Last updated: 2019-12-31
Document Reference: ID.me.S.00.030
We collect three types of information from and about Users: Personally Identifiable Information, Sensitive Information, and Non-Personally Identifiable Information.
We do not automatically collect any Personally Identifiable Information or Sensitive Information without your consent. When you create an account to obtain an ID.me Account and use the ID.me Service, you will be asked to provide certain Personally Identifiable Information and Sensitive Information so that we can verify your identity and attributes of your identity including, but not limited to, group affiliations (e.g., Military, First Responder, Student, Veteran, etc.), memberships, social media accounts, educational degrees, and professional certifications.
“Personally Identifiable Information” is information that identifies a specific individual, including, without limitation, first and last name, mailing address, e-mail address (including, without limitation, .mil e-mail address), telephone number, social security number, date of birth and photographic images. We collect this information through a variety of means, which may include from your identity documents, text you input and/or images and selfies we ask you to provide. We will only share your Personally Identifiable Information to the extent necessary to allow us to manage our relationship with you.
In addition, you may be asked to provide certain further information or documentation that we will use to verify your eligibility to receive discounts and benefits from organizations and registration authorities such as government agencies, telecommunications networks, credit card bureaus, financial institutions, or authoritative agents with access to your group affiliation credentials, military records (which may also contain Personally Identifiable Information)(collectively, “Registration Authorities”), your spouse’s or immediate family member’s social security number, military affiliation(s), dates of active and reserve duty service, and information related to your accounts with financial institutions (“Sensitive Information”).
In order to better serve members of America’s Armed Forces and other personnel covered by the Service Members Civil Relief Act (SCRA) (50 U.S.C. App. 501 et. seq.)*, ID.me provides services to Financial Services companies and Third-Party Websites in order to facilitate their compliance with the provisions of SCRA. By joining ID.me, you agree that ID.me may use your personal information in order to assist Financial Services companies and Third-Party Websites to determine your eligibility or your family member’s eligibility for SCRA benefits and protections. ID.me may periodically use your personal information to confirm your SCRA eligibility or your family member’s eligibility at a later point in time to inform third parties of any changes to your SCRA eligibility status. Source of this information may include, but are not limited to, publicly available websites, physical documentation, financial information, ID.me’s network or third parties that have a relationship with ID.me.
*The scope of ID.me’s SCRA services includes all individuals protected by the SCRA (i.e. personnel serving in the United States Armed Forces, commissioned officers of the Public Health Service and the National Oceanic and Atmospheric Administration, U.S. citizens serving with the armed forces of nations allied with the United States, and, where applicable according to federal or state laws and regulations, dependents and family members of an individual protected under the SCRA.
We will not share, sell, rent, or trade your Personally Identifiable Information or Sensitive Information with other parties, except to verify your identity and eligibility or upon receipt of your consent as provided below:
We will share your Personally Identifiable Information and Sensitive Information with entities necessary to validate your ID.me Account and provide the ID.me Service to you. In order to verify your identity and eligibility to receive discounts, cash back rebates and other benefits from merchants and other service providers, we will provide your Personally Identifiable Information and Sensitive Information to third parties such as government agencies, telecommunications networks, financial institutions or other trusted and reliable sources of information. Our provision of your Personally Identifiable Information to the foregoing parties is solely to verify your identity and eligibility for the ID.me Service. We have established relationships with Registration Authorities similar to the entities described above whereby the Personally Identifiable Information and Sensitive Information you provide to us will be transmitted to them using industry standard encryption tools, designed to protect such information from unauthorized access.
