Privacy Policy

  1. 1. Purpose

Your privacy is important to us. We believe you should always know what data we collect from you and how we use it, and that you should have meaningful control over both. This Privacy Policy explains how information about you is collected, used, and disclosed by APPII Pty Ltd (APPII). It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information, as defined below.

  1. 2. Data Protection Officer / Contacts

APPII Pty Ltd is headquartered in the United Kingdom. APPII Pty Ltd have appointed an internal data protection officer as our processing is deemed to be of the type and scale that requires one. Should you have any questions or concerns about APPII Pty Ltd personal data policies or practices; you can reach out to us at the following address:

Telephone: +44 203 239 2770

Email: [email protected]

Company Number: 10064676

We always respond to data enquiries and will investigate or clarify any requests. If there are any questions, we encourage you to get in touch with us, so we can respond accordingly.

  1. 3. About Us and This Application

APPII Pty Ltd (APPII) is a privately held software company that has pioneered methods for securely and conveniently combining biometric and digital identity capabilities to verify personal credentials that are required by industries such staffing and recruitment, health, defence, banking, insurance, media, and telecommunication, and, for securing borders and seamless travel.

APPII creates products to help manage identities and the verification of personal credentials across the full digital identity lifecycle including onboarding, authentication, and offboarding. APPII has developed identity and personal credential verification software that allows government and commercial enterprises to establish trust that someone is who they claim to be and that their associated verified credentials are genuine.

The APPII Application (“Application”) is a digital passport that allows real-time verification of personal credentials such as identity, background, employment, health credentials and diagnostic test results on your mobile device.

  1. 4. Our Data Values

APPII understands that you entrust us with your personal information with the expectation that it will be used only for specific purposes. We respect your expectation and place a high priority on protecting this information by limiting its use. At APPII, protecting your privacy is fundamental to the way our company and its subsidiaries conduct our business.

  1. 5. Scope of this Privacy Notice

This Privacy Notice (Notice) applies only to the personal information collected by the Application both within the Application and when accessing services online, through APPII’s websites. In Europe it is provided by APPII Pty Ltd (“us,” “we,” or “our”).

We collect and process information about you as described in this Privacy Notice (“Notice”). We are committed to protecting the privacy of those with whom we interact. This Notice contains details about how we collect, use, and share Personal Information that we obtain from and about you when you interact with us through your use of the APPII App. Please read this Notice carefully.

We process your personal information under the General Data Protection Regulations Article (6)(b) in order to provide you with the product / service you have purchased, undertake standard business functions such as billing, and to inform you of relevant events, content, and other benefits or opportunities. APPII Pty Ltd may also process this information under the General Data Protection Regulations Article (6)(f) to help us understand our customers’ needs and interests, to better tailor our products and services to meet those needs.

Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing Personal Information about another individual, you represent that your interactions and exchanges comply with applicable data protection laws. You shall have sole responsibility for any violation of privacy laws because of a failure to inform the other individual about how their Personal Information will be processed or to obtain any necessary consent from such individual.

We may update this Notice from time to time. The current Notice will be effective when posted. Please check this Notice periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Notice by posting an update on our website. When required under applicable law, we will seek affirmative consent from you before making material changes to the way we handle Personal Information previously collected from you. If you do not provide such consent, Personal Information will continue to be used in a manner that is consistent with the version of this Notice under which it was collected.

  1. 6. Sources of Personal Information

Personal Information refers to any information relating to an identified or identifiable natural person or household.

We collect information about you and how you interact with us in several ways, including:

  1. (a) Information you provide to us directly. We collect the information you provide to us directly, including to our service providers acting on our behalf.
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  3. (b) Information automatically collected or inferred from your interaction with us. We automatically collect technical information about your interactions with us (such as IP address, mobile device ID, and browsing preferences).
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  5. (c) Information from public sources, including government entities from which public records are obtained and information you submit in public forums.
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  7. (d) Information from third parties. We receive information about you and your interactions with us from third parties, such as from entities that use the APPII Application (the Application) to issue, read, and verify identity, background, or medial data and health credentials. In some cases that may include your pharmacy, GP, employer, school, or other location where the APPII Application is used.

