Affirmed Identity Authenticator and Identity Service Privacy Policy

This privacy notice for Affirmed Identity LLC ("we," "us," or "our") and AffirmedId Authenticator Application (“app”) and related Identity Service (“service”), describes how and why we might collect, (“process” and “discard”) or capture (“process”, “store” and “use”) your information when you use our app or our service, such as when you:

• Download, install, register, and use the app.
• When you use the app to take part in an authentication session initiated by a third party (“service provider”) via our identity service.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our app or services. If you still have any questions or concerns, please open a Support Ticket or email us at Support@ProteqsIT.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process or store? When you use our app or when you visit, use, or navigate our services, we may collect or capture personal information resulting from how you use or interact with our app and the services, the choices you make, and the features you use. Learn more about personal information you disclose to us.

Do we collect or capture any personal identification information (PII)? Yes, we do PII information that is stored both locally on your cell phone and remotely in our cloud service.

Do we collect sensitive personal information (SPI)? Yes, we do collect, process and discard SPI information.

Do we capture and store sensitive personal information (SPI)? We do not capture or store SPI information.

Do we receive any sensitive or personal information from third parties? We do not ask for or knowingly receive your sensitive or personal information from third parties.

How do we process your collected information?

Within the app we process collected SPI for the purpose of recognizing and verifying the identity of the person using the app. Should it be you using the app, then it is your SPI the app is processing. The inference processing of SPI information produces two values, a Boolean and a decimal between 0 and 1. These are used to recognize and verify your identity and to recognize when it is not you who is using your app. Within seconds of collection, the SPI is discarded and never stored. You by installing and registering the app grant your permission for the app to undertake SPI collection, processing, and discarding on your behalf. During installation, you are provided the opportunity to decline collection of certain types of SPI information and the app will respect your choices made.

How do we process your captured information?

Within the app we collect and process PII information you provide and export that to our service. Both our app and our service store that PII in an internal record it creates on your behalf. You can choose not to provide the PII and you have the right and opportunity to at any time to have the internally stored user record discarded. However, either option prevents both the app and service from performing their respective tasks on your behalf.

In what situations and with which parties do we share sensitive or personal information?

We do not share your information in any situations with any third parties under any circumstance. We do share identity conclusions drawn from processing the SPI information with those you have granted permission to reference your personal record and the PII it contains.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights?

The easiest way to exercise your rights is by either support ticket submission using the app’s form for doing so or by email to Support@ProteqsIT.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the privacy notice in full.

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

We collect personal information that you voluntarily provide to us when you install and register the app or access our services, express an interest in obtaining information about us or our products and services, when you participate in activities on the services, or otherwise when you contact us.

Personal Identification Information Provided by You. The PII that is captured by our app and service is strictly limited to:

• Verifiable email address: that is stored both locally by the app and remotely by the service.
• Optional phone number: if provided, is stored both locally by the app and remotely by the service.
• Personal Identification Number (PIN): we collect, process, and store the biometrics of PIN code entry. The PIN code number itself is not collected or stored and remains known only to you.

Sensitive Personal Information. We collect, process, and discard the following SPI. In some cases, you have the option to withhold granting permission to use certain SPI either during installation of the app or by visiting your device settings; we respect and honor those selections. Types of SPI collected include:

• Geolocation Information.
• Proximity Information.
• Sensor information.
• Microphone and camera information.

This information we collect, process, and discard and retain only data produced by processing the information as biometric data indicative of how, where, and when you use the app.

HOW DO WE PROCESS YOUR INFORMATION?

We process:

• Your email address is applied as your username for the purpose of authentication. It may also be used from time to time to inform you of important information pertaining to the app or service.
• Your cell phone number, if provided, for the purpose of providing support and product information.
• Your PIN code to provide the third leg of the three factor authentication stool on which service providers and other may rely.
• Your SPI information of verifying it is you who is using the app and to recognize when it is an unidentified third party attempting to use the app.

WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We must and do comply with regional and local laws pertaining to protection of your PII and SPI information in all regions and locals where we authorize the use of our app and service. Unless otherwise stipulated, installing and registering our app indicates your consent to process your PII and SPI.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal basis we rely on in order to process your personal information. As such, we may rely on the following legal basis to process your personal information:

• Consent.
• Performance of a Contract.
• Legal Obligations.
• Vital Interests.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• For investigations and fraud detection and prevention.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We do not share your personal information with any third-party except in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

HOW LONG DO WE KEEP YOUR INFORMATION?

We keep a user account record on your behalf until such time as you direct us to delete it. It holds the only personal information we store, your email address and phone number if provided at the time of registration.

HOW DO WE KEEP YOUR INFORMATION SAFE?

Our practice for storing all app and service information is to do so only when encrypted. Additionally, all information exchanged between our app and our service, between our service and authorized service provider, or between our service and an authorized person-to-person query are point-to-point encrypted in addition to using secure protocols such as HTTPS. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and in so doing improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the Services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using our app and service, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the app and service. If we learn that personal information from users less than 18 years of age has been collected without parental or guardian permission, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at Support@ProteqsIT.com.

WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

Privacy Rights Information

Categories and Retention Periods

We will use and retain the PII and SPI as needed to provide the services or for:

• Categories A - As long as you have an account with us and the app remains installed on your cell phone.
• Categories E, H, M - As long as the app remains installed on your cell phone.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How we use and share your personal information

Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Sharing of Personal Information

Will your information be shared with anyone else?

We do not share your personal information with anyone except as noted under, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents...

Colorado Residents

This section applies only to Colorado residents...

Connecticut Residents

This section applies only to Connecticut residents...

Utah Residents

This section applies only to Utah residents...

Virginia Residents

This section applies only to Virginia residents...

Other Regions Privacy Rights

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information. If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Richard to attention of DPO by email at Support@ProteqsIT.com, by phone at 2398417585, or contact us by post at:

Affirmed Identity LLC
200 Vintage Circle, PO Box 104
Naples, FL 34119 United States

If you have any further questions or comments, you may also contact us by post at the following corporate address:

Affirmed Identity LLC
200 Vintage Circle, PO Box 104
Naples, FL 34119 United States
Phone: 2398417585

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please open a Support Ticket or email us at Support@ProteqsIT.com.