By providing any personally identifiable information and sensitive information to us, you authorize ID.me to provide such information to the above Registration Authorities and other trusted entities in order to verify your identity and eligibility to receive discounts, cash back rebates and benefits. We will share certain Personally Identifiable Information tied to your ID.me Account (including the ID.me Cash Back Program) with Third-Party Websites where you grant us permission to do so by creating an account with the Website and utilizing your ID.me Account to access and use Third-Party Websites (including, without limitations, use of your ID.me to create an account, register or subscribe with a Third-Party Website). We do not share your Personally Identifiable Information or Sensitive Information with Third-Party Websites absent your permission. However, by utilizing your ID.me Account at Third-Party Websites, you are expressly authorizing us to share certain Personally Identifiable Information or Sensitive Information tied to your ID.me Account with such Third-Party Websites. The ID.me Service is intended to allow you to create a membership or profile with a Third-Party Website and/or engage in a transaction with a Third-Party Website by automatically transferring Personally Identifiable Information or Sensitive Information. This transfer of Personally Identifiable Information and/or Sensitive Information tied to your ID.me Account is necessary to verify your eligibility to receive benefits or discounts from various organizations, and to communicate such eligibility to Third-Party Websites. The information ID.me shares with Third-Party Websites will be limited to the Personally Identifiable Information and/or Sensitive Information that ID.me, at its sole discretion, deems necessary to complete the transactions described herein. You will have the opportunity to review the information required to complete a transaction before your information is released to a Third-Party Website. Absent your explicit permission, ID.me will never give Third-Party Websites access to any or all of your information tied to your ID.me Account. In using the ID.me Service, Users have the ability to control which Third-Party Websites are provided with their Personally Identifiable Information and Sensitive Information. We will not share a User’s Personally Identifiable Information and Sensitive Information with a Third-Party Website unless the User authorizes such sharing by using his or her ID.me account to register with the Third-Party Website or to authorize the Third-Party Website’s access to his or her information.
We may share your information with Authorized Third Party Service Providers.
We provide certain services and products of the Website through Third-Party service providers. These “Third-Party Service Providers” perform functions on our behalf, such as sending out and distributing our administrative and promotional emails. We may share your Personally Identifiable Information with such Third-Party Service Providers to remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments, operate the Website, troubleshoot, and provide customer service. We may also collect personal information from individuals and companies (“Affiliates”) with whom we have business relationships and may share your information with Third-Party Service Providers to accomplish our administrative tasks. However, we do not grant these entities any rights to use, and contractually restrict them from using, any information for any purpose other than providing services to us and to you. ID.me shall never sell your information to any entity for any reason.
We may share your information in a business transfer.
We may share your information for our protection and the protection of others.
We may disclose or share Non-Personally Identifiable Information with Third-Party Service Providers and Affiliates. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information or Sensitive Information) with “Third-Party Advertisers” or “Third-Party Advertising Companies” and other parties as provided below:
We may use Third-Party Advertising Companies to serve ads when you visit our Website. These companies may use Non-Personally Identifiable Information about your visits to this and other websites in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you. Some of these Third-Party Advertising Companies may be advertising networks that are members of the Network Advertising Initiative (“NAI”). If you would like more information about any NAI member company, or you would like to opt-out of targeted advertising from any NAI member company, click here: http://www.networkadvertising.org/consumer/opt_out.asp. We also use Third-Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our Users to administer our Website and constantly improve its quality. We may also publish this information for promotional purposes or as a representative audience for Advertisers. Please note that this is not Personally Identifiable Information or Sensitive Information as defined above, only general summaries of the activities of our Users. Such data is collected on our behalf, and is owned and used by us.
We believe that you should have the ability to access and edit the Personally Identifiable Information and Sensitive Information you provide us. You may change any of your Personally Identifiable Information or Sensitive Information by logging into your account and accessing the "my account" section of the site. You may update your Personally Identifiable Information or Sensitive Information by sending us an email at help@ID.me or writing to us at 8281 Greensboro Drive, Suite 600, Tysons Corner, VA 22102. Please indicate your name, address and email address, and what information you would like to update when you contact us.
We encourage you to promptly update your Personally Identifiable Information and Sensitive Information if they change. You may ask to have the information on your account deleted or removed; however, we may keep track of certain information if required by law. In addition, in may be impossible for us to completely delete all of your information because we periodically back-up information.
