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PRIVACY POLICY

Version: 6.5.1

Last updated: 2022-06-29

English

ID.me Privacy Bill of Rights


ID.ME PRIVACY STATEMENT

ID.me will not sell, rent, or trade your Personal Information. ID.me will only
transfer your Personal Information at your request, and with your consent, for
use by third parties to verify your identity or group eligibility, and as
required for the prevention of fraud. ID.me has built rigorous security and
privacy requirements into our technology from inception. We are an ethical
steward of your Personal Information and are committed to supporting the
following principles:

 * You are solely in control of your own Personal Information.
 * You must provide consent before we will share any of your Personal
   Information.
 * You can see all authorized applications and which specific elements of your
   Personal Information are shared in your My Account portal.
 * You can revoke access to your Personal Information for any authorized app at
   any time.
 * You may destroy your ID.me credential and disallow for further external use
   of any associated Personal Information at any time.


ID.ME PRIVACY POLICY

This Privacy Policy describes how ID.me and its affiliates (collectively
"ID.me") collect, use and disclose certain information, including your Personal
Information, both online and offline, and the choices you can make about that
information. We respect your concerns about privacy, and value our relationship
with each of our users – it is for this reason that ID.me will never sell, rent,
or trade your Personal Information, and why we take measures to safeguard your
Personal Information as we work to become the identity verification layer of the
internet.

When you verify yourself using ID.me, through our mobile and online
applications, use our in-person verification tools or other products and
services, visit our websites, view our content, or contact our customer service
(collectively, the "Services"), we may collect information from or about you.
There may be additional notices about our information practices and choices for
certain ID.me levels of verification, including our Biometric Information
Privacy Policy. By using any of the Services, you acknowledge the data
collection practices and purposes outlined in this Privacy Policy. You can learn
more about ID.me and our affiliates by visiting the About ID.me section of our
website, or by reviewing any of our whitepapers.

Click on each header below for more information or scroll down to read the full
policy.

 * What Information We Collect About You
 * How We May Use Your Information & Why
 * Who We Share Your Information With & Why
 * Your Choices, Rights, and Controls
 * Updating and Correcting Your Information
 * Privacy Policies of Third Parties
 * Protecting Your Information
 * Retention of Information
 * Children's Privacy
 * Additional Information if You Are Located in California
 * Additional Information if You Are Located Outside of the United States
 * Biometric Personal Information
 * Changes to this Policy
 * Contact Us


1. WHAT INFORMATION WE COLLECT ABOUT YOU

We collect information from and about you in connection with your use of the
Services. Some of this information may be considered "Personal Information"
which is information that identifies you or your device, or is reasonably
associated with you. The categories of Personal Information we may collect will
vary depending on the nature of the Service you choose.

We also collect, use, and disclose aggregated or de-identified information that
does not reasonably identify you or your device, and is not considered Personal
Information.

Information You Provide

We Collect Information You Provide to Us Which Includes:

Verification information. When you verify yourself, either individually or as
part of a group, with ID.me you provide us with Personal Information that may
include your name, date of birth, social security number and/or other government
issued identification numbers, copies of your government issued identification
card (e.g., license or passport), email address, phone number, mailing address,
and certain photographic images, and biometric data. You may also be asked to
provide group affiliations (e.g., Military, First Responder, Student, Veteran,
etc.), memberships, educational degrees, and professional certifications.

Please note, ID.me asks that you not provide physical documentation, via mail
service or otherwise, to ID.me. All documentation to be collected should be
provided either through the ID.me app or website portal, or presented to a
trusted referee where applicable.

Your correspondence and your feedback about our Services. We collect information
you provide when you contact us directly or provide feedback, comments, or
suggestions on our Services directly to us.

Information you provide when you do business with ID.me. If you are a vendor,
service provider, or business partner of ID.me, we may collect information about
you and the services you provide, including your or your employees' business
contact information and other information you or your employees provide to us as
part of the services you may provide and our agreement with you.

Information you provide offline. You may also provide information to us in
person and offline. You may be recorded if you visit our offices (including by
security surveillance of our premises, including CCTV).

Other information. We also collect information that relates to or is capable of
being associated with you, such as age, gender, and any other information you
choose to provide.

Information Collected Automatically

When using our Services we may automatically collect or receive certain
information associated with you or your network device(s), such as your computer
or mobile devices. This includes information about your use of our Services and
your preferences. Such information may be automatically collected through
device-based tracking technologies such as cookies, pixels, tags, beacons,
scripts, or other technologies. For more information about cookies or other
tracking technologies and the choices you have regarding the use of them, please
visit our ID.me Cookie Policy.

