App User Privacy Notice
Data that we hold and how we use it
As an app user, we do not act as the Controller for the messages between you and the Provider. We are the Controller of your registration data for the App itself, any log data and then your Nivo Identity if you have set one up. Your Nivo identity will include the results of your ID&V check, if you have agreed to share it with us for future use with a new provider. When you attempt to start a conversation with a provider on Nivo, you will be asked to consent to share your Nivo identity information. If you choose to consent that identity will be shared with the provider. If you use our Digital Assistant channel then we will process your any conversation that you have with the Digital Assistant, along with a conversation ID that we can link to your Nivo identity. This conversation is processed by OpenAI, but only the conversation ID is sent to them, they do not have any other identifying data for you. We recommend that you do not put personal information in the question box.
Lawful basis for processing
Our lawful basis for processing your data is a combination of Contract, Consent and Legitimate Interest. We use Contract as a lawful basis for the data you provided when you downloaded and registered yourself as a user on the App. If you create a Nivo ID and add the results of an ID&V check, we ask your consent to transfer that from your provider to us. Once transferred, we process it under contract and legitimate interest, depending on the process. We use consent if we process any of the biometric data from your ID&V check. We use legitimate interest when processing your data through the DigitalAssistant.
Data Sharing and Transfers
Like most companies, we use a number of other companies as part of our data processing, for example cloud services and technology services. We have Data Processing Agreements in place with these providers. Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example Standard Contractual Clauses. We do not sell your data to anybody. As part of the service we offer you, with your consent, and only upon your instruction, we transfer your Nivo Identity to new providers.
We hold data on our app users for the time of which you are an active user and then for 7 years afterwards in case of any dispute. This is to ensure that our customers continue to have an auditable record of the identity information which may be required for them under the laws and regulations they operate. It will also ensure that you can continue to easily communicate and transact with other providers on the Nivo network.