Privacy Policy

Effective Date: July 1, 2020

A. Privacy Statement

This privacy policy (“Privacy Policy”) governs how Private Identity LLC (“Private Identity,” “we”, “our” or “us”) uses the Personal Data we collect, receive and store regarding individuals in connection with the use of the Website (our “Service”), as well as your choices regarding use and disclosure of your Personal Data.  As used in this Privacy Policy, the term “Personal Data” (“Personal Data”) means information that identifies you or your household directly or indirectly, by reference to identifier(s) such as your name, identification number, location data, online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural, educational, commercial, professional or social identity.

By accessing our Services, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Services. Each time you use our Service, the current version of the Privacy Policy will apply. Accordingly, whenever you use our Service, you should check the date of this Privacy Policy (which appears at the top) and review any changes since the last version. This Privacy Policy is applicable to all Service visitors, registered users, and all other users of our Service.

Further, you acknowledge that this Privacy Policy is part of our Terms of Service which is available at​. This Privacy Policy is incorporated by reference, and by accessing or using our Service, you agree to be bound by the Terms of Service.  If you do not agree to our Terms of Service, do not access or use our Service.

B. Personal Data Collected by Private Identity


When you use our CLOUD BIOMETRIC MFA service to authenticate yourself, we anonymize and/or pseudonymize your biometric information and only collect anonymized and/or pseudonymized information. As explained in the terms of service accessible at, the Services provide you a limited, revocable, nonexclusive, non-assignable license to access the Cloud Biometric MFA application onto a device (phone, laptop, etc.) and use the Cloud Biometric MFA application for the sole purpose of accessing our authentication Services to enroll, identify, verify or authenticate yourself.

1) When you use our authentication Service or access the Website to have access to general information available on the Site, we do not currently require you to provide Personal Data. However, we may receive and/or collect Personal Data from you in the following ways:

a) Purchases. We use the tools, software or services of third-party service providers (i.e. AWS, GCP and Microsoft Azure) to process transactions on our behalf, in which case you acknowledge and agree to review and be bound by the terms of use and privacy policy of said third-party service provider. Private Identity does not receive Personal Data from these vendors.

b) Log Files. We use log files for our products for billing and quality assurance only. The information inside the Private Identity log files does not include internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), referring/exit pages, clicked pages or any other information your browser or device may send to us. We do not combine the information collected by any log files with customer or end-user personally identifiable information (PII).

1. Personal Data that you Knowingly and Willingly Provide

Private Identity collects the information that you knowingly and voluntarily provide when you use our Service (such as through web forms or profile screens), including registration/account setup information, profile details, payment information, and ratings information. We primarily use this information to fulfill your transaction requests. You can choose not to provide us with certain Personal Data, but then you may not be able to take advantage of our Service or other available features we offer. The information that we collect and use may include the following kinds of Personal Data:

  • First and Last Name
  • Alias(es)
  • Email Address
  • Credit and/or Debit Card Information
  • Purchase Information, including content and the time of the purchase
  • Postal Address
  • Telephone Number
  • Login or account name, screen name, nick name, handle or any other identifier that permits the physical or online contacting of a specific individual or household
  • Social Security Number
  • Driver’s License or State ID Number
  • Alien Registration Number
  • Passport Number
  • Taxpayer Identification Number
  • Vehicle Registration Information
  • Health Insurance Number
  • Insurance Policy Number
  • Signature
  • Medical Information, including Protected Health Information (PHI)
  • Personal Property Records
  • Political Affiliations or Activities
  • Spouse information, marital status, child information, emergency contact information
  • Education information
  • Genetic Information
  • Disability Information
  • Bank Account Number
  • Banking Account Information
  • Criminal Records
  • Military Records
  • Military or veteran status
  • Security Clearance
  • Resume
  • Mother’s middle and maiden names
  • Race
  • Color
  • Religion
  • Gender
  • Gender Identity and Gender Expression
  • Sexual Orientation
  • Age
  • National Origin
  • Citizenship Status
  • Ancestry
  • Status as a victim of domestic violence, assault or stalking
  • Geolocation Data
  • Audio, electronic, visual, thermal, olfactory or similar information
  • Professional and Employment Information, including employment history
  • Financial Information, including credit card and debit card numbers

Personal Data From and/or About Others. We may also collect and store Personal Data about other people that you provide to us, as well as information about you provided by others. We may also receive your Personal Data from trusted third parties (including, for example, business partners, sub-contractors in technical, payment and delivery of membership services, advertising networks, analytics providers, search information providers, credit reference agencies).

Anonymized and/or Pseudonymized Information. When you use our service to authenticate yourself, we anonymize and/or pseudonymize your biometric information and only collect anonymized and/or pseudonymized information. As explained in the terms of service accessible at, the Services provide you a limited, revocable, nonexclusive, non-assignable license to access/download the Cloud Biometric MFA application onto a device (phone, laptop, etc.) and use the Cloud Biometric MFA application for the sole purpose of accessing our authentication Services to enroll, identify, verify or authenticate yourself.

C. How Is Your Personal Data Used?

We will only process your Personal Data, including sharing it with third parties, where (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party, (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.

