End-user Privacy Policy
California Notice at Collection/US State Law Privacy Rights: See the US State law privacy rights section below for important information about your rights under applicable US state consumer privacy laws.
Sora ID, Inc. and our subsidiaries and affiliates (“Sora,” “we”, “us” or “our”) provide identity verification and compliance services. This Privacy Policy describes how Sora processes personal information that we collect and process when verifying the identities of our business customers’ end-users (the “Service”). Sora may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.
This Privacy Policy does not apply to our processing of personal information that we collect through our digital or online properties or services (including as applicable, our website and social media pages) as well as our marketing activities, live events and other such activities. For further information in relation to how we process personal information processed in the context of such activities, please see our Website Privacy Policy. For further information in relation to how our business customers may process your personal information, please direct your concerns to that particular enterprise customer.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.
Index
- Personal information we collect
- Tracking Technologies
- How we use your personal information
- How we share your personal information
- Retention of biometric data
- Your choices
- Other sites and services
- Security
- International data transfers
- Children
- Changes to this Privacy Policy
- How to contact us
- US state law privacy rights notice
- Notice to European users
Personal information we collect
- Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
- Demographic data, such as your city, state, country of residence, postal code, and age.
- Financial data, such as your stated income, economic standing, financial account numbers or payment card information.
- Photo ID data, comprised of personal information extracted from a photograph of your government issued photo ID document, including type of document, issuing country, expiration date, information embedded in barcodes, national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number).
- Biometric data, such as the data derived from processing a digital image or video of your face.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
- Third-party sources. We may combine personal information we receive from you with personal information (described above) that we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Data providers, such as information service providers, data licensors and identity verification service providers (such as credit bureaus and data aggregators).
- Business customers.
- Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
- Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Activity data, such as how long you spent on a particular screen, navigation paths between screens, information about your activity on a screen, access times and duration of access.
- Precise geolocation data when you authorize (our mobile application/the Service) to access your device’s location.
Tracking Technologies
Cookies and other technologies. Some of our automatic data collection is facilitated by cookies and other technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
For more information concerning our automatic collection of data, please see the relevant section of our Cookie Notice.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations.
We may use your personal information (including biometric data) to:
- provide the Service; and
- verify your identity in connection with the Service (such as through the use of facial recognition technologies).
In addition to the above, we may use your personal information (excluding biometric data) to:
- identify the use of fraudulent identification documents;
- enable security features of the Service (such as by sending you security codes via SMS);
- establish and maintain your user profile on the Service;
- provide support for the Service, and respond to your requests, questions and feedback.
Service improvement and analytics. We may use your personal information (excluding biometric data) to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service to develop new products and services.
Compliance and protection. We may use your personal information (including biometric data, where applicable) to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information (excluding biometric data). We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, and website analytics, SMS based verification services, and with respect to biometric data, providers that help us verify a user’s identity in connection with the Service).
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Business customers. We may share your personal information (excluding biometric data) with the relevant business customer(s) with which you are applying for a specific financial product or service. For more information on how the relevant business customer processes your personal information, please direct your questions to that enterprise customer.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Sora, financing of Sora, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Sora as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Retention of Biometric Data
For any biometric data that we collect from you, we will retain such biometric data only until (a) the initial purposes for which Sora collected your biometrics data has been satisfied (e.g., to verify your identity), or (b) one year following your last interaction with Sora (e.g., the last time you used our platform or service), whichever occurs first. After such occurrence, we will delete your biometric data in accordance with applicable law.
Your choices
In this section, we describe the rights and choices available to all users. Users who are located in California, or other US states with omnibus consumer privacy laws, or Europe can find information about their additional rights below.
Cookies and other technologies. For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Notice.
Opt-out of communications. If you receive text messages from us (such as in connection with our SMS based verification features), you may opt out of receiving further text messages from us by replying STOP to our message. Any personal information obtained through the short code program will not be shared with any third-parties for their own marketing reasons/purposes. Please see our SMS Terms for more information.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required, we may not be able to provide those services.
Other sites and services
Our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the important information provided below about transfer of personal information outside of Europe.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
CALIFORNIA PRIVACY NOTICE/US STATE LAW PRIVACY NOTICE
Except as otherwise provided, this section only applies to residents of California, Virginia, Colorado and Connecticut (the “Relevant States”). For purposes of this section, personal information has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the Relevant State in which you reside. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of the Relevant States, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.
In some cases, we may provide a different privacy notice to certain categories of residents of these Relevant States, such as job applicants, in which case that notice will apply with respect to the activities it describes instead of this section.
Your privacy rights. You may have some or all of the rights listed below. However, these rights are not absolute, are subject to certain exceptions, and in certain cases we may decline your request as permitted by law.
- Right to information/know. You can request the following information about how we have collected and used your personal information during the past 12 months:
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting and/or selling personal information.
- The categories of third parties with whom we share personal information for targeted advertising purposes.
- Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of third-party recipient.
- Whether we’ve sold your personal information (as “sell” is defined under the Relevant States’ privacy laws), and if so, the categories of personal information sold to each category of third-party recipient.
- Access. You can request a copy of the personal information that we have collected about you.
- Correction. You can ask us to correct inaccurate personal information that we have collected about you.
- Deletion. You can ask us to delete certain personal information that we have collected from or about you, as applicable depending on the Relevant State.
- Opt-out.
- Opt-out of the “sharing” of personal information (i.e., tracking for targeted advertising purposes). If applicable, you may have the right to opt-out of certain tracking activities for targeted advertising purposes (also known as interest-based advertising or “sharing” of personal information, as defined under the Relevant States’ privacy laws). However, we do not “share” personal information and have no actual knowledge that we have “shared” the personal information of residents of the Relevant States under 16 years of age.
