KYC & Identity Verification Policy
This policy governs identity qualification processes used to protect accounts, transactions and signature workflows, following minimisation, proportionality and privacy-by-design principles.
1. Purpose and scope
Checks may be required to increase account assurance, prevent fraud, satisfy provider requirements or enable specific services. The verification level is proportionate to risk and the requested service.
2. Data minimisation
Firmato seeks to retain status, outcome, case reference, dates, provider and audit information. Copies of identity documents, selfies, video or biometric data are not routinely copied into Firmato storage unless specifically required.
3. Liveness and biometrics
Where liveness or facial comparison is used, biometric data may be processed. Such processing requires an appropriate legal basis, transparent information, enhanced safeguards and clear allocation of roles among UESE, the customer and the provider.
4. Outcomes and review
A case may be pending, in review, require information, be verified, rejected or expire. A negative result is not automatically evidence of fraud. Additional evidence or review may be requested where appropriate.
5. Relationship with electronic signatures
Account KYC and identification required by a trust provider are separate processes. Advanced or qualified signatures may require additional verification, certificates or OTPs.
6. Retention and rights
Data is retained for periods proportionate to purpose, law, security and dispute handling. Data subjects may exercise GDPR rights where applicable and contact the DPO or competent supervisory authority.
7. Providers and security
KYC flows may use secure API or redirect mechanisms. Depending on the service and contractual structure, the provider may act as processor or independent controller.
8. Versioning, precedence and evidence retention
Firmato records the version made available and, where the application flow provides for acceptance, the corresponding acceptance evidence including date, account and technical audit information. Material changes may require renewed acknowledgement or acceptance. Language and country are separate variables: language determines the linguistic version, while country determines the applicable national supplement.