1. Introduction
A privacy policy is a statement or a legal document (in privacy law) that discloses some or all of the ways a party gathers, uses, discloses, and manages a customer or client's data. It fulfils a legal requirement to protect a customer or client's privacy of data termed as Personally Identifiable Information (PII).
This Privacy Policy (“Policy”) sets forth the reasonable security practices and procedures adopted by IDfy and shall apply for use, disclosure and sharing of the Sensitive Personal Information (“personally identifiable Information”) as provided by the customers to the IDfy via website/service. This privacy policy is in conjunction with the terms of use agreed by the customers while getting registered with IDfy for availing its services.
2. Purpose
This document sets forth the Privacy Policy in relation to information collected By IDfy in relation to any purpose, or otherwise in connection with its business or service provided to clients or customers.
3. Scope
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By accessing or using the Platform and/or availing the services provided through the platform or otherwise giving us your information, you undertake that you have the capacity to enter into a legally binding contract via this Policy, which constitutes a legally binding document between you and IDfy under applicable law.
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IDfy collects and processes your usage data, and Personal Information carefully, only for the purposes described in this Policy or in agreement (MSA) related to the availed services and only to the extent necessary as defined herein or within the agreement (MSA) and within the scope of all applicable legal regulations.
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This Policy seeks to ensure that any personal Information or third-party information handled by IDfy is managed in a way that is ethical, compliant, and adheres to the best industry practices.
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This Policy describes the types of Information IDfy collects, why and how IDfy uses the Information, with whom IDfy shares it, and the choices you can make about IDfy use of the Information.
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We also describe the measures taken by us to protect the security of the Information and how you can contact IDfy about its privacy practices.
4. Objective
IDFY TECHNOLOGIES (PHILIPPINES) INC. (“IDfy”, “we”, “our” or “us”) recognizes the importance of protecting personal details and information, and thus provides this Privacy Policy with respect to the access and use of various products and services of IDfy by way of any type of devices and media, including web-based, mobile-based applications, devices, URLs/links, notifications, chatbot and other forms of digital or non-digital media, (“Platforms”) as owned and operated by us and/or our affiliates and services provided thereon by us and/or our affiliates (“Services”). The term Platforms will also include all pages that are sub-domains or are associated with or within each Platforms and all devices, applications, features, technologies, functionalities and other services that IDfy operates or offers through such Platforms.
For the purpose of this Privacy Policy, the user of Services may be customers, channel partners, vendors or any other persons using Services or accessing the Platforms (“user”, “you” or “your”). This Privacy Policy will help you understand our policies and procedures regarding the collection, handling and use of your information.
We are committed to respecting your online privacy and recognize your need for appropriate protection and management of any information you share with us on the Platform.
This Privacy Policy is being framed in accordance with the applicable law. By using our Services through the Platforms, you signify your assent to this Policy and consent to the processing of your personal information and/or sensitive Personal Information or any other transaction that is generated with your use of the Platforms (“Information”). If at any time, an individual provides Information about someone other than himself or herself, the individual or an entity warrants that they have that person’s consent to provide such Information for the purpose specified. The Services are not available to persons below the age of 18 years.
If you do not agree with this Policy, ensure that you do not, in any manner, use our Services or website.
5. Roles and Responsibilities
All the employees, consultants, and contractors of IDfy are responsible for adhering to this Policy.
6. Policy Statement
PLEASE READ THE POLICY CAREFULLY TO FULLY UNDERSTAND THE NATURE AND PURPOSE OF GATHERING INFORMATION, USAGE, DISCLOSURE, SECURITY PROCEDURES AND SHARING OF SUCH INFORMATION.
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6.1 Information we collect
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IDfy gathers/obtains Information about you, for the Purpose, if you choose to provide the same voluntarily.
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IDfy only collects Information that is necessary to provide the services requested by its clients, which constitute the Purpose (“Purpose”).
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If any other additional Information is required then you will be informed of the same, and you should not provide such additional Information to IDfy unless you have explicitly consented to the same; neither will IDfy obtain or gather such Information from any other sources in the absence of such authorization, such as through access to its clients’ servers or databases.