The information we automatically collect may also include geolocation
information, such as information that identifies the approximate location of
your device and your IP address, which may be used to estimate your approximate
location.

Information from our partners. We acquire information from other trusted
sources. These business partners might include companies, such as your mobile
phone carriers, certain government agencies, licensing bodies, etc. We may also
collect information about you from other sources, including service providers,
data licensors and aggregators, marketing companies, programming distributors,
and public databases.

Information you provide through social media

If you connect to us through a social media platform or navigate to a social
media platform from one of our sites, the social media platform will collect
your information separately from us. You should review the social media
platforms' privacy policies to understand how they are using your information
and your rights in relation to such information.

Information We Derive

We may derive additional information or draw inferences about you based on the
information we have collected from you directly, passively, or through third
parties.


2. HOW WE MAY USE YOUR INFORMATION AND WHY

ID.me will not sell, rent, or trade your Personal Information. ID.me will only
transfer your Personal Information at your request, and with your consent, for
use by third parties to verify your identity or group eligibility, or as
required for the prevention of fraud or otherwise permitted by law.

We may use information to provide you with our Services. We may use the
information collected from or about you to authenticate and manage your identity
when you create an ID.me account, including to verify attributes of your
identity including, but not limited to, group affiliations (e.g., military
status, first responder, student, veteran status, etc.), memberships, social
media accounts, educational degrees, and professional certifications, as well as
to provide you with customer support and account updates. We may use this
information to verify your identity with ID.me partners in both the public and
private sector at your request and perform our contractual obligations with you
or to ensure that our Services function properly.

We may use information to perform our contracts with you. If ID.me enters into a
contract with you, including in instances where you may be a vendor or service
provider to ID.me or our business partner, we may use your information to
fulfill our contractual obligations.

We may use information for marketing purposes. If you have opted into receiving
marketing communications, then we may use your information to send promotional
messages and newsletters via email, or otherwise alert you to products or
Services we think might be of interest to you, including for the ID.me Shop. You
may unsubscribe from receiving marketing communications from us at any time by
logging in to your account and navigating to "My Preferences" to manage your
subscriptions.

Please note, if you are using ID.me Services in connection with legal identity
verification for a state or federal government agency we will not use any
Personal Information provided as part of your verification for any type of
marketing or promotional purposes.

We may use information to improve our Services. We use your information to
monitor and improve the operation, delivery, and general accessibility of our
Services. This may also include conducting internal research and development of
our Services.

We may use information to maintain the safety and security of our Services. We
may use your information to protect the rights and property of ID.me and others,
and to comply with our legal obligations including to detect, investigate, and
prevent fraud and other illegal activities and to enforce our agreements.

We may use information as otherwise permitted by law. We may use your
information to resolve disputes, enforce our agreements, and as otherwise
permitted or required by law.

We may use your Biometric Information. We may use your Biometric Information to
verify your identity for certain partners, such as the Internal Revenue Service
(IRS) or various other federal or state agencies (e.g., Department of Labor or
Division of Unemployment Benefits), as well as to detect and help prevent fraud.
We also may use the information in other ways with your consent, such as when
you choose to use a Service or participate in a program we may offer jointly
with another entity. We will never sell, rent, or trade your Biometric
Information.

For additional information on how ID.me collects an, uses, and protects your
Biometric Information, please see our Biometric Information Privacy Policy.

Additional Information regarding the Service Member Civil Relief Act (SCRA). 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 so they may
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 so they may determine continued
eligibility for SCRA benefits and protections. Sources 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.


3. WHO WE SHARE YOUR INFORMATION WITH AND WHY

ID.me will not sell, rent, or trade your Personal Information. ID.me will only
transfer your Personal Information at your request, and with your consent, for
use by third parties to verify your identity or group eligibility, or as
required for the prevention of fraud or otherwise permitted by law.

We may share your Personal Information with entities necessary to validate your
ID.me Account and provide our Services to you. In order to verify your identity
and eligibility to receive discounts and other benefits from our partners and
other service providers, we may provide your Personal Information to third
parties such as government agencies, telecommunications networks, financial
institutions or other trusted and reliable sources of information. Our provision
of your Personal Information to the foregoing parties is solely to verify your
identity and eligibility for ID.me Services. We have established relationships
with Registration Authorities similar to the entities described above whereby
the Personal Information you provide to us will be transmitted to them using
industry standard encryption tools, designed to protect such information from
unauthorized access.