- Opt-out of the “sale” of personal information. You may have the right to opt-out of the “sale” of your personal information (as “sell” is defined under the Relevant States’ privacy laws) we have collected about you to third parties now or in the future. The right to opt out of personal information sales is separate from our direct communications with you for marketing purposes. However, we do not “sell” personal information and have no actual knowledge that we have “sold” the personal information of residents of the Relevant States under 16 years of age.
- Sensitive Personal Information. If you are a California resident, you may have the right to limit the certain uses or disclosures of sensitive personal information (as defined under California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”)); however, we do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of refusal to provide the Services or legally prohibited changes to the price or quality of the Services.
Exercising your right to information/know, access, appeal, correction, and deletion. You may submit requests to exercise your right to information/know, access, correction, or deletion by emailing us at privacy@soraid.com.
We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
If you are a resident of Virginia, Colorado, or Connecticut, you may ask to appeal any denial of your request in the same manner through which you may submit a request.
Verification of Identity; Authorized Agents. We reserve the right to confirm your residency to process your requests and will need to confirm your identity to process your requests to exercise your information/know, access or deletion rights. As a part of this process, government identification may be required.
Consistent with applicable law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Retention. We will retain each category of personal information identified below for as long as reasonably necessary to maintain the Service, to meet legal and accounting obligations, and for the other purposes described in this Privacy Policy, or as otherwise required or permitted by law, unless specifically authorized to be retained longer. We may anonymize, deidentify and/or aggregate personal information and store it in order to analyze aggregate metrics and trends and for other permitted purposes.
Deidentification. We do not to attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
Personal information that we collect, use and disclose. The chart below summarizes the personal information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. The terms in the chart refer to the categories of information, statutory categories, and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.
Personal information we collect | CCPA statutory category | Categories of third parties to whom we “disclose” personal information for a business purpose | Purposes for which we process each category of personal information | Categories of third parties to whom we “sell” or “share” personal information |
· Contact data | · Identifiers (online) · Identifiers (other) · Commercial information · California customer records | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations · Service improvement and analytics · Compliance and protection · Data sharing in the context of corporate events · To create aggregated, de-identified and/or anonymized data | · None
|
· Demographic data | · Identifiers (online) · Identifiers (other) · California customer records | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations · Service improvement and analytics · Compliance and protection · Data sharing in the context of corporate events · To create aggregated, de-identified and/or anonymized data | · None |
· Financial data | · Commercial information · Financial information · California consumer records | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations · Service improvement and analytics · Compliance and protection · Data sharing in the context of corporate events · To create aggregated, de-identified and/or anonymized data | · None |
· Photo ID data | · Identifiers (online) · California customer records | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations · Service improvement and analytics · Compliance and protection · Data sharing in the context of corporate events · To create aggregated, de-identified and/or anonymized data | · None |
· Biometric data | · Identifiers (online) · California customer records | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations (in some instances) · Compliance and protection (where applicable) · Data sharing in the context of corporate events | · None |
· Device data | · Identifiers (other) · Internet or Network Information | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations · Service improvement and analytics · Compliance and protection · Data sharing in the context of corporate events · To create aggregated, de-identified and/or anonymized data | · None |
· Online activity data | · Identifiers (other) · Commercial information · Internet or Network Information | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations · Service improvement and analytics · Compliance and protection · Data sharing in the context of corporate events · To create aggregated, de-identified and/or anonymized data | · None |
· Data derived from the above | · Inferences | · Affiliates · Service providers · Third parties designated by you · Partners · Professional advisors · Authorities and others · Business transferees | · Service delivery and operations · Service improvement and analytics · Compliance and protection · Data sharing in the context of corporate events · To create aggregated, de-identified and/or anonymized data | · None |
· Other Sensitive Personal Information We do not intentionally collect this other sensitive personal information (i.e., outside of the categories specifically identified above), but it may be revealed in identity data or other information we collect | · Protected Classification Characteristics
| · N/A | · N/A | · N/A |
Notice to European users
General
Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).
Controller. Sora is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of UK law (“UK GDPR”)). See the contact us section for our contact details.
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:
Our Representative in the EU. Our EU representative appointed under the EU GDPR is the Prighter Group. You can contact them:
| Our Representative in the UK. Our UK representative appointed under the UK GDPR is the Prighter Group. You can contact them:
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Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
- Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see ‘How we use your personal information’.
| Purpose | Categories of personal information involved | Legal basis |
| Service delivery and operations |
|
|
| Service delivery and operations | Biometric data |
|
| Service improvement and analytics |
|
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| Compliance and protection | Any and all data types relevant in the circumstances |
|
| Data sharing in the context of corporate events | Any and all data types relevant in the circumstances |
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| To create aggregated, de-identified and/or anonymized data | Any and all data types relevant in the circumstances (excluding biometric data) |
|
| Further uses | Any and all data types relevant in the circumstances |
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Special categories of personal data. You may choose to provide us with biometric data. We will only collect such biometric data where you have provided us with your explicit consent to its use for the specific purpose of verifying your identity using automated facial recognition techniques. If you do not want us to process your biometric data, you can choose not to provide us with your consent.
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other info
No obligation to provide personal information. You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.
No sensitive information. Other than as set out in ‘Special categories of personal data’ above, we ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.
No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We provide our analysis to our business customers and our business customers make decisions that may affect you. If you have any questions about a decision taken by one of our business customers, we recommend that you direct your question to the relevant business customer.
Security. We have put in place procedures designed to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.
Your rights
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
- Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by email to the details listed in the contact us section. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
- For users in the United Kingdom – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
- Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
- However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on (including, where applicable, a copy of) the specific mechanism used by us when transferring your personal information out of Europe.