Australian Privacy Policy

Privacy is a fundamental human right. Your personal information is exactly that, yours. At OCR Labs Group (OCR Labs), we want to keep it that way. That is why privacy is paramount to us, in everything we do, and we are committed to respecting your privacy.

Our Privacy Policy sets out how we collect, hold, use, store and disclose your personal and sensitive information. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

For the purposes of this Privacy Policy, 'us' 'we' or 'our' means the OCR Labs' (listed at the end of this Policy). Noting, we are bound by the Australian Privacy Principles in the Privacy Act 1988 and ensure compliance with underlying state and territories equivalent legislation. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees.

1. What is personal or sensitive information?

Personal information includes information or an opinion (whether true or not) about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details.

Sensitive information includes biometric information, information about an individual's health, political affiliations, union associations, race and ethnic origins, criminal record and religious or philosophical beliefs.

2. What personal and sensitive information do we collect and hold?

We may collect and hold the following types of personal information and sensitive information:

  • name;
  • mailing or street address;
  • email address;
  • telephone number and other contact details;
  • age or date of birth;
  • nationality;
  • government related identifiers, such as your licence number and class, Medicare number, state or national ID card number, passport number, and birth or marriage certificate number;
  • other information identifiable from scanned ID documents you provide, such as photographs of your face;
  • biometric information, such as video footage or photographs of your face;
  • information obtained from fraud-prevention services and document verification services;
  • your device ID, device type, geo-location information, computer and connection information, IP address and standard web log information;
  • any additional information relating to you that you provide to us directly through our website or apps or indirectly through your use of our website or apps or online presence or through other websites or accounts from which you permit us to collect information;
  • information you provide to us through client or customer surveys; and
  • any other personal information that may be required in order to facilitate your dealings with us.

3. How do we collect your personal and sensitive information?

We may collect these types of personal or sensitive information either directly from you, or from third parties. We may collect this information when you:

  • utilise one of our verification services through one of our apps or web-based platforms;
  • if you are a representative of one of our partners or clients, create an administrator account or otherwise use one of our apps or web-based platforms on behalf of one of our partners or clients;
  • communicate with us through correspondence, chats, email or otherwise through our website; or
  • otherwise interact with our sites, services, content or advertising.

Where you provide us with personal or sensitive information on behalf of someone else, you must ensure you are permitted to provide us with their personal or sensitive information. You also need to tell them how to find a copy of this Privacy Policy.

We may receive personal, sensitive or anonymised information about you from our clients where they make use of our services. This information may include a client ID that identifies you in the third party's database, as well as the categories of information set out above. We will advise you as soon as possible where we collect personal and sensitive information from another source other than yourself.

In addition, when you apply for a job or position with us, we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.

Retention of your personal and sensitive information

We will retain your personal and sensitive information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal and sensitive information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

4. Why do we collect, hold, use and disclose personal and sensitive information?

The purposes for which we will use personal and sensitive information will depend on the relationship with you and the products or services you require from us. We may collect, hold, use and disclose your personal and sensitive information for the following purposes:

  • to enable you to access and use our website or apps;
  • to provide verification services, where you are seeking to access one of our clients' products or services (or the products or services of third parties, where our clients act as brokers, resellers, referrers or representatives of such parties);
  • to operate, protect, improve and optimise our website or apps, business and our clients' and users' experience, such as to perform analytics, conduct research and create new products, and conduct training;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts in connection with our verification services, and information requested by you;
  • to comply with our legal obligations, resolve any disputes that we may have with any of our clients or users, and enforce our agreements with third parties; and
  • where relevant, to consider your employment application.

We may also be entitled:

  • to use personal information for any purpose which is related to the above purposes; and
  • to use sensitive information for any purpose which is directly related to the above purposes.

We may also use de-identified, aggregated information to share insights about users of our verification services, such as by publishing a report on trends in the usage of such services.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to the collection, use and disclosure of personal and sensitive information as described above.

5. Other circumstances where we may disclosure of your personal or sensitive information

Business Transactions

If we are involved in a merger, acquisition or asset sale, your personal and sensitive information may be transferred. We will provide notice before your personal and sensitive information is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, we may be required to disclose your personal and sensitive information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other legal requirements

We may disclose your personal and sensitive information in the good faith belief that such action is necessary to:

  • comply with a legal obligation;
  • protect and defend the rights or property of the Company;
  • prevent or investigate possible wrongdoing in connection with our services;
  • protect the personal safety of users of the services or the public;
  • protect against legal liability.

6. Do we use your personal information for direct marketing?

If we have collected your personal information because you are a representative of one of our current or prospective partners or clients, we may send you direct marketing communications and information about services and products offered by members of the OCR Labs Group. Noting, we do not use personal information collected as part of our identity verification services, we provide to our partners and/or clients, for direct marketing.

Our marketing may take the form of emails, SMS, mail or other forms of communication, in accordance with the Privacy Act.

You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).

If we use your personal information for direct marketing, we will ensure we comply with our obligations under the Do Not Call Register Act 2006 and the Spam Act 2003.

7. To whom do we disclose your personal and sensitive information?

We may disclose personal information for the purposes described in this Privacy Policy to:

  • companies within the OCR Labs Group;
  • our clients and third parties (where our clients act as brokers, resellers, referrers or representatives of such parties), where you are seeking to access their products and/or services and are required to verify your identity in order to do so;
  • our employees and contractors, for the purposes of managing our products and systems and providing our services*^1^;
  • third party suppliers and service providers (including providers of document verification services to help us verify the validity of identity documents you disclose to us, and other providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
  • professional advisers, dealers and agents;
  • our existing or potential agents, business partners or partners (including our trusted resellers and referrers);
  • specific third parties authorised by you to receive information held by us;
  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law; and
  • as otherwise required or permitted by law.

