Charge’s Privacy Policy

Charge Technology Group, Inc. (“Charge”) respects the privacy of our users. This Privacy Policy (“Policy”) describes our privacy practices concerning information collected in connection with Charge’s payment, verification, and related online services, including but not limited to Authentication, Checkout, Document Verification, ID Verification and Identity Verification (the “Services”). A separate policy, available here, describes our privacy practices in connection with our online website, located at www.charge.io. Charge makes the Services available to third parties for integration into those third parties’ websites, applications, and online services. Charge collects, uses, and discloses individual users’ information only as directed by these third parties and, accordingly, under applicable data protection laws, Charge is a processor or service provider (“data processor”) of user information with respect to the Services and not a controller or business (“data controller”). Further, some features of the Services may be disabled or altered by the data controller, or the data controller may require Charge to collect, use, disclose, or otherwise process data in ways that differ from those described below. Thus, to fully understand how your information will be handled when you use the Services, you must review not just this Policy, but also the privacy policy of the third party with whom you are dealing directly (the “Customer Data Controller”). As an exception to the above, Charge processes personal information in the capacity of a data controller and a business to comply with its regulatory obligations. For further information please review the section “Charge acting as a data controller” below.

Charge is headquartered in the United States at 1100 Highland Ave, Manhattan Beach, CA 90266.

What personal and other information Charge collects about you

Charge collects “personal information” about users of the Services. “Personal information” is information such as a name, email address, or identification card image, which refers to an identified or identifiable person. Charge processes personal information on behalf of the Customer Data Controller. For its own purposes, Charge only processes the personal information described in section “Charge acting as a data controller” and anonymized and/or aggregated information. “Anonymized information” is information which does not relate to an identified or identifiable person or is rendered anonymous in such a manner that the person is no longer identifiable.

Personal information. Charge collects a wide range of personal information through the Services. This information varies depending on the Charge application and the Customer Data Controller in question, but may include such information as name, physical address, email address, telephone number, social security number, driver’s license number, state or national ID card number, passport number, other ID card number, credit or debit card number, CVV, expiration date, and/or date of birth. In some cases, Charge may collect a visually scanned or photographed image of your face and/or your identification card, driver’s license, passport, utility bill, bank account statement, insurance card, or credit/debit card. This image may include your photograph and other information from the imaged document, such as your eye color, weight, height, and organ donor status.

Information for Illinois residents: Charge’s collection of personal information may include biometric identifiers and/or biometric information (collectively “biometric data”), and Charge may share such biometric data with the Customer Data Controller. Charge may collect, process and store your biometric data for the purpose of verification services and long-term proof of inspection of your provided form of identification, on behalf of and as instructed by the Customer Data Controller. Charge will store your biometric data for as long as the Customer Data Controller requests (e.g., the duration of your use of its services), which shall be no longer than the earlier of the date when (i) the Customer Data Controller ceases to have a relationship with Charge or (ii) within three (3) years after the Customer Data Controller informs Charge that its last interaction with you has occurred.

Facial recognition. If you agree to use our Biometric Facial Recognition, or other facial recognition service that we offer to our business customers, Charge will collect an image of your face that you provide through a mobile app (i.e. a selfie) and a photo or scan of your face as it appears on an identification document. Charge will use facial recognition technology only for the purpose of verifying your identity as the person who appears on the identification document. Charge may share the facial scans with the Charge customer through which you used Charge’s identity verification service. Charge will retain your facial recognition information, including the photo of your face and photo or scan of your identification document, for the amount of time requested by the Charge customer through which you used Charge’s identity verification service. In no event will Charge store your facial recognition information after Charge ceases to have a customer relationship with the customer through which you used Charge’s identity verification service.

Data provided by third parties. We may receive personal or anonymized and/or aggregated information about you from the Customer Data Controller that integrates the Services into its website, application, or other online service. This information includes a customer ID, selected by the Customer Data Controller, that uniquely identifies you in the third party’s database. For additional information, review the privacy policy of the Customer Data Controller.

At the direction of the Customer Data Controller, Charge also might obtain information about you from other third parties, such as consumer reporting agencies and fraud-prevention services.

Cookies and other tracking data. When you use the Services, we automatically receive and record certain information from your computer (or other device) and/or your web browser. This may include such information as the third-party website or application into which the Services are integrated, the date and time that you use the Services, your IP address and domain name, your software and hardware attributes (including operating system, device model, and hashed device fingerprint information), and your general geographic location (e.g., your city, state, or metropolitan region; or your geolocation (GPS coordinates) if available). If you use the Authentication service, we may install little pieces of software (called: service workers) on your device to increase the speed of the next and following verifications. The service worker does not collect any data about you and does not track you. We will process such data only as instructed by the Customer Data Controller, or as required for Charge to meet its obligations relating to its own regulatory compliance. We also use cookies in connection with the Services. For further information please refer to the section entitled “Cookies” below.