Personal information will be retained until we have fulfilled ID.me’s legal, contractual and policy obligations. Currently, in order to fulfill these obligations, our retention policy is the duration of your relationship with ID.me plus seven and a half years.
In the event that ID.me’s services are no longer available, ID.me will make commercially reasonable efforts within its power to protect and/or securely destroy your personal information in accordance with applicable legislation.
While we hold your personal information, we use approved industry-recognized encryption methods to protect it from unauthorized access. Likewise, when we destroy your personal information, we use industry-recognized methods to effect such destruction.
As discussed above, you can always choose not to provide information, although it may be required to use all or parts of the ID.me Service, including the ID.me Marketplace.
Except as otherwise provided herein, if you register for an account with, or log into, the ID.me Service, including the ID.me Marketplace, you are expressly consenting to receive e-mails (namely, Administrative Emails and Promotional Emails, as defined below) from us at the email address supplied by you. However, we will not send you Promotional Emails if you have signed up through a Third-Party Website, unless you expressly consent to receive such emails or you separately register or log in as a user of the ID.me Service, including the ID.me Marketplace.
“Administrative Emails” relate to a User’s activity with the ID.me Service, and include emails regarding the User’s account, requests or inquiries by the User, earned cash back rebates, and purchases of products and services. We may also send you Promotional Emails. “Promotional Emails” advertise our products and services, including sales and other offers by Third-Party Websites, such as cash back rebate promotions, employment and educational opportunities, and/or the products and services of our Third-Party Websites, Third-Party Service Providers and Affiliates.
You cannot opt-out of Administrative Emails. However, you have the ability to opt-out from receiving Promotional Emails.
If you want to opt out of receiving Promotional Emails from us, you must e-mail us at firstname.lastname@example.org, write to us at the address contained herein, or click the “unsubscribe” button at the bottom of any of our e-mails and complete any additional steps required in response thereto. When contacting us, please indicate your name, address, email address, and indicate whether you no longer wish to receive all or certain Promotional Emails.
We take security seriously and take numerous precautions to protect the security of Personally Identifiable Information. You can access your Personally Identifiable Information and Sensitive Information on our Website through a password and your email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your Personally Identifiable Information and Sensitive Information reside on a secure server to which only select personnel and contractors have access.v
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with service providers that do the same, we cannot guarantee the security of any information transmitted to or from the Website, and are not responsible for the actions of any third parties that may receive any such information.
We may use other industry standard technologies like pixel tags and web beacons to track your use of our Website pages and promotions, or we may allow our Third-Party Service Providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Website, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on our Website, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our Affiliates and/or Marketing Partners for the same purposes. The Website is not presently configured to respond to DNT or “do not track” signals from web browsers.
Minors under the age of 18 may not use the Website. We do not knowingly collect personal information from anyone under the age of 18, and no part of the Website is designed to attract anyone under the age of 18. Because we do not intentionally collect any information from children under the age of 18, we also do not knowingly distribute such information to third parties. If you have reason to believe that a child under 18 years of age has provided us with information, please contact us at email@example.com and we will immediately delete such information, subject to and in compliance with applicable law.
We may provide areas on the Website where you can publicly post information about yourself, can communicate with others (such as discussion boards or blogs), or can review products, and submit media content. This information may be accessible by other consumers and companies, and may appear on other websites or web searches; therefore this information could be read, collected, and used by others. For example, if you post your email address along with a product or service review, you may receive unsolicited messages from other registered users. We have no control over who reads your postings or what other Users may do with the information you voluntarily post, so please use caution when posting any personal information. We do obtain consent from our Users to post their name along with their reviews.
Conversely, if you are not currently registered as an ID.me user and you click on "Sign in Using Facebook," you will first be asked to enter your Facebook credentials and then be given the option to register and join ID.me. Once you register on the ID.me Website and Connect with Facebook, you will be able to automatically post recent activity back to Facebook. You have the option to disable Facebook Connect at any time by logging into "My Profile" and clicking on "My Facebook Profile." Further, you can edit privacy settings for the reviews that appear on Facebook or disconnect this service by visiting the Facebook Application Settings page.