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Specifically, you may be requested to provide certain Information in the event (i) you decide to proceed with the use of this website, or (ii) if you choose to share any Information with IDfy through any other means, in relation to the type of Purpose described to you in relation to such Information; furthermore, IDfy may obtain such Information about you from its clients (i) through its website, or (ii) through the collection of physical or scanned documents through any other means, or (iii) through the use of APIs or other means that permit the transfer of Information from its clients’ databases or servers to IDfy, in relation to the type of Purpose described in relation to such Information, in the event that such client has provided IDfy a copy of a consent or authorisation from you to collect such Information.
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IDfy does not collect any Information, unless specifically mentioned on the Website, without your consent. The verification of your Information may be done by IDfy directly or through one or more of its associates. By consenting to provide any Information to IDfy in relation to the Purpose, you are also consenting to the sharing of your Information with third parties for the Purpose
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IDfy may also disclose Information in connection with (i) the sale, assignment, or other transfer of its business, (ii) in order to respond to requests of government or law enforcement agencies, or (iii) where this is required by applicable laws, court orders, or government regulations, with prior intimation to you, to the extent that such intimation is legally permissible.
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IDfy does not sell Information to any third parties. Also, IDfy will not transfer the Information you provide to any third parties for their own direct marketing use. For more details and Information in relation to how IDfy may share Information about you with third parties or governmental and law enforcement agencies please refer to section 6.3 of this Policy.
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Please use your discretion when providing any Information to IDfy, and under any circumstances, do not provide Information to IDfy, unless you thereby consent to IDfy’s use of that Information for its legitimate business purposes and consent to the transfer and storage of such Information to and in IDfy’s databases. If you have any questions about whether the provision of Information to IDfy is, or may be, necessary or appropriate for particular purposes, please contact IDfy’s Grievance Officer / DPO (Data Protection Officer) at the coordinates provided in section for “Grievance Officer / DPO” of this Policy.
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Various kinds and manner of personal and / or sensitive information about individual or entities, as required for a purpose, which may include:
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Address
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Email
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Educational qualification
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Past employment references
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Personal identifiable information (PII)
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Sensitive Personal Information
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Device Information such as device ID, pages accessed, IP address, mobile network, operating system, or a unique identifier. This helps us analyze how our app works, fix any issues, keep the app safe and ensure a seamless experience for you.
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Personal Information such as name, government ID, residential status, postal (or registered) address, e-mail address, mobile number, date of birth, gender, marital status, specimen signature(s), tax and insurance information, etc, only if required and applicable. This helps us fulfil our legal obligations to provide the availed services by our customer and which require us to confirm your identity.
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Location information, If you have authorized tracking it will help us provide to you any and/or all location-based services and protect you against any and/or all fraud.
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Cookies aid us in recognizing you as a customer and remember your preferences so we can personalize our services. Cookies are required to prevent fraud and ensure the security of websites we control. You are free to decline our Cookies if your browser permits this. However, that may not guarantee you a seamless user experience.
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Any other information that is required to be collected as per specific mandate from any bank or as a legal requirement in the Philippines.
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6.2. Purpose / Use of Information collection
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IDfy provides a range of background verification and allied services (ID verification, identity verification, Video KYC, AML screening etc.) for its clients through various means, which are enumerated below:
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Through its online services as detailed on the website https://www.idfy.com/ph/;
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Through the collection of various physical documents from individuals directly;
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Through APIs or other technological or software systems or methods that gather from end users or receive data from its clients’ servers in a manner authorized by and agreed with, its clients;
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Through physical verification of addresses and other locations; and
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Through communication and correspondence with educational institutes and universities, and various corporate bodies.
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You may have been directed to provide certain Information for the Purpose to IDfy through any of the means listed above, by or on behalf of a client of IDfy. Note that your use of this website, and you providing any Information to IDfy through this website, or through any other means, is at the behest and direction, and on the request, of such client, and IDfy disclaims any and all responsibility in relation to such Information, other than as specifically accepted here, or in IDfy’s Terms of Use. You should read this Policy carefully to ensure that you are aware of the manner and purpose for which IDfy collects such Information from you, and the manner in which IDfy stores, processes, and uses such Information.