We may combine information that we receive from the various sources described in this Notice, including third party sources and public sources, and use or disclose it for the purposes identified below.

  1. 7. Types of Personal Information We Collect

The types of information that we may collect about you are:

  1. (a) Identifiers, such as your name, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers.
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  3. (b) Personal information protected by Article 6 & 9 of the UK GDPR such as special category personal data (e.g., medical information)
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  5. (c) Internet or other electronic network activity information, information regarding your interactions with us (including interacting with us online, by the mobile application, and through advertisements).
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  7. (d) Audio, electronic, visual, thermal, olfactory or similar information, such as video or photograph recordings of your interactions with our devices and related technologies, call centre recordings, and customer support chat logs.
  1. 8. How We Use Your Personal Information

We may use each category of your information described above in the following ways:

  1. (a) To enable interactions between you and us, such as to process account creation and registrations; register and administer your account; provide you with services and support your interactions with us; diagnose, repair and track service and quality issues; provide requested product information; communicate with you about your account or our data practices; install and configure changes and updates to programs and technologies related to interactions with us; authenticate those who interact with us; or to respond to your requests, complaints, and inquiries.
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  3. (b) To confirm your health status. Information you provide in response to questions and prompts within the APPII Application or that you otherwise share when seeking verification of your health status may be used to confirm your health status.
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  5. (c) For our own internal business purposes, such as to evaluate or audit the usage and performance of programs and technologies related to interactions with us; evaluate and improve the quality of your interactions with us and programs and technologies related to interactions with us; design new services; process and catalogue your responses to surveys or questionnaires; perform internal research for technological development and demonstration; conduct data analysis and testing; maintain proper business records and other relevant records.
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  7. (d) For legal, safety, or security reasons, such as to comply with legal requirements; protect our safety, our property or rights of those who interact with us, or others; and detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
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  9. (e) In a de-identified, anonymised, or aggregated format. When converted to a de-identified, anonymised, or aggregated format, data no longer constitutes Personal Information in certain jurisdictions, and we may use this information for any purpose as legally permissible.
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  11. (f) For any other purposes for which you provide consent.
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  1. 9. With Whom We Share Your Personal Information

We may share your Personal Information with the categories of recipients described below:

  1. (a) Affiliates and subsidiaries: We may share your Personal Information within our group of companies, which includes parents, corporate affiliates, subsidiaries, business units and other companies that share common ownership for the purposes described above.
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  3. (b) Third party service providers: We may share your Personal Information with third party service providers working on our behalf in order to facilitate our interactions with you or request or support our relationship with you, such as hosting service providers, IT providers, operating systems and platforms, internet service providers, analytics companies, and marketing providers (e.g., we may share your email address with our outbound email marketing provider). We may contract with other companies to provide certain services, including identity verification, email distribution, market research, promotions management, and payment processing. We provide these companies with only the information they need to perform their services and work with them to ensure that your privacy is respected and protected.
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  5. (c) For legal, security and safety purposes: We may share your Personal Information with third parties such as law enforcement or other government agencies to comply with law or legal requirements; to enforce or apply our Terms of Use and other agreements; and to protect our rights and our property or safety of our users or third parties.
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  7. (d) In connection with a corporate transaction: If we sell some or all of our assets, merge or are acquired by another entity, including through a sale or in connection with a bankruptcy, we will share your Personal Information with that entity.
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  9. (e) With Third Parties from Whom You Seek Verified Credentials: If you seek to obtain verified credentials (e.g., verified medical data) from a third party through the APPII App, we may share your personal information with that third party.
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  11. (f) With your consent: We may share your Personal Information with other third parties with your consent.

We may also de-identity, anonymise, or aggregate Personal Information to share with third parties for any purpose as legally permissible.

  1. 10. Security and Retention

We maintain reasonable security procedures and technical and organisational measures to protect your Personal Information against accidental or unlawful destruction, loss, disclosure, alteration, or use.

