Fragomen ("we") aim to ensure that any affected data subjects ("you") are informed about the security and use of the personal information that we receive from you. We are committed to continual improvement of our privacy program, standards and compliance, both locally and globally. Accordingly, this Privacy Notice (“Privacy Notice”) is intended to inform you about Fragomen’s privacy practices for the Fragomen Wallet. It describes the types of personal information we collect, how we may use that information, with whom it may be shared, and the measures taken to ensure its security. In addition, this Notice provides information on how to contact us to: (1) exercise your right to object to the processing of certain aspects of your personal information in accordance with applicable laws; (2) access, correct, or delete your personal information; (3) ask any questions you may have about our privacy practices.
Fragomen Wallet enables you to upload different types of documents (e.g. driving license, passport, academic transcript), which will be stored in the Fragomen Wallet app on your phone as pictures. The documents you’ve uploaded will then be verified and transformed into standardized digital certificates, which we call “verifiable credentials”. To set up your account in the Fragomen Wallet, we first capture and verify your government-issued ID document. This process involves comparing a picture of your ID document with a live selfie that you will be asked to take during the app onboarding. We are using Regula Forensics software to complete the identity verification. The issuance process for verifiable credentials is facilitated using walt.id software, integrated into our main Fragomen Wallet platform. While only transactional metadata is permanently retained in the platform, selected personal data attributes are temporarily stored on the platform to enable app onboarding (see the list below). The documents, and all personal data associated with these documents, that are uploaded to the app remain and are stored on your phone and are therefore in your control, should you wish to edit or delete them. The following Personal Information may be processed as a result of the type of documents you upload to Fragomen Wallet:
The following personal data will be temporarily stored in our backend platform, and will be purged in 24 hours after the onboarding process completion:
The data controllers of your personal information, stored on our backend platform, are Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and the Fragomen office providing the services to you, as well as your employer (current or potential), where applicable.
As noted under Personal Information We Collect About You we process the sensitive personal information you upload to the Fragomen Wallet, e.g. the picture of your passport, which will then be converted into a standardized digital certificate. As part of the identity and verification process, Fragomen Wallet will require you to take a live selfie which will be compared against your passport picture (or any other identity document) to validate your identity and generate a verifiable credential. The selfie will be captured directly in the Fragomen Wallet app, which includes a detection module to analyze images and recognize faces. This verification step is critical to validate it is a real person accessing the camera, and match the selfie against the provided document image, e.g. passport picture. Once the identity verification process is complete, which may take from a few seconds to a few hours in case of manual verification required, your live selfie and passport picture are deleted from our backend systems. We don’t share your face data, i.e. live selfie, with any third party. Personal Information and documents stored in the Fragomen Wallet app are protected by security controls, including user identification when accessing the app, and can only be accessed by Fragomen upon receipt of your explicit consent to share your data with us.
Fragomen relies on the following legal basis when processing your personal information and sensitive personal information:
We will not sell, share, transfer, rent, use, or distribute your information for purposes other than those disclosed here as authorized by you. We share the information you upload to Fragomen Wallet with your consent. Fragomen Wallet utilizes Regula Forensics, which is a third-party technology vendor integrated with Fragomen Wallet and hosted within the Accenture environment, meaning it operates entirely within the controlled infrastructure of the Fragomen Wallet and does not have external dependencies. Regula's primary function is to scan and extract data from physical identity documents, such as passports, national ID cards, and driver’s licenses, and perform facial biometric verification. The extracted and validated data is passed to subsequent components in the Fragomen Wallet (for instance walt.id ) for processing and digital verifiable credential creation and issuance. walt.id, similarly to Regula, is a third-party technology vendor integrated with Fragomen Wallet and hosted within the Accenture environment.
We seek to ensure that any personal information that we hold about you is accurate, complete, current and otherwise reliable based on data you upload to make use of the Fragomen Wallet service. We seek to collect only personal information that is adequate, relevant and not excessive for these purposes. We maintain appropriate administrative, technical, organizational, and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of personal information. We educate our employees and strive to maintain appropriate standards of conduct with regard to the protection of personal information. We take steps to require that third parties who assist in our provision of services abide by all applicable privacy and data protection laws and prohibit them from using your information other than in connection with the services they have been engaged to provide. We delete your personal information from our backend systems once identity check and onboarding processes are complete, we permanently store only transactional metadata. You are also free to delete the documents that you have previously uploaded to the Fragomen Wallet.
We do not transfer your information to any third parties, all data processing happens on Fragomen Wallet platform, hosted within Accenture environment.
As set out above, Fragomen may collect certain information about you in conjunction with providing Fragomen Wallet services. You may delete any documents that you have uploaded to the Fragomen Wallet. Additionally, should you wish to delete or deactivate your account you may do so by visiting the account management page in the Fragomen Wallet app. To help protect your privacy and the security of your information, Fragomen takes reasonable steps to verify your identity before granting access to information. Where we rely solely on your consent, you may withdraw it at any time. To exercise these rights, contact our data protection officer by email at dataprivacy@fragomen.com. If you have unresolved concerns, where provided by local law, you may have the right to complain to a data protection authority where you reside, where you work or where you believe there has been an infringement of data protection laws. Please note that when exercising your rights, Fragomen will request a copy of a government issued identification document in order to verify your identity. This is done in accordance with our obligations under data protection laws and to protect the personal information that we hold. We will only use this information for identity verification purposes, and we will delete it after your request has been responded to.
We store your live selfie and passport picture until the identity verification process is complete, which may take from a few seconds to a few hours in case of manual verification required, your live selfie and passport picture are then deleted from our backend systems. We temporarily store your first name, last name, date of birth, email address and unique personal identifier for 24 hours after the onboarding process completion. Personal information, documents and verifiable credentials in your Fragomen Wallet can be deleted by you at any time and we don’t have access to any of these data.
This Privacy Notice may be updated periodically without prior notice to you to reflect changes in our information practices. We will post a notice on our applicable websites or materials to advise of any significant changes to our Privacy Notice and indicate in the notice when it was most recently updated. In certain countries, additional or different procedures not inconsistent with this Privacy Notice may apply as necessary to satisfy local legal requirements.
The controllers of your personal information are Fragomen. Our representative in the European Union is Fragomen Ireland Limited, Riverside 4, Ground Floor, Central Quay, Sir John Rogerson’s Quay, Grand Canal Dock, Dublin, Republic of Ireland . If you have any questions or comments about this Privacy Notice directed at any of the data controllers listed above, please contact our data protection officer by email at dataprivacy@fragomen.com.
You also may write to us at:
Attn: Office of General Counsel
Fragomen, Del Rey, Bernsen & Loewy, LLP
90 Matawan Road
P.O. Box 2001
Matawan, New Jersey 07747 USA