If a User uses Facebook Connect, depending on the privacy settings that the User has set on his or her Facebook account, the User will be granting us access to the information accessible via that Facebook Account and we will access, make available and store (if applicable and as permitted by Facebook and authorized by the User via his or her Facebook account setting) that information so that it is available on and through the User’s Account on the Website. If there is information about the User’s "friends" or people with whom the User is associated via the Facebook account, the information we obtain about those "friends" or people with whom the User is associated, may also depend on the privacy settings such people have with Facebook.
The California Consumer Privacy Act (the “CCPA” or “Act”) provides California residents with specific rights regarding their personal information. It should be noted that personal information under the Act does not include publicly available information from governmental records and de-identified or aggregated consumer information. This section describes your rights under the Act and explains how to exercise those rights.
Right to Personal Information.
As required by the Act, we will provide you the following information upon a verifiable consumer request: (1) categories of Personally Identifiable Information that we collect; (2) categories of sources from which the Personally Identifiable Information is collected; (3) the purpose of collecting such Personally Identifiable Information; (4) the categories of third parties with whom we share Personally Identifiable Information; and (5) specific pieces of Personally Identifiable Information collected. If we sold or disclosed your Personally Identifiable Information for a business purpose in the preceding 12 months, we will provide (a) a list of the categories of personal information that was sold, and (b) a list of the categories of personal information that was disclosed for a business purpose.
Right to Request Deletion of Personal Information.
According to the Act, you may request that your Personally Identifiable Information be deleted. We will comply with this request once we are able to confirm that we received a verified consumer request. Please be advised that we may deny your request to delete your Personally Identifiable Information if we need to maintain your Personally Identifiable Information in order to (1) complete a transaction, provide service or goods, or perform a contract for which the Personally Identifiable Information is collected; (2) detect any security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for these activities; (3) debug products and to identify and repair errors that impair functionality of the Service or Website; (4) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law; (5) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.); (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) comply with a legal obligation; or (9) otherwise use your Personally Identifiable Information, for internal use only, that is compatible with the context in you provide the Personally Identifiable Information.
Right to Opt-out of the Sale of Personal Information.
Exercising your CCPA Rights.
To request (a) information about your Personally Identifiable Information collected or (b) deletion of your Personally Identifiable Information, please log into your account and make such request, or send a request by email to help@ID.me or standard mail to the address found below.
We can only respond to verifiable consumer requests. A verifiable consumer request means a request that is made by consumer, by a consumer on behalf of a consumer’s minor child, or a person registered with the California Secretary of State that is authorized to act on your behalf. Your verifiable consumer request must include (1) sufficient information that allows us to verify your identity or provides sufficient authority to make the request; and (2) describes you request with enough detail to evaluate and respond to your request. We will not respond to any requests if we cannot verify your identity or authority to make the request and confirm that the personal information belongs to you. You are not required to create an account in order to make a verifiable consumer request. We are not required to comply with more than two verifiable requests from the same consumer in a 12-month period of time.
Please allow 45 days to complete your request. We will inform you if more time is required to complete, but it should take no longer than 90 days. if you have an account, we may provide our response to your account. If you do not have an account, we will provide our response according to your requested format, namely, electronically or by mail. Please note that there is no charge for making a request, but we reserve the right to charge a fee if the request is deemed excessive, repetitive, or manifestly unfounded. We will notify you of any fee and reasons for such fee before completing your request.
We will not discriminate against you because you exercised your rights under the CCPA including: (1) denying goods or services; (2) charging different prices or rates for goods or services through discounts, benefits, or imposing penalties; (3) providing different level of quality of goods or services; or (4) suggesting that you will receive a different price, rate, quality, or level of goods or services.
Please note that if you do exercise your CCPA rights, you may not be eligible to receive discounts, cash back rebates and other benefits from merchants and other service providers since they will not be able to verify your identity and/or eligibility.
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