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The entity or individual on whose direction or request you have been asked to visit this website, or provide Information to IDfy in any other manner, may have sought your authorisation to share your Information with IDfy; alternatively, IDfy may seek your authorisation and consent to obtain and use your Information, and shall specify the type of Purpose for which it seeks such Information from you. If you (i) have not received or accepted such an authorisation from IDfy or any other entity or individual at whose behest or direction you are asked to provide any Information to IDfy, or (ii) do not consent to the use of your Information by IDfy, or (iii) do not consent to the sharing of such Information with third parties in the manner described in section 6.3 of this Policy, please:
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Do not share any Information with IDfy or its representatives through any means;
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Do not proceed any further on this website, or provide any further Information on or through this website;
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Close the tab or window in your browser where this website is displayed; and
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Contact the entity or individual on whose direction you visited this website, or on whose direction you were contacted by IDfy.
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You proceeding with the use of this website, and/ or your providing any Information to IDfy on or through the use of this website or through any other means, is based upon the assumption that you have indeed executed and provided to such entity or individual, or to IDfy, such an authorization, and the subsequent provisions of this Policy are based upon such an assumption.
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IDfy is committed to protecting the privacy and Information provided voluntarily by individuals to enable IDfy to complete the Purpose on behalf of its clients. This Policy sets out the nature/type of Information IDfy collects, the Purpose of such collection and usage, disclosure of such Information, and IDfy’s security practices and procedures in relation thereto.
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You may access this website for preliminary browsing without availing IDfy’s services. In such an event, and/ or in the event you access this website in relation to IDfy’s services, or in relation to any Purpose, you confirm that you have read, understand, and agree with this Privacy Policy each time you access the Site.
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6.3. How are we sharing information
Disclosure/Sharing of Information:
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To enable IDfy to provide services in relation to the Purpose, the Information provided by you may be shared by IDfy either with its own employees, officers, representatives, and directors other corporate entities and affiliates (both in Philippines and outside Philippines) working on IDfy’s behalf to provide the service in relation to the Purpose, and all other agencies from which relevant data or responses are to be obtained for the Purpose (both in Philippines and outside Philippines), on a ‘need-to-know’ basis, for the purpose of verifying the authenticity of the Information/ for the purpose of undertaking the verification and submitting a report, which may be used for the Purpose.
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Exceptions to Consent Limitations and this Policy, and Disclosure of Information: IDfy may disclose Information if required to do so by law or upon the advice of its professional advisors, such as legal counsel, that such disclosure is reasonably necessary to respond to:
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court orders, or other legal process, or third-party rights owners; or
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law enforcement offices, and / or Government agencies mandated under the law to obtain such Information; Provided that IDfy shall provide prior intimation of such disclosure to you, to such extent as may be permissible under applicable law.
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As a user of this website, you understand and agree that you assume all responsibility and risk for your use of the website, the internet generally, and the documents you post or access and for your conduct on and off the website.
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In case of an amalgamation, merger, acquisition or business transfer, IDfy will transfer all your Information to the acquirer.
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We will only disclose your Information in accordance with this Policy. If we want to use it for any other purpose, we will obtain your consent.
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IDfy does not control the acts of its users. All users should be aware that, when they disclose Information such as their name, e-mail address, etc. to third parties, that Information may be collected and used by others to send unsolicited e-mail from other parties, who may or may not be users. In the event that you encounter any person improperly collecting or using information about users, please contact us by emailing at dpo.philippines@idfy.com.
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6.4. Keeping information secure
Security Practices and Procedure are:
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IDfy is dedicated to guarding the security of your information and has taken appropriate steps to protect the security of Information and to ensure that your preferences for its intended use are followed.
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IDfy takes industry standard security measures to protect your data from loss, misuse, unauthorised access or disclosure, alteration, or destruction.
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IDfy prioritises the confidentiality and security of your Information. As a result, it uses industry standards as well as physical, technical, and administrative security measures to keep Information confidential and secure, and IDfy will not share your Information with third parties unless otherwise specified in this Policy / in agreement with its customer.
We are committed to keeping your information secure and using it appropriately and will:
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Limit the collection and use of your Personal Information to that which we believe is necessary to serve you, administer our business or tell you about our services.
