SUMSUB APPLICATION CONSENT TO PROCESS PERSONAL INFORMATION
As you have notified us that you reside in mainland China, under Article 39 of the Personal Information Protection Law of the People’s Republic of China 2021 (PIPL) we are obligated to separately inform you of the following and collect your explicit consent before your personal information can be accessed or shared outside China.
Who will receive your personal 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. Contact email: privacy@sumsub.com
1. Sumsub will collect and process your personal information on 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.
2. Sumsub processes your personal information under Unite Students' explicit instructions. Unite Students remains the controller for and is responsible for your personal data under UK data protection law.
3. What personal information this covers:
a. 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).
b. Identity document data: Document type, issuing country, number, expiry date, MRZ, information embedded into document barcodes (may vary depending on the document), security features.
c. 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.
d. Biometrical data: Facial recognition.
e. Contact details: Address, e-mail address, and phone number.
f. 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.
g. Geolocation data: IP address.
h. 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.
i. Sensitive personal information: The personal information this consent statement covers, as per the above, includes biometric data (facial recognition), which constitute sensitive personal information under the PIPL. It may also include relevant information about criminal history, if we obtain this data in the course of carrying out verification checks. The collection and processing of this sensitive personal information is strictly necessary for the purpose of completing your identity verification, as the verification process requires biometric matching of your facial image against your identity document to confirm your identity. This sensitive personal information will not be used for any other purpose.
4. Why your personal information is processed outside of China and how it is processed:
Sumsub will undertake the identity verification process on behalf of Unite Students. Sumsub is a company registered in England and Wales; however, its processing infrastructure is located in Germany. Your personal information is collected via the Sumsub application, transmitted to and processed on Sumsub's systems located within Germany, with no counterpart located within mainland China. The method of processing includes the automated collection, storage, comparison, analysis and deletion of your personal information for the purpose of verifying your identity.
5. How your personal information is protected once it's outside China:
Your personal information is processed by Sumsub on behalf of Unite Students under data processing agreements. Sumsub is contractually required to protect your personal information to the standard required under UK data protection law, to process it only on Unite Students' instructions, and to use it only for the purpose described above. Where Sumsub itself transfers personal information between its own group companies outside the UK and European Union, it does so by relying on European Commission adequacy decisions, Standard Contractual Clauses, or other safeguards recognised under the UK GDPR.
6. Your rights regarding overseas processing:
Under the PIPL, you have the right to access, correct, and delete the personal information that Sumsub holds on Unite Students' behalf, and to request information on how your personal information has been used. You may exercise these rights against the overseas recipient, Sumsub, by contacting them at the contact details mentioned in section 1 above, [or by contacting Unite Students at dataportection@unitestudents.com who will coordinate with Sumsub on your behalf.
You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of any processing already undertaken prior to such withdrawal or any existing agreements, but will mean that Unite Students will be unable to complete the identity verification step.
7. 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 personal information into Sumsub, and Unite Students won't be able to complete your identity verification.
8. Data retention:
Your personal information will be retained only for as long as is necessary to fulfil the purpose of identity verification as described in this notice. Upon expiry of the retention period, or upon your request for deletion (subject to any overriding legal obligation to retain), your personal information will be securely deleted.
I have read the terms above. By proceeding I understand and give my explicit consent for my personal data to be collected, processed, and stored 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.