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Identity verification PIPL consent statement

TO BE AGREED - SUMSUB APPLICATION CONSENT TO PROCESS PERSONAL INFORMATION

As you have notified us that you are in mainland China, under Article 39 of the Personal Information Protection Law of the People’s Republic of China (PIPL) we are obligated to separately inform you of the following and collect your explicit consent before your information can be accessed or shared outside China.

  1. Who will receive your information overseas Sum and Substance Ltd (Sumsub), a company registered in England and Wales, company number 09688671, located at 30 St Mary Axe, London, England, EC3A 8BF. Sumsub will collect and process your information on behalf the behalf of Unite Integrated Solutions (Unite Students), registered in England and Wales, company number 02402714, registered office 1st Floor Welcome Building, Avon Street, Bristol, United Kingdom, BS2 0PS and under Unite Students explicit instructions. Unite Students remains the controller for and is responsible for your personal data under UK data protection law.

  2. What information this covers:

    1. General Personal Data: Full name, sex, personal identification code or number, date of birth, legal capacity, nationality and citizenship, location (street, city, country, and postcode).

    2. Identity document data: Document type, issuing country, number, expiry date, MRZ, information embedded into document barcodes (may vary depending on the document), security features.

    3. Facial image data: Photos of the face (including selfie images) and photos or scans of the face on the identification document, videos, and sound recordings.

    4. Biometrical data: Facial .

    5. Contact details: Address, e-mail address, and phone number.

    6. Technical data: Information regarding the date, time, and activity in the Services; IP address and domain name; software and hardware attributes (e.g., camera name and type); general geographic location (e.g., city, country) from User’s device.

    7. Geolocation data: IP address.

    8. Device behavioural data & biometric recognition: User ID, biometric recognition including device fingerprint data (screen size, user agent, browser, incognito mode, type of device, operating system, geolocation), screen resolution, session languages, operating system verification, focus/blur of the window, time of the day, focus in/out, paste, mouse movement, battery usage to detect emulator, detect touch/mouse/keystroke events, G meter/AccelMeter.

  3. Why your personal data is processed outside of China Sumsub will undertake the identity verification process on behalf of Unite Students. The processing takes place on Sumsub's systems located within Germany, with no counterpart located within mainland China.

  4. How your information is protected once it's outside China. Your personal data is processed by Subsub on behalf of Unite Students under data processing agreements. Sumsub is contractually required to protect your information to the standard required under UK Data protection, to process it only on Unite Students' instructions, and to use it only for the purpose described above. Where Sumsub itself moves data between its own group companies outside the European Union, it does so by relying on European Commission adequacy decisions, Standard Contractual Clauses, or other safeguards recognised under the UK GDPR.

  5. Your rights regarding overseas processing You can ask Unite Students to access, correct, or delete the information Sumsub holds on Unite Students' behalf and ask how it's been used. Withdrawing won't affect anything already undertaken with your information or existing agreements, but will mean we can't complete this verification step.

  6. If you do not give consent Your consent is separate from and in addition to any general privacy notice, terms of service or agreements you have entered into. If you do not consent, you will be unable to continue entering your information into Sumsub, and Unite Students won't be able to complete your identity verification.

I have read the terms above. By proceeding I understand and give my explicit consent for my personal data to be collected, processed, and within the SumSub application for the purpose of completing an Identification and Verification check. I understand that my personal information will be shared with Unite Students and Sumsub, outside mainland China, for the purposes described in this notice.