U.S. Consumer Health Data Privacy Policy
Last Updated: September 2024
This U.S. Consumer Health Data Privacy Policy (“Privacy Policy”) supplements the Services Privacy Policy of Trulioo Information Services Inc. and our affiliates (“Trulioo,” “we”, “our” or “us”) and describes how Trulioo processes Consumer Health Data, as defined under applicable U.S. state laws, in connection with our identity verification and related online services (collectively, the “Services”). In the event of a conflict between our Services Privacy Policy and this Privacy Policy, this Privacy Policy applies to the extent that it is consistent with applicable U.S. state laws.
1. Consumer Health Data We Collect
Under applicable U.S. state laws, Trulioo may be considered to collect Consumer Health Data in connection with the Services, including facial scan data extracted from identification documents and selfie images(“Facial Identification Data”).
2. How We Use Your Consumer Health Data
We use Consumer Health Data for purposes described in this Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:
| Categories of Consumer Health Data | Purpose of Use |
|---|---|
| Facial Identification Data | For identity verification purposes, for example by analyzing the data you submit to recognize and compare your facial images (such as the image on your identity document and your selfie image). |
| For fraud prevention purposes, for example by checking whether your selfie has been taken in real time, and is of a real person (as opposed to an image of an image) and whether any other fraud indicators are present. | |
| To develop and improve our products and services, including training machine learning models, for example to recognize and compare your facial images or detect other fraud indicators. | |
| Compliance and protection: complying with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protecting our, your or others’ rights, privacy, safety or property; auditing our internal processes for compliance with legal and contractual requirements or our internal policies; enforcing the terms and conditions that govern the Services; preventing, identifying, investigating and deterring fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. |
3. How We Share Your Consumer Health Data
We may “share” (as applicable U.S. state laws define that term) Consumer Health Data with your consent or as we determine necessary to provide the Services, or as otherwise permitted or required by law. For example, we may share your Consumer Health Data with the following categories of recipients:
- members of the Trulioo group, only to the extent necessary to fulfill the purposes outlined in this Privacy Policy;
- our third party business infrastructure providers, who we engage to enable us to support our Services and product development and improvement activities, such as data storage and hosting providers, and outsourcing partners (e.g., providers whose staff perform human review of document verification checks);
- our customers in connection with the provision of our Services (such as public registry data for our business verification services and risk signals for our Fraud Intelligence service);
- any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisors) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; or
- any other person with your consent to the disclosure (obtained separately from any contract between us).
4. Your Consumer Health Data Choices
You may have certain rights to your Consumer Health Data under applicable U.S. state laws, including the rights listed below.
- Withdraw consent. To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you have the right to withdraw such consent from any future collection or sharing.
- Access and confirm. You have the right to ask us to confirm whether we have collected, shared or sold your Consumer Health Data. Further, you have the right to access (in other words, request a copy of) the Consumer Health Data that we have collected, shared or sold. You also have a right to access a list of all “third parties” (as applicable U.S. state laws define that term) and affiliates with whom we have shared or sold your Consumer Health Data and receive certain corresponding information.
- Correction. You have the right to ask us to correct inaccuracies in your Consumer Health Data.
- Deletion. You have the right to ask us to delete your Consumer Health Data.
To exercise your rights and make a Consumer Health Data rights request, please email us at [email protected]. Please note that the rights discussed above may be subject to certain limitations (for example, a monetary charge), and we may need to verify your identity to process your request. To confirm your identity, we may ask you to provide personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you (such as government identification), which we will only use to verify your identity, and for security or fraud-prevention purposes.
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 or mandatory, we may not be able to provide those services.
5. Changes To This Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, regulatory, technical or business developments.
You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.
6. How To Contact Us
If you have any questions or concerns about our use of your Consumer Health Data, please contact us using the following details:
Email: [email protected]
You may also write to us at the following address:
FAO Privacy Office
Trulioo Information Services Inc.
400 – 114 E 4th Ave
Vancouver, BC V5T 1G2
Canada