Introduction
Scope
This document contains the Privacy Policy (a.k.a. Privacy Notice or Privacy Statement) that applies to the AV Yourself Age Verification Service (“AV Yourself AV Service”) that is provided directly to client users by W2 Global Data Solutions Ltd (“W2”), where only the resulting age verification status is communicated to a referring merchant. The nominated merchant is specific to each age verification transaction.
The scope of this document is constrained to the rationale, usage and contents of the Privacy Policy that relates to the AV Yourself AV Service and the Privacy Policy itself will be published on the AV Yourself website at https://avyourself.com/and referred to within user communications.
The Privacy Policy must comply with the requirements of both the UK Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679)) (“GDPR”).
Responsibilities
The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to AV Yourself Limited collecting/processing their personal data.
All Employees/Staff of W2 Global Data who operate AV Yourself who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
Document Owner and Approval
The Data Protection Officer is the owner of this document and is responsible for ensuring that this policy is reviewed in line with the review requirements of the GDPR.
Usage Requirements
Availability and Prominence
To ensure the availability of the Privacy Policy it will be published on the AV Yourself corporate website at https://avyourself.com/.
A hyperlink to the Privacy Policy will be included within text shown on the AV Yourself AV Service Landing Page which is displayed to the user before they commit to proceed with the use of the AV Yourself AV Service or provide any personal data to AV Yourself.
AV Yourself AV Service Landing Page
The AV Yourself landing page is the first AV Yourself website page that a user will see when they are referred to the AV Yourself AV Service by a Merchant. This landing page allows the user to: –
- Provide their mobile phone number; and
- Request that AV Yourself carries out age verification using that mobile phone number; and furthermore, this landing page;
- Provides clarity that the user is requesting AV Yourself to perform age verification; and
- Obtains agreement that their personal data may be used in accordance with AVYs terms; and
- Provides a link to AV Yourself AV Service Privacy Policy (which refers to the Terms where applicable); and
- Obtains acknowledgement that the mobile phone number entered will be transferred to AV Yourself for processing.
Action Statement
The action statement is displayed below the mobile number entry field but above the action buttons in black with a normal font size (c. 10pt). The standard action statement reads as follows:-
By clicking “Age Verify” below, you request us to verify your age and agree that we may process your personal information in accordance with our terms.
Note: that if the “Age Verify” button label is changed on the landing page, then the text in the action statement must also be amended accordingly.
Rider and Link
The rider is displayed below the mobile number entry and action buttons area, in dark grey and with a smaller font size (c. 7.5pt). The word “here” at the end of the footer text will always contains a hyperlink to https://avyourself.com/privacy-policy/and typically appear in blue and underlined (depending on the user’s browser settings).
The standard footer reads as follows:-
The Merchant ([Referring_Merchant_Brand]) referred you to us at AV Yourself, to undertake independent age verification. By clicking “Age Verify“ above, you acknowledge that your mobile phone number will be sent to us for processing. Learn more about our privacy practices here.
Where [Referring_Merchant_Brand] is substituted for the consumer facing brand name of the merchant that is contracted with AV Yourself, such as “AgeID” as illustrated in the example that follows.
Notethat if the “Age Verify” button label is changed on the landing page, then the text in the rider must also be amended accordingly.
Landing Page Example
Privacy Policy – Age Verification Service
Version 1.0, Last updated 17 June 2019
Introduction
- This Privacy Policy (together with our terms of use and any other documents referred to in it) explains what we do with your personal data, whether we are in the process of assisting you verify your age, providing you with a service, assisting you with your enquiry or dealing with a formal enquiry from a regulator.
- It describes how we collect, use and process personal data, and how, in doing so, we comply with our legal obligations.
- We respect your privacy and are committed to protecting it through our compliance with applicable privacy and data protection laws and regulations. Please read this privacy policy carefully to understand our policies and practices regarding your personal data and how we treat it. By using the AV Yourself Age Verification Service, you are accepting the practices described in this privacy policy.
- If you do not want your information to be processed as set out in this privacy policy, please do not provide any personal data to us and do not use our age verification service.
- It is important to note that we may amend this Privacy Policy from time to time. We review our Privacy Policy regularly, sooner if changes to regulation require or if we change the way we process personal information. We will post any updates to this Privacy Policy on our website at https://avyourself.com/privacy-policy/so please visit this page if you would like to stay up to date.
- If you have any questions about our privacy practices, please refer to the contact details at the end of this privacy policy.
Who Are We?
- The AV Yourself Age Verification Service (“AV Yourself AV Service”) is owned and operated by W2 Global Data Solutions Limited a company registered in England and Wales with Company No 7669978(“AV Yourself”, “we”, “us” or “our”). Our registered office is at W2 Global Data Solutions Limited, Clarence House, Clarence Place, Newport, NP19 7AA, UK.
- For the purposes of the UK Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679)) (“GDPR”), in respect of the AV Yourself AV Service, we are the data controller. We are responsible for the processing of any personal data you provide to us whilst using our services. W2 Global Data Solutions Limited is registered with the UK Information Commissioner’s Office under Registration No. Z2736945.
When This Privacy Policy Applies
- This Privacy Policy applies to personal information that we collect whilst you are using the AV Yourself AV Service and in any email and other communication between you and us.
- It does not apply to information collected by any other website or web-based service operated by us (or our group companies), any website operated by a third party including those operated by the merchant that referred you to the AV Yourself AV Service or any third party application or content (including advertising) that may link to or be accessible from the AV Yourself AV Service.
