This Privacy Policy describes how Caluu Holdings Inc, doing business as SourceID,  (collectively, “SourceID,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. You can jump to particular topics by going to the headings below:Information We Collect
How We Use Information.
How We Share Information.
Your Choices
How We Protect and Retain Information
Transmission Of Information To Other Countries
Third-Party Applications/Websites
Changes To This Privacy Policy
Contact InformationInformation We Collect
We collect information about you in a variety of ways depending on how you interact with us and our websites, and mobile apps, and other services, including:
• Directly from you when you provide it to us, such as when you upload or input your identification verifying information,, sign up to receive communications from us, make a purchase, or contact us by phone, email, or otherwise.
• Automatically through the use of, server logs, and other similar technologies when you interact with our websites, apps, advertisements, and emails.
• From other sources, including, for example, our affiliates, business partners, service providers, references you provide, online social media networks, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.
Context
Types of Personal Information
Primary Purpose and Legal Basis for Collection 
and Use of Personal Information
Account Registration
We collect your name, contact information, and other identification data when you create an account. This includes the information you upload, such as your address and identification card. We also collect information relating to the actions that you perform while logged into your account, such as when you take your verification photo.
We have a legitimate interest in providing account related functionalities to our users. Accounts can be used for our clients’ customers to prove their identities and by our clients to comply with identity verification
Biometric Identifiers
In some instances we collect biometric information to verify an individual’s identity. The identifier we use is a face scan, which is taken from the 3D Liveness selfie uploaded by an individual.
We have a legitimate interest in providing identity verification services, which can include through the use of biometrics. Users consent to the processing of their facial scan when they begin the identity verification process.  
Client Information
We collect the name, and contact information, of our clients and their employees with whom we may interact. At the clients’ request, we also collect identifying information about individuals who engage with our clients when we perform identification verification services.
We have a legitimate interest in contacting our clients and communicating with them and their employees concerning normal business administration such as projects, services, and billing. We have a legitimate interest in collecting identifying information to deliver services to our clients about individuals. Additionally, individuals consent to the processing of the information related to their identification verification.
Your Use of Our Website  
We use technology to monitor how you interact with our websites. Other types of data we track include your IP address, the website that referred you to our website, and data about the device you use to visit our website.
We have a legitimate interest in making our website operate efficiently. We also use it to understand how you interact with our websites to improve them and understand your preferences.  Finally, we use this information to help detect and prevent fraud.Demographic Information
We collect personal information, such as your age or location.
We have a legitimate interest in collecting identifying information to provide identity verification services. Additionally, individuals consent to the processing of the information related to their identification verification.
Location Information
When you engage with our services, we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from certain venues.
We have a legitimate interest in correctly verifying the identity of individuals, which includes detecting anomalies in their profiles, such as impossible locations or locations that do not align with the contact information provided as part of the identity verification process.
Email Interconnectivity
If you receive email from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.
We have a legitimate interest in understanding how you interact with our communications to you.
Employment
If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your government identification. Providing this information is required for employment. We also collect information about individuals’ employment as part of our identity verification services
We use information about current employees to perform our obligations to employees. In some contexts, we are also required by law to collect information about employees or applicants. We also have a legitimate interest in using your information to have efficient staffing and work force operations. For individuals who upload employment information as part of the identity verification services, we process this information with their consent and for our legitimate interest in providing identity verification services.
Feedback/Support
If you provide us feedback or contact us for support, we will collect your name and email address, as well as any other content that you send to us, in order to reply.
We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mobile Devices
We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or using our app.
We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Whistleblower email
We may maintain a whistleblower email, operated by us or by a third party. We collect the personal information that individuals who utilize that communication channel provide.  This may include in some cases their contact information, or information that may relate to other individuals or employees. Note that if you provide your contact information we may not be able to keep it confidential in all instances.
We have a legitimate interest in allowing our employees to communicate  with us regarding issues that might violate our policies or procedures.  In certain situations, we may need to disclose the information that an employee provides.  When that occurs, the disclosure may be based depending on the situation on their consent, our compliance with laws that mandate disclosure, our legitimate business interest in administering our business, or protecting an individual that may be at risk of injury.How We Use Information.
In addition to the purposes and uses described above, we use information in the following ways:
• To identify you.
• To provide products and services.
• To improve, or create, our services and product offerings.
• To conduct analytics.
• To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
• To send marketing and promotional materials including information relating to our products or services.
• To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
• To debug, identify and repair errors that impair existing intended functionality of our website and services.
• To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
• For internal administrative purposes, as well as to manage our relationships.
• For such other purposes as you may consent (from time to time).
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
How We Share Information.
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:
• Business Customers. We may share information with our business customers where we are retained to provide or perform services on their behalf. For more information about how those customers process your personal data, please visit their websites or request a privacy notice governing their processing activities. If individuals choose to re-use their uploaded information and verification status with additional SourceID business customers, individuals may have the opportunity to do so through the mobile app, which indicates their consent to this instance of sharing.
• Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
• Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
• Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of identity verification services.
• Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.
Your Choices
Some jurisdictions give you a right to make the following choices regarding your personal information:
• Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
• Changes To Your Personal Information. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law. If elements of the information you have provided to us change, such as your address or employment, you may update this information directly.
• Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
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• Objection to or Restriction of Certain Processing. In certain circumstances, you may object to the processing of your personal information, or request that we restrict processing of your personal information, by following the instructions described below.
• Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
• Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
• Revocation Of Consent. Where we process your personal information based upon consent, you may revoke consent. Please note, if you revoke your consent for the processing of personal information then we may no longer be able to provide you services.
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.
Submitting Requests
You may exercise the rights described above by logging into your account and contacting us there, or by contacting us as indicated in the “Contact Information” section below.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such the date of your last contact with us or elements of the identification information you shared with us when using our services. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
How We Protect and Retain Information
No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.
Automated Decisions Using Your Information
SourceID engages Artificial Intelligence (AI) to provide identity verification services. Initial phases of the identity verification process use AI to analyze your data, however there is human intervention before decisions are made using this information.  The results of these decisions are shared with our clients and may lead to legal consequences.
Transmission Of Information To Other Countries
As a multi-national company, we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.
Third-Party Applications/Websites
For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.
Changes To This Privacy Policy
We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified. If we make a material change to our privacy notice, we will attempt to notify you through email or through a website pop-up.
Contact Information
If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
[INSERT EMAIL CONTACT]
[INSERT MAIL CONTACT]
[INSERT TOLL FREE PHONE CONTACT]
If you are not satisfied with our response and you live in Nigeria, you may have a right to contact your data protection authority, Nigeria’s Data Protection Commission. If you live in Ghana and are not satisfied with our response, you may have a right to contact your data protection authority, Ghana’s Data Protection Commission. Effective Date: July 13, 2024