the breach is also reported to the relevant data protection authority, the respective Client, and, if necessary, the individual affected.
The report provides complete and accurate information about the incident, including its causes and scope, and outlines the corrective measures planned to address and mitigate the breach.
17. Cross-Border data transfers
Kycaid confirms that all Personal Data is stored on its servers located within the EU and/or in accordance with any national data localisation requirements applicable in specific jurisdictions. Clients have the option to select the location for Personal Data processing (including storage) to ensure compliance with the relevant legal provisions.
Where it is necessary for the provision of the Service or to enable convenient and reliable communication with Data Subjects, Kycaid may transfer Personal Data outside the EU/EEA, the UK, or other relevant jurisdictions (if applicable), to the third parties and recipients listed in Section 15 of this Notice.
Whenever Personal Data is transferred outside the EEA or the UK, Kycaid applies appropriate safeguards in accordance with Chapter V of the EU GDPR or the UK GDPR. Such transfers are conducted on the basis of an EU Adequacy Decision (or UK Adequacy Regulations) or through the use of Standard Contractual Clauses. Third-party processors also rely on suitable safeguards, including binding corporate rules, Standard Contractual Clauses, or other lawful mechanisms.
Cross-border transfers of Personal Data from the UK to EU/EEA countries are permitted by the UK Government. For international data transfers from other jurisdictions (when services are provided on behalf of companies outside Europe), Personal Data is transferred either to countries with an adequate level of protection or using data transfer mechanisms permitted under applicable laws, such as appropriate contractual measures.
To maintain transparency and comply with applicable data protection legislation, Kycaid outlines below the non-EU countries to which Personal Data may be transferred, along with the relevant safeguards applied.
18. Special Provisions for residents of the states of Illinois, Washington, or Texas (USA)
Kycaid may process certain types of Personal Data classified as biometric identifiers (including facial geometry scans and voiceprints) and biometric information (data generated from such identifiers) for the purpose of verifying the identity of Users.
Whenever such biometric identifiers and/or biometric information (together referred to as “biometric data”)
are used as part of the Services provided by Kycaid to any Client, this data is processed by Kycaid on the
Client’s behalf and permanently deleted in accordance with Section 10 of this Notice. In such cases, Kycaid
does not carry out any actions involving this data other than storing it for the period required under the
applicable law.
In all cases, Kycaid collects and processes biometric data only after obtaining the written
informed consent of the relevant Data Subject. If there is any conflict or inconsistency between other Sections
of this Privacy Policy and the provisions of this special notice, the latter shall prevail whenever the laws
of the states of Illinois, Washington, or Texas (USA) govern the legal relationship between Kycaid and a Data
Subject.
Clients are independently responsible for complying with the privacy regulations, including BIPA, providing all necessary disclosures and obtaining all required consents.
19. Sale of personal data and CCPA Compliance
Kycaid does not sell Personal data and strictly complies with restrictions and prohibitions under CCPA and the EU or the UK GDPR.
Kycaid is committed to complying with the California Consumer Privacy Act (CCPA) and other applicable California privacy laws. This section supplements our main Privacy Policy and applies to California residents who provide personal information to Kycaid.
The following categories of personal information may be collected, processed, and stored by Kycaid in the course of providing services to California residents:
| Identifiers | Full name, postal address, email address, Internet Protocol (IP) address, Social Security number, driver’s license number, identity document details (such as type of document, issuing country, number, expiry date, MRZ, data encoded in document barcodes, which may vary depending on the document, and security features), or other similar identifiers. |
| Categories of Personal Information as defined in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Full name, signature, Social Security number, postal address, email address, telephone number, identity document details (including document type, issuing country, number, expiry date, MRZ, data encoded in document barcodes, which may vary depending on the document, and security features), driver’s license or state ID card number, bank account information, credit or debit card information (including cardholder name, expiry date, and the first six and last four digits of the card number), or any other financial information, such as documents provided to verify the source of funds or wealth. |
| Protected characteristics or classifications as recognized under California or federal law | Age (applicable to Users over 40) and citizenship. |
| Commercial information | Records of personal assets |
| Biometric information | Facial features. |
| Internet or comparable network activity | History of access and details of your interactions with our services |
| Audio, electronic, visual, thermal, olfactory, or other related information | Photographs of the face (including selfies), images or scans of the face on identification documents, videos, and audio recordings. |
| Professional or job-related information | Occupation, employment details. |
| Confidential personal data | Information related to health, including vaccination certificate data, test certificate data (NAAT/RT-PCR or rapid antigen tests), and certificates for individuals who have recovered from COVID-19. |
Kycaid collects the personal information described above from the following sources: directly from clients or their agents, directly from users, and indirectly through interactions with our services and platforms.
