Identity Verification Privacy Notice

1. Who We Are

• Legal company name: Smartledger Solutions Ltd
• Company number: 15187461
• Registered office address: 4 Corville Gardens, Birmingham B26 3JU, United Kingdom
• Companies House Authorised Corporate Service Provider (ACSP) number: AP002129
• Supervised for anti-money laundering purposes by the Institute of Certified Bookkeepers (ICB), Practice Number 24545
• ICO registration number: [to be confirmed]
• Contact email: team@smartledgersolutions.co.uk

This notice applies only to the information we collect through our identity verification service. Our wider Privacy Policy covers the rest of this website.

2. What Information We Collect

When you submit an identity verification application, we collect:

• Your name, email address and phone number
• An identity document (such as a passport, driving licence or national ID card)
• A proof-of-address document
• A facial image/selfie and a short liveness capture
• Technical information such as your IP address, generated automatically when you use the form

3. Why We Collect It and Our Legal Basis

We collect and process this information to:

• Provide the identity verification service you have requested (contract)
• Meet our anti-money laundering and know-your-customer obligations as a business supervised by the Institute of Certified Bookkeepers (legal obligation)
• Prevent and detect fraud and identity misuse (legitimate interests, and for biometric data specifically, substantial public interest — see below)

4. Facial Images and Biometric Data

The facial image/selfie and liveness capture you provide is biometric data, used to confirm that you are a real, present person and that you match the identity document you have submitted.

This is a special category of personal information under UK data protection law. We process it on the basis that it is necessary for reasons of substantial public interest — specifically, the prevention and detection of fraud and identity misuse, and compliance with our anti-money laundering obligations.

This data is shared with our identity verification partner, Didit, solely to carry out this check, and is retained only as described in Retention below.

5. Automated Checks and Human Review

Your documents and facial image are first checked automatically by Didit, our identity verification partner. This automated check looks at things such as document authenticity and whether your facial image matches your identity document.

The outcome of this automated check is then reviewed by a member of our team before a final decision is made on your application. You will not be subject to a decision based solely on automated processing without human review.

6. If You Don't Provide Information

If you choose not to provide the information requested — such as a valid identity document, a proof of address document, or a facial image/liveness capture — we will not be able to complete your verification request.

We do not retain incomplete/partial submissions beyond what is described in Retention below, and no fee is charged unless you had already submitted a complete application for processing.

7. Who We Share It With

We do not sell your information. We share it only where necessary, with:

• Didit, our identity verification partner, to carry out the document and biometric checks
• Stripe, our payment provider, to process the application fee
• Authorities or regulators, where we are legally required to report or disclose information (for example, suspected fraud or money laundering)
• Professional advisers, where necessary

8. International Transfers

Didit and Stripe may each process information outside the UK as part of their own service delivery. Where this occurs, it is subject to those providers' own safeguards and privacy terms.

We do not otherwise transfer your information internationally beyond what is necessary to provide the identity verification service.

9. Retention

We retain information submitted as part of an identity verification request — including identity documents, proof of address documents, and facial/liveness data — for 7 years from the date of your application, in line with our anti-money laundering record-keeping obligations as a business supervised by the Institute of Certified Bookkeepers. After this period, it is securely deleted.

10. Security

We take reasonable technical and organisational measures to help protect your information against unauthorised access, loss, misuse or alteration, including access controls and secure handling of submitted documents.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Depending on the circumstances and applicable law, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request erasure of your information, where applicable
• Request that we restrict processing of your information, where applicable
• Object to certain processing, where applicable
• Request a copy of your information in a portable format, where applicable

These rights are not absolute and may be limited by our legal obligation to retain anti-money laundering records for the period set out above.

12. Complaints

If you have concerns about how we handle your personal information, please contact us first at team@smartledgersolutions.co.uk so we can try to resolve the matter directly. We aim to respond within 14 days.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection matters, at ico.org.uk.

13. Changes to This Notice

We may update this notice from time to time. Any changes will be published on this page, along with an updated "Last Updated" date.