We may share your information in connection with a corporate transaction. We may
disclose or transfer your information as part of, or during negotiations for,
any purchase, sale, lease, merger, or any other type of acquisition, disposal,
or financing involving our brands.

We may share information with third parties who perform services on our behalf.
We may share your information with unaffiliated companies or individuals we hire
or work with that provide us with professional advice, business support, or
perform services on our behalf, including customer support, web hosting,
information technology, payment processing, direct mail and email distribution,
and administration, and analytics services. These Service Providers are allowed
to use your information to help us provide our Services and not for any other
purpose.

We may share information as needed in order to comply with legal processes, to
protect ourselves, or improve our Services. For example, we will share
information when it is necessary for us to comply with applicable law or legal
process, to respond to legal claims, to prevent fraud, or to protect our rights
or the property or personal safety of our users, employees, or the public.

We also use third party service providers to track and analyze website usage and
volume statistical information to administer our Website and constantly improve
its quality.

We may share information as required with the United States federal government
and certain state governments. ID.me does not provide any government with direct
and unfettered access to our user's data, and we do not provide any government
with our encryption keys or the ability to break our encryption. We may share
certain Personal Information associated with an ID.me account with government
entities where we reasonably believe that account may be engaging in fraud.

If a government entity requires additional information related to an ID.me
account, whether related to a suspected instance of fraud or otherwise, it must
follow applicable legal processes. It must serve us with a subpoena, warrant, or
present other legally compelling justification for the additional information
associated with the account, the request must be targeted and specific in
nature.

Our legal and compliance teams review all requests to ensure they are valid,
reject those that are not valid, and only provide the data specified in the
subpoena or similar court order.


4. YOUR CHOICES, RIGHTS, AND CONTROLS

You have certain choices about how we use your information, including how your
Personal Information is shared.

Close your ID.me Account. You may close your ID.me account at any time, by
choosing to close your ID.me account you are directing ID.me to deactivate your
identity credential and to purge the associated data from active use in our
databases. Please note, however, that ID.me does retain account history (e.g.,
events, logins, and transactions) as well as verification history (e.g., group,
vaccine, or identity details including documentation and data elements used for
verification) for up to three (3) years.

 * Please Note: Use of your ID.me credential to verify your identity with state
   or federal government agencies will be stopped in the event you delete your
   ID.me account. Please check with the specific state or federal government
   agency associated with your particular use case to confirm whether periodic
   or ongoing identity verification is required.

Deleting your selfie image and Biometric Information. Users who have created an
account requiring submission of a selfie image, and who consented to the
collection of the associated Biometric Information, may request the deletion of
both the selfie image and Biometric Information by submitting a request through
the ID.me "Privacy Rights Center" which is accessible via a link at the bottom
of our Website, or under the "Privacy" setting in your account. Deletion of the
selfie image and associated Biometric Information may take up to seven (7) days
and will not impact the validity of your credential or verified status. ID.me
reserves the right to retain this information as needed to comply with our legal
obligations or to help prevent fraud.

Opt out from receiving marketing emails. To stop receiving our promotional
emails, follow the instructions in any marketing email you get from us. When
applicable, you can also change your preferences in your account. Even if you
opt out of getting marketing emails, we are permitted to send you transactional
messages. For example, we may still contact you about your use of our Services
or any changes to our policies or Terms of Service.

Change or update the information you have given us. If you have verified
yourself and created an ID.me account, then you can correct or delete certain
information or update your verification information by logging into your account
and following the instructions or by contacting the member support team.

Control cookies and tracking tools. To learn how we—and our vendors—use cookies
and other tracking tools, please visit the ID.me Cookie Policy.

Ad Choices. We, our affiliates, and any associated third parties may collect
information on our Services to help alert you to products and Services that may
be relevant to your interests. This is known as interest-based advertising. We
rely on third parties who collect information on the Services to provide
opt-outs or other controls to you. For more information on how to opt-out of
receiving interest-based advertising on desktop and mobile websites, please
visit:

 * Network Advertising Initiative


5. UPDATING AND CORRECTING YOUR INFORMATION

Accessing and updating your Personal Information. We believe that you should
have the ability to access and edit the Personal Information you provide us. You
may change any of your Personal Information by logging into your account and
accessing the "My Account" section of the site.

