This article contains a brief breakdown of some of the interesting elements of the policy.
- 1.1.- AgeID is operated through a company called Colbette II Limited, registered in Cyprus.
- 2.3 - "We strongly recommend that you review the privacy policies of any website which you use AgeID to log into before using them or providing them with any personal information."
Why do we collect information?
- 4.2 - "If you would like to have your age verified by us, we will require certain personal information from you so that this can be checked with a third party who is then able to confirm your age to us. One a Personal User's age has been verified, they will be granted a 'Universal Login' which they will be able to use to access websites operated by Business Users."
Information we collect
- 5.1 - "We only collect a limited amount of information by which Users may be personally identified ('personal information'). We do not collect personal information about Personal Users' visits to the Business Users' websites (or particular content on those websites)."
- 5.2 - "When you access our website from a mobile device like a tablet or phone, we receive information about your approximate location from your IP address, information about your device, including one or more unique identifiers for your device, and your mobile carrier."
Information collected automatically
- 5.3.1 - "Information about your computer and internet connection. This includes your internet protocol address ('IP address'), your country of location (so we know which version of the website to display), operating system and browser and platform type (e.g., a Firefox browser on a Macintosh platform) and language, access times and the content of any undeleted cookies that your browser previously accepted from us.
- 5.3.2 - "Information provided by cookies (or browser cookies). Cookies are small text files that are stored in your web browser or downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie, and allow a website to recognise a user's device."
- 5.3.4 - "Information provided by device identifiers. When you use a device like a tablet or phone to access our Platform, we may access, collect, monitor, store on your device, or remotely store one or more 'device identifiers'. Device identifiers are small data files or similar data structures stored on or associated with your mobile device. A device identifier may be data stored in connection with the device's operating system or other software, or data sent to the device by the Platform. It does not identify the specific device. Some features of the Platform may not function properly if use or availability of device identifiers is impaired or disabled."
Purposes for which we use your personal information
- 6.1 - "We use information that we collect about you or that you provide to us for following purposes:"
- Age verification
- Provision of services
- Customer management
- Functionality and security
- As informed (i.e. in any other way)
Disclosure of your personal information
- 7.1.1 - Personal information may be transferred in the event of a merger/restructuring/dissolution etc.
- 7.1.2 - Information may be transferred "in response to a summons or similar investigative demand", court orders etc.
- 7.1.3 - Information may be disclosed in the course of taking action regarding illegal activity, fraud etc.
- 7.2 - Aggregated information and statistics may be disclosed where it "does not identify any individual".
How we store your personal information
- 9.1 - "We do not transfer any personal information relating to our Personal Users outside of the European Economic Area. All data relating to Users is stored on servers in Amsterdam and is not replicated anywhere else."
Retention of personal information
- 10.1 - "We keep [your personal information] for as long as you have an account with the Platform."
- 10.2 - "If you delete your Universal Login, or it is closed for any reason, we retain your information to the extent this should be necessary to comply with have legal, auditing or account obligations or it is in our archive system. Where possible, your personal information will be anonymised."
- 10.3 - "Personal information used for functionality and security purposes will be stored as long as necessary to ensure the proper operation and the security of our Platform and services."
- 10.4 - "The period for which we keep your personal information that is necessary for compliance and legal enforcement purposes varies and depend (sic) on the nature of our legal obligations and claims in the individual case."
How we protect your personal information
- 11.1 - "We take appropriate security measures ... to safeguard your personal information from unauthorised access and disclosure.
- "only authorised employees are permitted to access personal information, and they may only do so for permitted business functions"
- "In addition, we use encryption in the transmission of your personal information between your system and ours, and we use firewalls to help prevent unauthorised persons from gaining access to your personal information."
Choices about how we collect, use and disclose your personal information
- 12.2 - Notes that you can choose not to provide certain information, "but that may result in you being unable to use certain features of our Platform".
- 12.5 - "You may delete your Universal Login at any time. If you do so, your personal information and any and all other account related information including, but not limited to, user profile data, sharing data and any other data, or content specifically associated with your account will no longer be accessible with you."
- 13 - "In accordance with the Data Protection Act 1998 you have the right to access any personal data that we hold relating to you. ... If you would like a copy of this information, please write to us at section 19."