Website privacy policy - Lloyds Bank Smart ID

You choose if you want to use the app to share your information with other individuals or with companies. You will get a receipt of any sharing you do. You must be aware that the third party companies you choose to share information with may be located overseas. 

Where we have access to your information, we may share it in specific circumstances, such as:

• suspected or confirmed identity fraud or other offences;
• valid and legally binding requests for information from third parties;
• to verify your details;
• where a company you are sharing details with requests further checks with third parties that we are able to provide.

We do not sell your information.

While we verify your account, for a short period of time after you sign up or add information, your account will be pending and Yoti will be able to access your personal information. Usually this is only for 28 days, but we will continue to store it and access it where we suspect or find fraud or other unlawful activity.

You can choose when to share your information, and with whom. There are some situations where we will share or will have to share some information with third parties, and we list these below. Yoti’s core principles are that it is not our business model to sell, transfer or share outside the company any of the personal information used to set up your account or your user activity information.

The Lloyds Bank Smart ID allows you to share information with another organisation. The app is your secure digital ID. It’s a safe place to store your personal details, encrypted so only you can access them. When you need to prove your age, identity or other details about yourself, you can securely share just the details required without revealing everything about yourself.

You alone will decide when you want to use your app to identify yourself to a third party, or to swap, send and request information. You choose whether to agree or not to share the information the third party requests. If you decide to share your information with a third party, you will both receive a receipt which will contain a copy of the information that each party shared. 

Yoti encourages companies to only ask for the information they actually need, for example, your age, or confirming you are over 18, rather than a full date of birth. If you choose to share your information with a third party using the app, those third parties may choose to use that information to communicate with you or they may share that information with others. We suggest you read the privacy policies of any third party company you share your information with to understand how they will use your personal information.  You must be aware that the third party companies you choose to share information with may be located overseas. 

Share receipts 

The app creates and encrypts a master receipt which contains the details of what information was shared and who with. This master receipt is securely stored on our servers and we cannot access it unless either you or the third party provides us with their own receipt containing the encryption key we need to access the information.

You can access your sharing receipts in the app, and also by logging into Hub: https://hub.yoti.com 

Please see the Hub product section for relevant privacy information.

Third party companies using the app can request the source of the information they request from you, such as ‘passport’, ‘driving licence’ or ‘unverified’. This is because some third party companies carrying out some types of identity checks are required to evidence where they got the details from. 

Remember Me IDs

When you allow a share with a third party company, the app generates two unique Remember Me IDs. One is for the specific service you are using, and one is for the third party company that owns that service. It means you don’t have to share your personal details every time, as the third party company or service can just ask for your Remember Me ID instead. The service and any other services owned by the same third party company will already have your personal details if you have shared them using the app in the past.

For example, if you use the app to prove your identity with service 1 offered by Company ABC, that share will contain one ID for service 1 and a different ID for Company ABC. If you then use the app to prove your identity with service 2 offered by Company ABC, that share will contain the same Company ABC ID and a different ID for service 2. Yoti has no access to these IDs.

The service or third party company can choose to store these IDs along with the personal information they request from you. If they store it, they can use this ID to recognise your app when you share with them again, so you can use different services or features without having to keep sharing the same information for each interaction. 

For example, if you sign up with a site using the app the website can use the ID to allow you to log in to the site, prove your age, carry out ‘know your customer’ due diligence and so on. It does all this by only asking for any required additional details, rather than asking you for all your details again. This approach is in line with Yoti’s data minimisation approach, meaning you should only share the details relevant to what you are doing. 

If a third party company or service you are sharing information with uses the ID and you do not want them to do this, you should contact them to delete your account with them. The IDs are unique to your app account, so if you delete your app account you will lose your IDs. If you then set up a new app account you will have new IDs which will not be recognised by any third party company or service you previously used with your old app account.

If you allow a share with another individual there will only be one Remember Me ID.

Always allow

We provide a feature to some companies, for some scenarios, where you can choose to automatically share the same information each time you interact with them. Usually, you scan a QR code to see what information the company is asking for, and you are asked whether you want to allow the sharing of your information. With ‘Always allow’ you can cut out the approval step. This may be useful to save time for some transactions you carry out often, where the same information is requested from you each time. 

The information you provide is stored separately and encrypted in secure locations. Once your account is set up, we have no access to your information. Only you have access to use the app to share your information as you choose. 

We continually test our systems to ensure that we are compliant and to ensure that we follow top industry standards for information security. Several times a year external audits are carried out on us to check that our security arrangements are compliant. These auditors follow internationally recognised standards for best practice in security, these are known as ISO  27001 and SOC2.

Except for the biometric template and photos, as mentioned in the ‘Information collection and use’ section, we do not have access to your personal information that we have verified and stored on our servers. The only way we can access the information is if you provide us with the encryption key (which is a set of unique numbers stored securely on your device). Only you hold the keys to decrypt your account information.