We may use Personal Data we collect about you on its own or combine it with other information we have about you to:

  • To create user accounts and/or profiles through registration;
  • Perform internal operations, such as tracking and improving the effectiveness of our website, mobile experience, and marketing efforts;
  • Provide product and/or Service fulfillment, such as creating and maintaining accounts, managing purchases, payments, and more;
  • Resolve disputes between users and/or a user and the company as set forth in our Terms of Service;
  • Use the location of your mobile device to prevent fraud or deliver other location-based services that you may request;
  • Receive feedback;
  • Conduct audits;
  • Recruit;
  • Provide information to our business partners;
  • Provide information to our suppliers;
  • Provide information to our representatives and/or advisors, such as our attorneys, accountants, and others to help us comply with legal, accounting, or security requirements;
  • Transfer your information, such as to servers outside of the United States, or as part of a merger or sale of the business;
  • Protect the rights, safety, and information of our members, third parties, as well as our own. This includes fraud prevention, business or product recalls, prosecuting and defending a court arbitration or similar proceeding, and more;
  • Comply with legal requirements, such as in response to a subpoena or similar investigative demand;
  • Protect against harm to the rights, property or safety of Private Identity, our users, or the public as required or permitted by law.

We may also disclose your Personal Data as otherwise set forth in this Privacy Policy, as permitted by law, or with your consent.

D. Who Can Access the Information We Collect?

We will only transfer your Personal Data to trusted third-parties who provide sufficient guarantees in respect of the technical and organizational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures.

Where third parties are processing Personal Data on our behalf, they will be required to agree, by contractual means or otherwise, to process the Personal Data in accordance with the applicable law and to act only on our instructions, or as permitted by law.

Private Identity may disclose your Personal Data in the following to the following entities and purposes:

Agents. We employ other companies and individuals to perform functions on our behalf. Examples of such functions include cloud storage providers and other third party service providers involved in processing transactions and billing processing credit card payments, and providing customer service. We share our users’ Personal Data with these agents as we deem necessary for such third parties to perform their functions.

Employees. Only authorized employees have access to your Personal Data.

Authorized Business Partners. These include agents, contractors, vendors, licensors, resellers, system integrators, etc. Private Identity, our affiliates, and our business partners may share this Personal Data with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, Service, content, and advertising.

To Comply with Legal Process, Protect Private Identity, or Enforce our Rights. We may release your Personal Data when it is necessary to (i) conform to legal requirements or comply with legal process; (ii) enforce or apply our conditions of use and other agreements (iii) protect the rights, safety or property of Private Identity, our affiliates, service providers, our users or the public, or (iv) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

As Part of a Merger or Sale of Business. We may disclose your Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

E. Selling of Personal Data

We will not sell your Personal Data to third parties for their use without your consent.

F. Disclosure of Personal Data for a Business Purpose

We will never disclose your Personal Data to third parties for a business purpose with whom you do not have an existing relationship. We may disclose your information (including Personal Data) to our strategic business partners with whom you have an existing relationship in order for our partners to better target their products and services to you. Our partners will not have direct access to your Personal Data but rather will have the ability to communicate with you through your participation with our Service.

The kinds of Personal Data we have disclosed for a business purpose over the preceding twelve (12) months include: None.

G. Minors and Children Privacy

1. Children Online Protection

Our Service is not directed to children under the age of 16, if you are not 16 years or older, do not use our Service. We do not knowingly collect Personal Data from children under the age of 16.  If we learn that Personal Data of persons less than 16 years-of-age has been collected through our Service, we will take the appropriate steps to delete this information.  If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted or otherwise communicated Personal Data to our Service without your consent, then you may alert us at so that we may take appropriate action to remove the minor's Personal Data from our systems.

H. Links to Third Party Services

Our Service may contain links to third party websites, applications and services not operated by us. These links are provided as a service and do not imply any endorsement by Private Identity of the activities or content of these sites, applications or services nor any association with their operators. Private Identity is not responsible for the privacy policies or practices of any third party including Websites or services directly linked to our Service. We encourage you to review the privacy policies of any third-party site that you link from our Service.

1. Security

We take reasonable technical and organizational precautions to protect the confidentiality, security and integrity of all data including any Personal Data. Although we use security measures to help protect Personal Data against loss, misuse or unauthorized disclosure, we cannot guarantee the security of information transmitted to us over the Internet. While we strive to use commercially acceptable means to protect Personal Data, there is no guarantee that information may not be accessed, disclosed, altered or destroyed.

2. Storage

Any Personal Data that you provide to us is generally stored on AWS, GCP or Microsoft Azure servers located in the United States. If you are located in another jurisdiction, you should be aware that once your Personal Data is submitted through our Service, it will be transferred to our servers in the United States and that the United States currently does not have uniform data protection laws in place.

3. Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

I. International Users

We are headquartered in the United States. Your Personal Data may be accessed by us or transferred to us in the United States or to our affiliates, partners, merchants, or service providers who are located worldwide. If you are visiting our Service from outside the United States, be aware that your information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated. By using our Service, you consent to any transfer of this information.

We will protect the privacy and security of Personal Data according to this privacy statement, regardless of where it is processed or stored, however you explicitly acknowledge and consent to the fact that Personal Data stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Data.

J. Your Rights and Deletion Requests

Private Identity will not collect any Private Data subject to the rights established by the GDPR or CCPA. On a voluntary basis, Private Identity will take reasonable steps to delete anonymized subject data upon request. Where we are able to authenticate a user deletion request, and subject to a waiting period during which we will confirm any contractual or legal commitments to retain the anonymized data, anonymized data will be permanently erased.

K. Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy from time to time. If we make any material changes to this Privacy Policy or the way we use, share or collect Personal Data, we will notify you by revising the “Effective Date” at the top of this Privacy Policy, prominently posting an announcement of the changes on our Service, or sending an email to the email address you most recently provided us (unless we do not have such an email address) prior to the new policy taking effect. Users are bound by any changes to the Privacy Policy when he or she uses our Service after notice of such changes has been communicated. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with Private Identity’s current practices.