- Please check the privacy policies of any external site before submitting any personal data to them, as we cannot accept any responsibility or liability in relation to them.
Why does W2 Global Data Solutions Limited need to collect and store personal data for the AV Yourself Product?
- We collect information in order to provide an age verification service to merchants who operate websites, applications and businesses which are required to verify a person’s age before allowing them to a) access certain websites and/or certain types of content shown on websites, or b) purchase certain types of goods and/or services either via a website, an application or in person.
Personal Data we collect and how we collect it
- For us to provide our age verification services to you we need to collect limited personal data from you for identification and validation purposes. We cannot perform age verification without the personal data associated with the age verification method. In any event, we are committed to ensuring that the information we collect and use is kept to a minimum, is appropriate for this purpose and does not constitute an invasion of your privacy
- Data we collect directly from you via forms presented via the AV Yourself AV Service
| Age Verification Method | Personal Data Type | Source |
| UK Mobile Phone | Mobile Phone Number | You |
- Data collected automatically
- When you access our web-based services, we may also receive information automatically which relates to your computer, mobile device and internet connection, whether you decide to use our services or not. This includes your internet protocol address (“IP address”), your country of location, operating system, browser and platform type and access times. These are not actively utilised by the service and are only present in log file for technical operations and maintenance purposes. These log files are automatically deleted after 3 months.
- Our website uses cookies which are small files of letters and numbers that we put on your computer. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also helps us to improve our website We use analytical cookies which enable us to recognise and count the number of visitors and to see how visitors move around our website. This helps us to improve the way our website works. We currently use the following types of cookies.
| Cookie | Purpose | Type |
| PHP Session Cookie | Allows a user to be recognised within a website visit so that changes or data selection is remembered from page to page. | Session Cookie |
| Google Analytics | We use Google Analytics cookies which allows Google Inc. to collect information about how visitors use our site. We then use this information to help us improve our site.
The Google privacy policy is located at: https://www.google.co.uk/policies/privacy You can find out how to opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout |
Persistent Cookie Various Durations (max 2 Years) |
- You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
- Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit allaboutcookies.org.
Consent
- By consenting to this privacy policy, you are giving us permission to process your personal data specifically for the purposes identified. If you do not want your information to be processed as set out in this privacy policy, please do notprovide any personal data to us and do notuse our age verification service.
- Consent is required for the AV Yourself solution to process personal data, but it must be explicitly given. The AV Yourself solution does not collect or process sensitive personal data.
Will W2 Global Data Solutions Limited share my personal data with anyone else?
- We may pass your personal data on to third-party service providers contracted to W2 Global Data Solutions Limited in the course of providing our age verification services to you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide to us. When they no longer need your data to fulfil this service, they will dispose of the details in line with W2 Global Data Solution Limited’s procedures.
- We may disclose your personal data if we are required to do so by law, any applicable regulation or to protect the rights, property, or safety of ourselves or others.
- W2 Global Data Solutions Limited will not pass on your personal data to any other third parties. We do not pass the personal data you provide to us, back to the merchant whose website referred you to us. We only indicate the success or failure of the age verification process to the referring merchant.
How will W2 Global Data Solutions Limited use the personal data it collects about me?
- W2 Global Data Solutions Ltd will process (collect, store and use) the information you provide in a manner compatible with the UK Data Protection Act 2018 and the GDPR. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. W2 Global Data Solutions Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
- Where we undertake your Age Verification via your UK mobile phone number we will exchange Short Message Service (“SMS”) text messages with you via your mobile network. We will use the Mobile Network Operator’s content control status associated with your Mobile Station International Subscriber Directory Number (“MSISDN”) to determine successful age verification.
How long will AV Yourself Limited keep the personal data it collects about me?
- W2 Global Data Solutions Ltd will process personal data only for the time required to complete the age verification process and once this is complete we will store the personal data for a period of [two years years] in order to provide customer service, maintain an audit trail of age verifications and comply with our legal and regulatory requirements.
Under what circumstances will W2 Global Data Solutions Ltdcontact me?
- Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. We will not normally contact you once your age verification is complete. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Your Rights as a Data Subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our systems.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that W2 Global Data Solutions Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
If you would like to exercise any of these rights, details of how to contact our Data Protection Officer can be found at the end of this policy. In order to assist you with exercising these rights we will first need to confirm your identity. W2 Global Data Solutions Ltd will normally accept the same form of identity that you originally submitted for age verification.
How to Complain
W2 Global Data Solutions Ltd takes complaints very seriously and will respond to complaints within 30 days, this allows us time to investigate your complaint thoroughly. In the event that you wish to make a complaint about how your personal information is used by us please contact our Data Protection Officer.
Contact details
W2 Global Data Solutions Ltd, a company registered in the UK under company registration no: 7669978 is the Data Controller (ICO Data Protection Registration Number Z2736945).
Registered Office Address:
| W2 Global Data Solutions Limited, Clarence House, Clarence Place, Newport, NP19 7AA, United Kingdom |
| Email: [email protected] |
How to contact the UK Supervisory Authority
If you are not satisfied with our response or believe we are not processing your personal data in accordance with UK Data Protection Act 2018 and the requirements of the GDPR; you can complain directly to the UK Supervisory Authority.
| Customer Contact Information Commissioner’s Office Wycliffe House Water Lane Wilmslow SK9 5AF United Kingdom |
| Email: [email protected] |
| Web: www.ico.org.uk |
| Helpline: 0303 123 1113 |
Updated: 17/06/2019