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Restrict employee access to your Personal Information to those employees who need access to such information to provide you with our services through the site.
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Maintain appropriate physical, electronic, and procedural safeguards and controls, including encryption technologies, designed to protect your Personal Information, in line with industry standards and practices, to protect information about you.
We use all reasonable and appropriate technical and organizational security measures to protect the security of your Personal Information both online and offline including the implementation of access controls, implementation of firewalls, network intrusion detection, and use of anti-virus software.
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Please be aware, however, that while IDfy strives to protect Information and privacy, by using the website, users accept the inherent security implications of data transmission over the internet and the world wide web, which cannot always be guaranteed to be completely secure, and thus there will always be some inherent risks associated with using the website.
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Users are responsible for safeguarding the login and password records for their accounts. IDfy will evaluate this necessity on an annual basis, taking into account your privacy and IDfy's relationship, as well as the applicable legislation.
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6.5. Information retention and deletion
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Duration of storage: IDfy stores Information for such duration as may be required to fulfil the Purpose. Such duration may vary by the type of Purpose contemplated in relation to such Information.
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By providing any Information to IDfy, you agree to IDfy’s storing such Information for the duration necessary to fulfil such Purpose.
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Note also that IDfy shall store Information beyond the duration required for the Purpose in the event it is mandated or obliged to do so under any applicable law.
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6.6. Your privacy rights
Rectification/Correction of Information:
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You have the right to review your Information submitted by you on the website https://www.idfy.com/ph/ and to access / update / correct / delete any Information provided by you directly on the mentioned website. You hereby understand that any such access / updation / modification or deletion may affect your ability to use the website / services avail via IDfy’s customer. Further, it may affect IDfy’s ability to provide its services to you.
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IDfy reserves the right to verify and authenticate your identity and your account information and/or payment information in order to ensure accurate delivery of services. Access to or correction, updation or deletion of your Information may be denied or limited by IDfy, if it would violate another person’s rights and/or IDfy's client's rights based on IDfy's agreement with its client and/or is not otherwise permitted by applicable law.
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If you need to access, update, correct or delete your Information that IDfy may have collected directly from you via the website to offer you personalized services and offers, you may send such requests to IDfy at citing the reason for such request of Information. IDfy will take all reasonable efforts to incorporate the changes within a reasonable period of time.
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In addition to being able to update and correct your Personal Information, you may also have other data protection rights. This revolves around what you can allow or restrict us to do with your information.
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if we have collected and processed your Personal Information with your consent, then you have the right to withdraw your consent at any time stating your reasons or concerns.
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You also have the right to ask for a copy of your Personal Information in a portable (machine-readable) format. You can also say no to us using your Personal Information for direct marketing and in certain other circumstances which include events where ‘legitimate interest’ is involved.
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As per the existing legal regulations, specific data fields would be locked once you enter that information in our website. There would be a separate procedure to modify such information (such as after giving a self-declaration), you can find out further details by contacting us at dpo.philippines@idfy.com.
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Withdrawing your consent will not affect the lawfulness of any processing we carried out before your withdrawal, nor will it affect processing of your Personal Information carried out in reliance on other lawful grounds other than consent.
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We will keep your Personal Information for as long as it is needed to carry out the purposes we've described above / as mentioned in MSA signed by IDfy with it’s customer, or as otherwise required by law. Generally, this means we will keep your Personal Information as long as your account is active or as needed to provide our services. If you cancel/ deactivate/ unsubscribe your account with us, we are not under any obligation to retain your information. However, we may retain your information for twenty-four (24) months (post cancellation/ deactivation), as our business practice.
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You can make any of these requests by contacting us at dpo.philippines@idfy.com. We will respond to all requests in accordance with the applicable laws.
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6.7. Cookies
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We use cookies. "Cookies" are a feature of a web browser that allows web servers to recognize the computer used to access a site. They are small pieces of data that are stored by a user's web browser on the user's hard drive. Information gathered through cookies and web server logs may include information such as the date and time of visits, the pages viewed, time spent at this site, and the websites visited just before and just after this Site. Cookies can remember what information a user accesses on one web page to simplify subsequent interactions with that site by the same user or to use the information to streamline the user's interactions on related web pages. This makes it easier for a user to move from web page to web page and to seamlessly navigate the Site. Cookies should make your online experience easier and more personalized.