Purpose of Use of Personal Information
Kycaid collects and processes personal information for specific, explicit, and legitimate purposes. As a Business, we use the information to provide our services, maintain communication with clients and their representatives, respond to inquiries, and ensure compliance with applicable laws, regulations, and internal policies.
As a Service Provider, we process personal information to verify identities, perform necessary due diligence, and support our clients’ compliance with regulatory requirements, including automated checks against relevant databases such as sanctions lists, PEP lists, and other public or proprietary sources. Automated processing may include verification of authenticity and cross-referencing information to ensure accuracy and compliance.
Once personal information is no longer necessary for the intended purpose, it is securely deleted or returned to the client upon request.
Kycaid may share personal information with third parties when necessary to provide services, operate our platforms, or comply with legal obligations. Any third parties are limited to using personal information only for the specified purposes and are contractually obligated to safeguard it appropriately.
The categories of personal information that may be shared correspond to those listed in the table above. Kycaid does not sell personal information and only discloses it when required for legal, regulatory, or legitimate business purposes.
California residents have specific rights regarding their personal information under CCPA. Kycaid respects and guarantees these rights, which include:
- Right to know: You may request information about the categories of personal information collected, the purposes for which it is used, and the categories of third parties with whom it is shared.
- Right to delete: You may request deletion of your personal information, subject to certain exceptions. Deletion requests may be denied if retaining the information is necessary to ensure security, exercise legal obligations or human rights, comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.), comply with other applicable laws, or for legitimate business purposes.
Kycaid provides accessible mechanisms to exercise these rights and responds to requests in accordance with CCPA requirements.
California residents may exercise their CCPA rights by submitting a valid request to Kycaid via email at [email protected].Only you or an authorized representative registered with the California Secretary of State may make a request.
Requests must provide sufficient detail to identify the personal information and allow verification of your identity or authority. If identity or authority cannot be verified, Kycaid cannot respond to the request.
As a Service Provider, Kycaid assists businesses in responding to CCPA requests in accordance with the business’s written instructions.
Kycaid endeavors to respond to valid CCPA requests within one month, and no later than two months when additional time is required. Requests are handled in accordance with the procedures outlined in the relevant section 11 of this Privacy Policy, including the method of response, applicable fees, and timeframes.
Kycaid does not discriminate against individuals for exercising their CCPA rights. Unless permitted by law, we will not:
- Deny access to our websites or services;
- Provide a different level or quality of services.
20. Details of the Kycaid company
Kycaid is incorporated in the United Kingdom as a legal entity under the name Compligate Ltd (registration number 15376538) and operates globally.
21. Modifications to this Notice
This Privacy Policy is regularly reviewed and updated to ensure compliance with applicable data protection laws.
Kycaid reserves the right to modify this Notice at any time and for any reason. Any changes will take effect immediately upon posting the updated Privacy Policy on our Website. Users of our Website acknowledge and agree that they are not entitled to receive specific notice of such updates. You are encouraged to review this Privacy Policy periodically to stay informed of any changes.
If you wish to review a previous version of this Privacy Policy, please contact us at [email protected]. Our technical and legal support teams are available 24/7 and will respond to your request promptly.