Cookies

What are cookies? Cookies are small files that are stored on your computer or other device by your web browser. A cookie allows Charge to recognize whether you have used the Services before and may store user preferences and other information.

How are cookies used? For example, cookies can be used to collect information about your use of the Services during your current session and over time, your computer or other device’s operating system and browser type, your Internet service provider, your domain name and IP address, and your general geographic location or geolocation. We process personal information generated by cookies only as instructed by the Customer Data Controller.

What kind of cookies are used on the Website? Our website primarily uses the following types of cookies:

Cookie Name Cookie Type Purpose
__qa Persistent cookie This cookie is used to distinguish users and expires after 2 years.
__gat Session cookie This cookie is used to throttle the request rate and expires after 10 minutes.

__gatSession cookie This cookie is used to throttle the request rate and expires after 10 minutes.“Session cookies” are temporary bits of information which are deleted when you exit your web browser. Session cookies are typically used to improve navigation and to collect web statistics.

“Persistent cookies” are more permanent bits of information that are stored and remain on your computer until they are deleted by you. This type of cookie stores information on your computer for a number of purposes; such as saving your passwords. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.

How do you avoid cookies?If you are concerned about having cookies on your computer or device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.

How Charge uses the personal and anonymized/aggregated information that we collect

In general, Charge uses the personal and anonymized and/or aggregated information that we collect in connection with the Services as discussed in this section of the Policy. Other than as described under the section “Charge acting as a data controller” personal information is used by Charge only as directed by the Customer Data Controller that integrates the Services into its website, application, or other online service. Subject to the privacy policy of the Customer Data Controller, we use your personal information as follows on behalf of the Customer Data Controller.

Charge may use your personal information to provide the Services. For example, we might use your credit card information or ID card information to populate an online form, or to verify your identity in connection with your use of another online service. We also may use your personal information to fulfill the terms of any agreement between us and the Customer Data Controller; to complete a transaction that you initiate; to deliver confirmations, account information, notifications, and similar operational communications; and to comply with legal and/or regulatory requirements.

Anonymized and/or aggregated information that we collect in connection with the Services is used by Charge for its own purposes to perform analytics and research concerning the Services.

We process the provided personal information manually, by our specially trained verification agents or automatically with the use of our software and machine learning capabilities. When we process the personal information automatically, we apply especially the following criteria:

  • Checks on the integrity and quality of the photographs;
  • Checks on the integrity and recognition of the document
  • Extracting and analysis of text, graphical layout, and any other available information on the document, face photographs and face maps, background;
  • Analysis of results of all the steps combined, considering multiple variables, predictions and confidence values for a final score;
  • Lookups against known images as well as known cases;
  • In case of identity verification, your selfie is compared to the photo on the document and is used to ensure your liveness in the selfie.

Please reach out to the Customer Data Controller responsible for your personal information with any inquiries regarding the rights you may have in case your personal information is subject to automated decision-making.

How Charge shares personal and anonymized/aggregated information with other entities

In general, Charge shares the personal and anonymized and/or aggregated information that we collect in connection with the Services as discussed below.

Other than as described under the section “Charge acting as a data controller” below, Charge shares personal information only as directed by the Customer Data Controller, and thus the following language is subject to the privacy policy of the Customer Data Controller.

Charge service providers.We share the personal and pseudonymized information that we collect on behalf of a particular Customer Data Controller with that Customer Data Controller.

Customer Data Controller.Charge also uses third-party service providers to help us deliver, manage, and improve the Services. These service providers may collect and/or use your personal information or anonymized and/or aggregated information to assist us in achieving the purposes discussed above in the section entitled “How Charge uses the personal and anonymized /aggregated information that we collect.”

We also may share your personal information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; or to meet the terms of any agreement that you have with us or our partners.

Legal purposes.We also may use or share your personal information with third parties when we have reason to believe that doing so is necessary:

  • to comply with applicable law or a court order, subpoena, or other legal process;
  • to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • to establish, protect, or exercise our legal rights or defend against legal claims; or
  • to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated information. From time to time, Charge may also share anonymized and/or aggregated information about users of the Services, such as by publishing a report on trends in the usage of the Services.

