Privacy Policy

This privacy policy will inform you as to how we look after your personal data. It aims to give you information on how 1account collects and processes your personal data and tells you about your rights under the General Data Protection Regulation (“GDPR”).

For the purposes of this privacy policy:

• When we refer to “personal data” or “personal information” we mean data which identifies, or may identify, you and which may include, for instance, your email or IP address.
• When we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting, and storing your personal data.
• When we refer to “sensitive data” we mean personal data which may reveal information about racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, genetic or biometric data.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will collect different categories of personal data from you depending on your level of interaction with our Platform. We will limit the collection and processing of information to information necessary to achieve one or more of our legitimate purposes as identified in this privacy policy.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth, sex, photo image, and photo ID document data.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or third parties using our solution either on our site or their own.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform.
• Profile Data includes your username and password, purchases or orders made by you, your feedback and survey responses.
• Biometric data includes biometric identifiers and characteristics such as facial patterns for verifying your identity.
• Usage Data includes information about: how you use our Platform and products and services; and physical retailer locations and time of use when you use our ID app to verify your age or identity.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature on any part of the Platform. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect:

• Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic data).

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services
  • create an account on our Platform
  • subscribe to our service or publications
  • request marketing to be sent to you
  • enter a competition, promotion, or survey
  • give us feedback or contact us
• Automated technologies or interactions: As you interact with our Platform, we will automatically collect Technical Data about your equipment. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google
    • advertising networks such as Traffic Stars based inside the EU
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as RocketGate or CardPay based outside the EU.
  • Identity and Contact Data from data brokers, aggregators and credit reference agencies such as GBG, Equifax, Boku, and Fonix based inside the EU.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Contract: Where we need to perform the contract we are about to enter, or have entered, into with you.
• Consent: Where you have given consent for us to process your personal data for a specific purpose.
• Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: Where we need to comply with a legal obligation that we are subject to.

You have the right to withdraw consent at any time by contacting us at privacy@1account.net.

The table below sets out the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may share your personal data with the following third parties in the circumstances outlined:

• We share the results of our online age verification check with our business customers when you have consented or us to process your data in order to verify your age to a business customer (as required by them in connection with the sale of an age restricted product or access to age restricted website content).
• We may share your data with third parties who are contracted to supply services related to our online age verification service and/or for the purposes of fraud prevention.
• When you verify your age and identity to a retailer, service provider or venue operator using the 1account ID app, we share your personal data with the retailer, service provider or venue operator.
• We may share your data where we may be legally required to do so, in such circumstances as: if we are involved in legal proceedings; or complying with legal obligations, a court order, or the instructions of a government authority.
• We may share your data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis.

Our main databases are stored within the EU. Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality. All data processed by us is protected with end-to-end encryption by default.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We maintain ISO 27001 (International Standard for Information Security Management) certification and undergo quarterly internal, and annual external, information security audits in maintenance of this certification.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

The table below sets out the length of time that we will retain your data for:

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

These rights include but are not limited to:

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@1account.net.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

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