\1 -- noting parts of our algorithm engineering teams are located overseas (Japan and UK). These teams may be provided access to information that we reasonable suspect are fraudulent identity documents and/or spoofed liveness video. If this occurs, we maintain full control of access to this information that is only retained for a very limited period time and is not transferred outside of Australia.*

8. Overseas transfer of personal and sensitive information

No personal and/or sensitive information is transferred overseas. We only leverage reputable Australian based cloud hosting and infrastructure services.

9. Security and storage

OCR Labs is equipped for the toughest standards. Our platform meets stringent privacy, security and integrity standards based on international best practices.

Whilst we cannot guarantee the safety or security of your personal information, we take reasonable physical, electronic, and procedural measures to protect your personal and sensitive information against loss or unauthorised access, use, interference, modification, or deletion.

Among other things, we encrypt personal and sensitive information both in transit and at rest and we implement robust disaster recovery and business continuity procedures.

Personal and sensitive information will be held in a secure environment either in writing, electronically or both. We have security measures in place which are intended to protect personal and sensitive information. The key methods of securing the storage of personal and sensitive information include:

  • Secure access to electronic and physical records containing personal and sensitive information, via password protected access permissions to systems and security-protected access to filing cabinets and storage;
  • Access only to authorised OCR Labs employees and contractors that require access to perform their daily duties; and
  • Varying access levels depending on the level of the authority and the type of personal and sensitive information required to be accessed.

Controls relating to how personal and sensitive information is extracted from the secure environment and how it is used and distributed. We also regularly conduct independent security audits, vulnerability scans, and penetration tests to ensure compliance with security international best practices and standards.

10. Unsolicited personal and sensitive information

There may be circumstances where an individual provides us with the
personal or sensitive information about another person. Where we
receive unsolicited personal information which we do not require for
the purposes we have outlined above, we will destroy or de-identity
that information as soon as practicable (if it is lawful and
reasonable to do so).

11. Accessing and correcting your information

You can access the personal information we hold about you by contacting us using the contact information below.

Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will provide you with a written notice explaining why. We may also need to verify your identity when you request your personal information.

We note that we may not have stored your personal information where it was collected by us to perform verification services and such services have been completed.

If you think that any personal information, we hold about you is inaccurate, outdated, incorrect or incomplete, please contact us promptly and we will take reasonable steps to ensure that it is corrected.

12. General Data Protection Regulation (GDPR) Privacy

Legal Basis for Processing Personal Data under GDPR

We may process personal data under the following conditions:

  • Consent: you have given your consent for processing personal data for one or more specific purposes.
  • Performance of a contract: provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: processing personal data is necessary for compliance with a legal obligation to which we are subject to.
  • Vital interests: processing personal data is necessary in order to protect your vital interests or of another natural person.
  • Public interests: processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested us.
  • Legitimate interests: processing personal data is necessary for the purposes of the legitimate interests pursued by us.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

We undertake to respect the confidentiality of your personal data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to your personal data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
  • Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the service.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

13. Using our website and cookies

When you use our verification services, we automatically receive and record certain information from your computer (or other device) and/or your web browser.

This may include such information as the third-party website or application into which the services are integrated, the date and time that you use the services, your IP address and domain name, your software and hardware attributes (including operating system, device model, and hashed device fingerprint information), and your general geographic location (e.g., your city, state, or metropolitan region).

To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.

What are cookies? Cookies are small files that are stored on your computer or other device by your web browser.

A cookie allows us to recognize whether you have used our services before and may store user preferences and other information.

How are cookies used? For example, cookies can be used to collect information about your use of our services during your current session and over time, your computer or other device's operating system and browser type, your Internet service provider, your domain name and IP address, and your general geographic location.

How do you avoid cookies? If you are concerned about having cookies on your computer or device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it.

You can also delete cookies from your computer.

However, if you choose to block or delete cookies, certain features of our services may not operate correctly.

14. Links

Our website or apps may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained.

Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites.

The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

15. Making a complaint

If you think we have breached the Privacy and/or applicable data protection laws, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below.

Please include your name, email address and/or telephone number and clearly describe your complaint.

We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.

If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take, one of which is to lodge a complaint with the Office of the Australian Information Commissioner.

16. Contact us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us promptly using the details set out below:

Privacy Officer

e: t: 1300 OCR LABS a: Suite 1302, 140 Arthur Street, North Sydney NSW 2060 Australia

17. Privacy Impact Assessment (PIA) Register

Ref. Date signed Short description

PIAv1.1 Oct-18 Initial draft covering core verification services (Orbit SDK) PIAv2.0 Jan-19 IDVaaS based upon Orbit SDK engines, including updates on the recommendations from PIA_v1.1

18. Privacy: Transparency Report

OCR Labs is committed to being transparent about government requests for customer data and how we respond. We publish an annual Transparency Report disclosing the number of government requests for customer data OCR Labs receives.

Government and private entities are required to follow applicable laws and statutes when requesting customer information and data from OCR Labs.

Report: 1 July 2019 - 30 June 2020

No requests received.

19. OCR Labs Group

This Privacy Policy covers the following entities, which form part of the OCR Labs Group:

  • OCR Labs Pty Ltd
  • OCR Labs IDVaaS Pty Ltd
  • IDKit Pty Ltd
  • Express VOI Pty Ltd
  • OCR Labs ANZ Pty Ltd
  • OCR Labs Management Pty Ltd

Effective Date: 16 April 2021