Information for California residents. Charge processes your personal information on behalf of the Customer Data Controller pursuant to a written agreement for verification services. As such, Charge acts as a service provider to the Customer Data Controller. Moreover, Charge does not sell your personal information as the terms “sell” and “personal information” are defined by the California Consumer Privacy Act (the “CCPA”) and, in providing its services to the Customer Data Controller, Charge will not retain, use, or disclose your personal information to any other third parties that would constitute “selling” as the term is defined by the CCPA. Any questions or requests regarding Charge’s processing of your personal information in respect of your rights under the CCPA should be directed to the Customer Data Controller that is responsible for your personal information.

Security

Charge uses commercially reasonable physical, electronic, and procedural safeguards designed to protect your personal information against loss or unauthorized access, use, modification, or deletion. Among other things, Charge encrypts sensitive information both in transit and at rest. Charge regularly conducts security audits, vulnerability scans, and penetration tests to ensure compliance with industry security practices and standards. However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information. Moreover, we cannot guarantee the safety of your information when in the possession of other parties, such as the Customer Data Controller.

Reviewing and updating your information

With the exception of Charge acting as a data controller (please see below), Charge will grant you access to your personal information only as directed by the Customer Data Controller that integrates the Services into its website, application, or online service. Charge also will retain your personal information as directed by the Customer Data Controller and, accordingly, we may retain your personal information for as short as a few minutes or longer as directed by the Customer Data Controller.

Thus, if you want to learn more about the personal information that Charge has about you, or you would like to submit a request to update or change that information, please contact the Customer Data Controller. You also may reach us by email at privacy@charge.io.

Charge acting as a data controller

Processing of GPS coordinates and IP addresses

Charge acts as a data controller when processing GPS coordinates and IP addresses collected when rendering its services to Customers Data Controllers.

The data subjects whose personal information is processed are end-users using the Services.

Purpose and legal basis for processing

The purpose of processing is to provide legal notices to data subjects and allow them to grant their informed consent relating to the use of biometric information by Charge in connection with the Services, as required under the laws applicable to Charge concerning the respective user (e.g. the Illinois Biometric Information Privacy Act or “BIPA”).

Charge processes the personal information – GPS coordinates and IP addresses – on the basis of Article 6(1)(f) GDPR, specifically:

(i) the prevailing legitimate interest of Charge to comply with its legal obligations in jurisdictions outside of the European Union;

(ii) the prevailing legitimate interest of data subjects using Charge’s services to be notified of biometric information processing by Charge and express their consent, under the laws applicable to Charge concerning the respective user.

Recipients of the personal information

The personal information is entrusted to data processors acting on Charge’s behalf, providing hosting services, technical staff and relevant technical infrastructure. In such case the processors shall process personal information on the basis of an agreement with Charge and exclusively in accordance with Charge’s instructions.

The personal information may be received by competent state authorities operating on the basis of generally applicable legal provisions.

Charge’s authorized employees and contractors may have access to the personal information.

The period for which the personal information will be stored

GPS coordinates and IP addresses will only be stored for the period necessary to establish the location of the data subject and deleted immediately afterwards.

Data subjects’ rights in regard to personal information – GPS coordinates and IP addresses

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. If we are unable to verify your identity, we will not be able to fulfill your request.

California Residents

For purposes of the California Consumer Privacy Act, Charge does not “sell” personal information.

California residents have the right not to receive discriminatory treatment by Charge for the exercise of their rights conferred by the California Consumer Privacy Act.

Data Subjects Located in the European Economic Area – Supervisory Authority

If you are located in the European Economic Area, you have the right to file a complaint with the supervisory authority – Austrian Data Protection Authority (Österreichische Datenschutzbehörde). To exercise your rights please contact us at the address provided below.

Additional information for users of the Services from outside the United States

The personal information that Charge collects through or in connection with the Services is transferred to and processed in the United States for the purposes described above. Charge also may subcontract the processing of your data to, or otherwise share your data with, its affiliates or third parties in the United States or countries other than your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence.

However, we only transfer your personal information to countries where the EU Commission has decided that they have an adequate level of data protection or we take measures to ensure that all recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC).

Children’s Privacy

The Services are not directed to children under the age of 13, and Charge will never knowingly collect personal or other information from anyone it knows is under the age of 13. We recommend that persons over 13 but under 18 years of age ask their parents for permission before using the Services or sending any information about themselves to anyone over the Internet.

Questions or comments

If you have any questions or comments regarding our Policy, please mail or email us at:

Charge Technology Group, Inc.
1100 Highland Ave
Manhattan Beach, CA 90266

Email: privacy@charge.io

The Data Protection Officer can be reached by email at: privacy@charge.io

We may request that you confirm your identity in order to continue with your request.

Effective date: April 1, 2020

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