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We use site browser software tools such as cookies and web server logs to gather information about this site's Users' browsing activities, and gain insights into trends and statistics in order to improve this site and better serve the Users of this site. This information helps us to continually improve this site to better meet the needs of our current and prospective users. We do not link cookies to personally identifiable information. All information gathered through cookies is gathered in a manner so as to preserve the anonymity of its source, and is kept strictly confidential. The information is used and analyzed only at an aggregate level and none of this information is reviewed at an individual level.
Nevertheless, you can constantly control how and whether cookies would be accepted by your web browser; if you do not want your details to be used in this manner, you can either disable your cookies or opt-out at the relevant download or request page. For more information on how to do so, please refer to the documentation accompanying your browser. However, if you have turned off all cookies, many features of this Site may not be available to you.
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6.8. Links to Other Sites
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Occasionally, at our discretion, we may include or offer third party products or services on our Site, which will be clearly notified on the Website. These third-party sites have separate and independent privacy policies, and you are advised to peruse the policies regarding privacy and related topics posted by such third-party sites before use / disclosing any personal Information. We are not responsible for third party content accessible through the Site, including opinions, advice, statements and advertisements, and you shall bear all risks associated with the use of such content. We are not responsible for any loss or damage of any sort which you may incur from dealing with any third party.
7. Limitation of Liability
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IDfy shall not be liable to you for any loss of profit, production, anticipated savings, goodwill or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary or consequential losses arising out of performance or non-performance of its obligations under this Policy.
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Except as expressly permitted otherwise in this Policy, you shall have the right to recover damages or to indemnification of any nature, whether by way of lost profits, expenditures for promotion, payment for good will or otherwise made in connection with this Policy, solely as a result of the expiration or permitted or lawful termination of the engagement contracted between the Parties.
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Notwithstanding anything contained in this Policy or elsewhere, IDfy shall not be held responsible for any loss, damage or misuse of your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event. The term “Force Majeure Event” shall mean any event that is beyond the reasonable control of IDfy and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, pandemic, epidemic, computer hacking, civil disturbances, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, or national/state lockdown due to any reason and any other similar events not within the control of the IDfy.
8. Applicable Law
This Privacy Policy, and our collection, use and disclosure of your information, is governed by Philippines law, and not by the laws of any country, territory or jurisdiction other than Philippines. We do not represent or warrant that the Site, or any functionality or feature thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to download, access or use the Site do so on their own initiative and at their own risk and are responsible for complying with all local laws, rules, and regulations. By downloading, accessing, using, or submitting any information to the Site, users of the Platform or the Site from outside Philippines acknowledge that the Site is subject to Philippines law and consent to the transfer of their information to Philippines, which may provide a different level of data security than in their country of residence, and waive any claims that may arise under their own national laws.
9. Changes to this Policy
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IDfy may change this Policy from time to time at its discretion. The date of the Policy is indicated at the top of the Policy. You may review the Policy periodically to understand the Privacy protection offered by IDfy for your Information.
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If you have any suggestions or questions you may contact IDfy’s Grievance Officer / DPO at the coordinates set out in Section “Grievance Officer / DPO“ of this Policy.
10. Grievance Officer / DPO
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Should you have any complaint or grievance about the manner in which IDfy receives or processes your Information, you may write to our Grievance Officer / DPO, whose details are provided below. IDfy is committed to resolving any such grievances in an expeditious and effective manner.
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Details of IDfy’s Grievance Officer / DPO:
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Name: Johann Kelly Lao
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Office Address: 25th Floor, Picadilly Star Building, 27th Street Corner 4th Avenue, Bonifacio Global City, Barangay Fort Bonifacio, Taguig City, Philippines
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Email Address: johann.kelly@idfy.com
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Phone Number: +91-+639177035357
11. Disclaimer
In spite of its best efforts to protect the interest of its clients it is made clear that in the unlikely event of any data theft or misuse, IDfy will not be liable in any way. The policies uploaded in the Website of IDfy are illustrative in nature and the rights and liabilities of the parties are to be governed strictly by the actual contract entered into and signed by the parties thereto.