We will retain your personal information, for no longer than is necessary to enable you to use the Application, unless we need to keep your information to comply with applicable legal, regulatory, or other obligations, or the information is required for business reasons (such as to resolve disputes, provide service and enforce agreements). In any event, we will retain your information for the period stated in our retention schedule, at which point APPII will take steps to dispose of your personal information securely and permanently, according to applicable laws and regulations. 

  1. 11. Children’s Privacy

Interactions with us are intended for individuals 16 years of age and older. Our interactions are not directed at, marketed to, nor intended for, children under 16 years of age. We do not knowingly collect any information, including Personal Information, from children under 16 years of age. If you believe that we have inadvertently collected Personal Information from a child under the age of 16, please contact us at the address below and we will use reasonable efforts to delete the child’s information from our databases. In all cases where we may inadvertently be provided with personal information relating to children, the information in the relevant parts of this Notice applies to children, as well as adults.

  1. 12. Terms of Use

The End User License Agreement for interactions with us is incorporated by reference into this Notice and can be found here.

  1. 13. Contact Info/Your Choices

If you have questions regarding this Notice, please contact us at:

To opt-out of receiving promotional email messages from us, please click on the “Unsubscribe” link contained at the bottom of each email or by contacting us using the information above.

14 . Your EU Privacy Rights

For the purposes of the EU General Data Protection Regulation (GDPR) APPII Pty Limited is the controller for the personal information we process, unless otherwise stated. For all data protection enquiries and/or concerns in connection with your EU privacy rights please contact our Data Protection Officer at [email protected] or any of the other ways to contact us at Section 10 as might apply to you.

Pursuant to the GDPR below is specific information which relates to the processing of personal information of data subjects who are in the EU. The section references relate to the sections above in this Notice.

Purpose of Processing

The business and/or commercial purposes for which we process personal information are detailed in the Section 6 and are part of the following general purposes: (a) performing services, (b) auditing, (c) legal and compliance, (d) quality assurance, (e) security, (f) debugging, (g) short term, transient use, (h) internal research, and (i) corporate transactions.

If we intend to process your personal information for any additional purpose(s), we will provide you with information on the other purpose(s) and seek your prior consent.

Legal Basis

The legal basis for the processing of your personal data is one of the following:

  • consent, or to provide the service for which you entered into a contract with us when you accepted the terms and conditions of the end user licence agreement when you downloaded the Application or to comply with a legal obligation to which we are subject.

Please note that the provision of personal information is a requirement of the contract you entered into with us when downloading the Application and is necessary to enable us to provide our services to you through the Application. Where you have provided your consent for us to process your personal information, you have the right to withdraw your consent at any time.

Sharing Personal Information

The categories of third parties to whom we disclose personal information for a business purpose are detailed in the Section 7 and are summarised as follows: (a) affiliates and subsidiaries, (b) third party service providers, (c) legal, safety, and security, (d) corporate transactions, (e) with third parties from whom you seek credentials, and (f) otherwise with your consent.

Transfer of Personal Information

Personal information may be processed by APPII Pty Ltd for the purpose of providing customer service and support. If we share your personal data with external third parties outside of the E.E.A. we use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the GDPR.

Data Retention

We will retain your personal information for no longer than is necessary to enable you to use the Application, and to comply with our legal obligations, resolve disputes, and enforce our agreements but in any event, no longer than 1 year after the last time you interacted with or used the Application.

Data Subject Rights

If you wish to access, correct, delete or update your personal information, restrict or object to processing or exercise a right to data portability (where technically feasible) please refer to the functionality available within the Application on the user profile page or email us at [email protected]. We will respond to reasonable requests in accordance with relevant data protection laws.

Compliance

We work to high standards when it comes to processing your personal information. If you have any queries or concerns about our approach to protecting your information, we welcome the opportunity to make things right for you and encourage you to contact us by one of the methods at Section 13.

If you are not satisfied with our response, you have the right to lodge a complaint with your national data protection authority.