You may update your Personal Information by sending us an email at help@id.me.
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 Personal Information if it changes. You
may also ask to have the information on your account deleted or removed from
active use in our databases; however, we may retain certain information if
required by law or by certain credential providers (e.g., the National Institute
for Standards and Technology), contractual obligation, or for internal use by
ID.me in the prevention of fraud.


6. PRIVACY POLICIES OF THIRD PARTIES

This Privacy Policy applies only to ID.me and our Services. This Privacy Policy
only addresses the use and disclosure of information we collect from you on
www.ID.me. Other websites, including third party websites, may be accessible
through this Website have their own privacy policies and data collection, use
and disclosure practices. If you link to any such website, we urge you to review
such website's Privacy Policy. We are not responsible for the policies or
practices of third parties.


7. PROTECTING YOUR INFORMATION

We use reasonable security measures. We are committed to protecting your
information. We have adopted technical, administrative, and physical security
procedures to help protect your information from loss, misuse, unauthorized
access, and alteration. Please note that no data transmission or storage can be
guaranteed to be 100% secure.

To safeguard certain sensitive information (such as biometric information and
government-issued identification information), we implement security measures
such as encryption, firewalls, and intrusion detection and prevention systems.



In addition, the following are examples of security measures that are used to
safeguard all types of Personal Information we maintain about our consumers:



 * Procedures for the identification and classification of Personal Information
   and implementation of safeguards appropriate to the sensitivity of the
   information;
 * access control procedures designed to verify a business need before access to
   Personal Information is granted, and procedures for the periodic review of
   access permissions;
 * procedures for termination of access to Personal Information designed to
   curtail access to the information by terminated personnel or when there is no
   longer a business need for access;
 * personnel security controls designed to reduce the risk of human error,
   theft, fraud or misuse of facilities; and
 * physical and environmental security procedures designed to prevent
   unauthorized access, damage or interference to business premises and
   information.


8. DATA RETENTION

Personal Information will be retained until we have fulfilled our legal,
contractual and policy obligations. ID.me stores your Personal Information for
as long as needed, or permitted, based on the reason why we obtained it
(consistent with applicable law and contractual obligations). This means we may
retain your Personal Information even after you close your account with us, for
up to three (3) years. Users may request that ID.me delete certain Personal
Information at any time at account.ID.me or through our Privacy Rights Center,
where applicable. We acknowledge all such requests, however we reserve the right
to retain data tied to certain high-risk transactions, particularly in
government and healthcare settings, exclusively for fraud prevention and
government audit purposes.

ID.me aligns to the National Archives recommended guidelines for data retention
when supporting government agencies. Personal Information provided by users in
connection with a public sector agency as part of their verification may be
retained for up to three (3) years after account closure, unless applicable
regulations require a shorter retention period.

Selfie Image and Associated Biometric Information. Certain pieces of Personal
Information, such as a selfie image and the associated Biometric Information
submitted by users for certain types of verification Services, are retained in
line with ID.me's obligations to our partners, with the specific retention
periods determined by the first partner with whom a user first verifies their
identity (e.g., IRS, Dept. of Veterans Affairs, etc.) Certain partners may
require this information to be purged within twenty-four (24) hours following a
successful verification, other partners may require a longer retention period,
but under no circumstances will ID.me this retain information for longer than
thirty-six (36) months absent a subpoena, warrant, or other legally compelling
justification.

While we store 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 affect
such destruction.


9. CHILDREN'S PRIVACY

We do not knowingly collect information from minors. 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 support@id.me and we will immediately delete such information, subject to
and in compliance with applicable law.


10. ADDITIONAL INFORMATION IF YOU ARE LOCATED IN CALIFORNIA

Residents of California. Pursuant to the California Consumer Privacy Act of 2018
(CCPA), residents of California are entitled to additional rights and
disclosures regarding their Personal Information. Please see our Notice to
California Residents for additional information regarding these disclosures and
how to exercise your rights.


11. ADDITIONAL INFORMATION IF YOU ARE LOCATED IN EUROPE

This Website is hosted in the United States. If you are a User accessing our
Website from Europe, Australia, Asia, or any other region with laws or
regulations governing personal data collection, use, and disclosure, that differ
from United States' laws, you are transferring your Personal Information to the
United States which does not have the same data protection laws as such other
regions. By providing your information to the Website, you are consenting to the
transfer of your information to the United States for processing and maintenance
in accordance with this Privacy Policy and our Terms of Service. You are also
consenting to the application of Delaware law and controlling U.S. Federal law
in all matters concerning the Website and ID.me Service.


