Nivo

App User Privacy Policy Notice

Data that we hold and how we use it

As an app user, we do not act as the Controller for the messages between you and the Provider When The Bank Says No. We are the Controller of your registration data for the App itself, any log data and then your Nivo Identity if you have set one up. Your Nivo identity will include the results of your ID&V check including facial biometric checks, if you have agreed to share it with us for future use with a new provider. When you attempt to start a conversation with a provider on Nivo, you will be asked to consent to share your Nivo identity information. If you choose to consent, that identity will be shared with the provider.

Lawful basis for processing

Our lawful basis for processing your data is a combination of Contract, Consent and Legitimate Interest. We use Contract as a lawful basis for the data you provided when you downloaded and registered yourself as a user on the App. If you create a Nivo ID and add the results of an ID&V check including facial biometric checks, we ask your consent to transfer that from your provider to us. Once transferred, we process it under contract and legitimate interest, depending on the process. We use consent if we process any of the biometric data from your ID&V check including facial biometric checks.

Data Sharing and Transfers

Like most companies, we use a number of other companies as part of our data processing, for example cloud services and technology services. We have Data Processing Agreements in place with these providers. Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example Standard Contractual Clauses. We do not sell your data to anybody. As part of the service we offer you, with your consent, and only upon your instruction, we transfer your Nivo Identity to new providers.

Retention Periods

We hold data on our app users for the time of which you are an active user and then for 7 years afterwards in case of any dispute. This is to ensure that our customers continue to have an auditable record of the identity information which may be required for them under the laws and regulations they operate. It will also ensure that you can continue to easily communicate and transact with other providers on the Nivo network. This data includes the ID&V check including facial biometric checks.

Face Data

Face data is only processed as part of our ID&V checks to confirm your identity against government issued documents. ID&V data is stored by the identity provider (Onfido) for as long as is required under the relevant laws and regulations. ID&V check results are only shared with your consent to relevant parties involved in the transaction. Face data is only stored by the identity provider used to capture and check your identity ie. Onfido. You can find Onfido's privacy policy at https://onfido.com/privacy/