Effective Date: 12.15.2022

Verisoul Inc., A USA Delaware Corporation

At Verisoul, Inc. (“Verisoul”) we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Verisoul's Services is at all times subject to our Terms and Conditions, which incorporates this Privacy Policy.

Privacy Policy Table of Contents

1. What this Privacy Policy Covers

2. Personal Data
   1. Categories of Personal Data We Collect
   2. Categories of Sources of Personal Data
   3. Our Commercial or Business Purposes for Collecting Personal Data

3. How We Share Your Personal Data

4. Information About Biometric Information We Collect

5. Tracking Tools and Opt-Out

6. Data Security and Retention

7. Personal Data of Children

8. Other State Law Privacy Rights

9. European Union and United Kingdom Data Subject Rights

10. Changes to this Privacy Policy

11. Contact Information

1) What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

2) Personal Data

Categories of Personal Data We Collect

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

• When you provide such information directly to us.
  • When you use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.

• When you use the Services and such information is collected automatically.
  • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
  • If you use a location-enabled browser, we may receive information about your location.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.

Public Records

• We collect transactional data associated with you from public blockchains.

Third Parties

• Vendors
  • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

• Social media networks
  • If you integrate your social media accounts with our service, we collect certain information from your social media accounts.

Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

• Providing you with the products, services or information you request.

• Meeting or fulfilling the reason you provided the information to us.

• Providing support and assistance for the Services.

• Improving the Services, including testing, research, internal analytics and product development.

• Personalizing the Services, website content and communications based on your preferences.

• Doing fraud protection, security and debugging.

• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

Marketing the Services

• Marketing and selling the Services.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Verisoul or the Services.

• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

• Protecting the rights, property or safety of you, Verisoul or another party.

• Enforcing any agreements with you.

• Responding to claims that any posting or other content violates third-party rights.

• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

3) How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers and analytics providers.

• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.

• Our Customers & Partners. Our Customers & Partners are the customers to which we provide our identity verification and fraud prevention services. These entities include companies (or other) with which you may have an account.

• Parties You Authorize, Access or Authenticate
  • Third parties you access through the services.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

4) Information about Biometric Information We Collect on Behalf of Our Customers

For more information, please read our Biometric Policy

Our Collection and Use of Biometric Information

We may collect biometric information about our customers’ end users in order to provide our identity verification and fraud prevention Services to our customers. Biometric information is a form of personal data based on an individual’s biometric identifier – such as an iris scan, fingerprint, voiceprint, hand geometry, or facial geometry – that is used to identify an individual. As used in this policy, “Biometric Information” refers to both “biometric information” and “biometric identifiers” as those terms are defined under applicable law. When providing our biometric verification services to our customers, we conduct a FaceScan to extract the end user’s FacePrint and capture a VoiceScan to extract the end user’s VoicePrint. The FaceScan and VoiceScan are transformed into a FacePrint and a VoicePrint, which are non-reversible vectors and contain no image or audio data. Only FacePrints and VoicePrints are stored. We use the unique FacePrint and VoicePrint to link the end user’s identity to any other accounts they may have with our other Customers. We do not use this biometric information for any other purposes than providing the identity verification and fraud prevention Services to our Customers. We may also use Biometric Information to comply with applicable legal obligations or comply with a request from law enforcement or government entities, unless prohibited by law.

How We Share Biometric Information

Note that we never sell or rent Biometric Information. We may use service providers to process and store Biometric Information. We may also share your Biometric Information with third parties where permitted to enforce our terms of use, comply with legal obligations, or cooperate with law enforcement agencies where required by law.

How We Secure Biometric Information

We seek to protect your Biometric Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures. We endeavor to protect Biometric Information in the same or more protective manner than the manner in which we store, transmit or protect other confidential and sensitive information. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Our Retention of Biometric Information

Unless otherwise required by contract with our customer or to comply with a legal obligation, Verisoul will retain biometric data until the earlier of the following: (1) the identity verification purposes for the collection have been satisfied; or (2) three years from your last interaction with our Services.

Questions about Your Biometric Information

If you have any questions about the collection and use of your Biometric Information, please contact us at support@verisoul.xyz.

5) Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

6) Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

7) Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16  years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at support@verisoul.xyz.

8) State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@verisoul.xyz

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@verisoul.xyz with the subject line “Nevada Do Not Sell Request” and providing us with your name. However, we do not sell Personal Data.

9) European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Verisoul will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@verisoul.xyz. Note that we may also process Personal Data of our customers’ end users in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity:  We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Legitimate Interest:  We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

• Profile or Contact Data

• Identifiers

• Commercial Data

• Online Identifiers

• Device/IP Data

• Web Analytics

• Social Network Data

• Demographic Data

• Geolocation Data

• Inferences Drawn from Other Personal Data Collected

• Other Identifying Information that You Choose to Provide

• We may also de-identify or anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above):

• Providing, customizing and improving the Services.

• Marketing the Services.

• Corresponding with you.

• Meeting legal requirements and enforcing legal terms.

• Completing corporate transactions.

Consent:  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU and UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@verisoul.xyz Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

• Erasure: You can request that we erase some or all of your Personal Data from our systems.

• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

• Right to File Complaint: You have the right to lodge a complaint about Verisoul's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Verisoul and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Verisoul in the U.S. and will be hosted on U.S. servers.

10) Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Verisoul website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

11) Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• +1 (925) 666-3012

• https://verisoul.xyz

• support@verisoul.xyz

Address

1401 Lavaca St. #989

Austin TX, 78701 USA