12. BIOMETRIC PERSONAL INFORMATION

ID.me will not sell, rent, or trade your Personal Information. ID.me will only
transfer your Personal Information at your request, and with your consent, for
use by third parties to verify your identity or group eligibility, or as
required for the prevention of fraud or otherwise permitted by law.

ID.me may collect Biometric Information from some users as required by the
National Institute of Standards and Technology verification standards. Some
ID.me partners, such as the IRS and certain state agencies, may require ID.me to
verify the identity of an individual to a higher level of certainty as required
by the National Institute of Standards and Technology (NIST) guidelines. For
additional information regarding what Biometric Information we collect, and how
this information may be used, please see our Biometric Information Privacy
Policy.


13. CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may be periodically updated. This Privacy Policy may be
updated periodically to reflect new ID.me features or changes in our Personal
Information practices. We will post a notice for consumers at the top of this
Privacy Policy of any significant changes. We will indicate at the top of the
Privacy Policy when the policy was most recently updated.


14. ID.ME RX

ID.me, including ID.me Rx, will not sell, rent, or trade your Personal
Information. ID.me will only transfer your Personal Information at your request,
and with your consent, for use by third parties to verify your identity or group
eligibility, or as required for the prevention of fraud or otherwise permitted
by law.

Use of this Service requires the creation of an ID.me Rx Account. To understand
more about ID.me Rx, please review the ID.me Rx Terms of Service. Through your
use of ID.me Rx, you consent to ID.me collecting your health information and you
understand that ID.me Rx is not subject to the Health Insurance Portability and
Accountability Act (HIPAA) when it collects and processes this information.

Information collected through ID.me Rx. We may collect information from or about
you in several ways through your use of ID.me Rx and other ID.me Services,
including when you choose to share information with us by entering it through
our Services, through the postings that you may make, through healthcare
providers, through data partners and ID.me Rx Plan Administrators, through your
pharmaceutical purchases when using the Services, through pharmacy benefit
managers, and by using automated processes. Information collected may include
health information about you relating to your use of ID.me Rx, such as the
details about prescriptions pricing and discounts obtained, the prescribing
physician, the location of the pharmacy at which a prescription is purchased,
and details about how you use and interact with ID.me Rx. ID.me Rx may also
collect aggregate and de-identified data about the prescriptions purchased
across the ID.me Rx platform, this information will not be associated with your
ID.me Rx account.

We may use information to provide you with our ID.me Rx Services. We may use the
information collected from or about you to provide you with the services
requested, to facilitate your obtaining discount pricing on prescriptions, and
to provide information that may be of interest to you, such as information about
related ID.me Services, newsletters, and special offers. We may also use the
information that we collect to customize your experience on our Services, to
provide customer support, and to enforce the ID.me Rx Terms of Service.

We may share information with third parties who perform services on our behalf.
We may share your information with unaffiliated companies or individuals we hire
or work with that provide us with professional advice, business support, or
perform services on our behalf, including customer support, web hosting,
information technology, payment processing, direct mail and email distribution,
and administration, and analytics services. These Service Providers are allowed
to use your information to help us provide our Services and not for any other
purpose. When using ID.me Rx, you will share, directly with your pharmacy or
other third-parties at your discretion, your ID.me Rx Card details in order to
obtain applicable discounts. The information you share in your use of ID.me Rx
will be subject to the applicable policies and terms provided by those
third-parties.

Close your ID.me Rx Account. You may close your ID.me Rx account at any time. By
choosing to close your ID.me Rx account, you are directing ID.me to deactivate
your ID.me Rx Member ID and to de-identify the data stored in ID.me Rx relating
to your use of the Services. Closing your ID.me Rx account does not require the
closure of your ID.me account. To the extent that you shared your ID.me Rx Card
details with a pharmacy or third-party and they were integrated into your
profile and/or account with that third-party, you are responsible for updating
and removing any ID.me Rx Card information with such third-party.


15. CONTACT US

Whether you're a new or loyal customer, marketer, publisher, media member or job
seeker we'd like to stay connected and want to hear from you!

> Corporate Address.
> ID.me, Inc. 8280 Greensboro Drive, Suite 800 McLean, VA 22102
> 
> For Users and Customers.
> Member Service Inquiries may be directed to help@id.me.
> 
> For Legal Notices.
> Legal notices may be directed to legal@id.me.

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