We keep all the personal information you add to your app account in the UK in highly secure datacentres. All the information is held separately and encrypted. 

We have a Security Centre in India who carry out fraud prevention checks when you set up your app account. The personal information is not stored outside of the UK, the data is actually stored in our UK based data centre. However the India Security Centre have secure remote access to carry out their role and therefore your data may be viewed by our staff in India. We have standard contractual clauses and the UK Addendum  in place between Yoti UK and Yoti India. 

Where we use ‘Aristotle Integrity’ service to verify your address, this data will be processed in the US. We have standard contractual clauses for this transfer.

If we decide or are obliged to send or store your personal information in another country, we will update this section to describe the protections we have put in place.

To opt out of Biometrics being used for research and development you can go to the app > More > My data > Biometric consent. Biometrics are your unique features, such as your face. We use biometrics in our app to help prevent fraud and to make sure it’s actually you using the app. The app is a biometric identity app, so you can’t use the app without this extra security.  We also use some of your data in our internal research and development (research and development). For some projects this could include data that is considered your biometrics. You can opt out of this in the app settings the app > More > My data > Biometric consent.  When you set up an app account we ask you to consent to our use of your biometrics. You can withdraw this consent at any time in the app settings. You can opt out of research and development data use, which will allow you to continue to use the app.

Please refer to our definition on biometrics if you would like a high level definition of what they are.

Legally, biometrics is defined differently in different laws, but the common factor is that you are identified or authenticated through your unique physical characteristics or behaviour. Not all of the app uses this data to identify or authenticate you. However, to make things easier to understand, we have called all the physical characteristics and behaviour data in our privacy notice ‘biometrics’.

The app is a biometric identity app. It works by allowing you to set up a trusted, genuine and verified digital identity. The biometrics are a key part of making sure we keep out fake identities and documents. The biometrics also make sure that it really is you taking actions in the app. 

Essentially, our use of biometrics to identify or authenticate you is to prevent fraudulent use of the app and protect your data. 

We also use some user data for internal research and development, which is explained under the ‘Internal research and development’ heading. 

Face

When you set up your account we take a scan of your face to create a biometric template of your face, which we store securely. A biometric template is a digital map of your face. 

When you take certain actions in the app and we need to check if it’s really you we will ask you to take a photo or take another video and compare it against the template to check it matches. We also check that the image is of a real person. These checks make sure that only you can take these actions. We usually ask for these checks when you want to take an action that would have a negative impact on you if it wasn’t really you. For example, changing your PIN or deleting your account.  

You can also add an ID document to the app so that you can share verified identity details like your name, address and date of birth. When you add a document we compare its photo with the face template to make sure users only upload their own documents, and we check the image is of a real person.

Checking you’re a real person

When you set up your account, add an ID document or take other actions in the app that need extra security, we need to make sure that it’s really you and not someone pretending to be you. We use different technologies for these checks. Some ask you to take an action, such as moving the phone towards your face or recording a short video of yourself saying a few words. Some happen in the background automatically. We use the information from these checks to make sure you are a real person. We can’t give you any more details about how this works, as we don’t want people to be able to get round our checks. 

Different ways we use biometrics: 

• Some data might involve your face or elements of your face, but without identifying you. For example, we have developed technology to check if a face presented to the app is real, or if it is someone wearing a mask. This activity doesn’t identify you in any way, it checks the image is genuine.
• Each time you need to prove that you are really you, your live face scan (see “key definitions” section) is compared against a biometric template associated with your account to see if it matches. 
• A biometric template is a snapshot of your physical or behavioral attributes. This image then becomes a master profile-and it is from this, that the unique features of your physical or behavioral attributes are extracted, and then converted into a mathematical file. This file can be anything from a binary mathematical file to a statistical model. It is these mathematical files which become known as the Biometric Templates-not the images which were extracted and created.

For example, many smartphones allow access using a fingerprint or your face, instead of a PIN. To use your fingerprint or face you first need to provide it to your phone so it can create a template. Then every time you use your fingerprint or face to access the phone it compares it to the template and only lets you in when the fingerprints or face match. This prevents someone else from accessing your phone. 

Apps like the Lloyds Bank Smart ID can use the phone’s fingerprint or face technology so you can also log in to our app using your fingerprint or face instead of your PIN. We don’t collect or store your fingerprint or face to do this.

Instead of having to remember PIN numbers, or usernames and passwords (which may be guessed or hacked), biometrics uses something unique to you that only you have, like your face or fingerprint. Many companies, such as banks, are using biometrics like voice recognition to make sure only you can access your account.

As well as preventing fraud in your everyday use of the app, we need to make sure our security checks continue to work and that we constantly improve them so we stay ahead of fraudsters and others who might try to provide fake identities or might try to get into your account. 

We have an internal research and development team who are constantly testing new ways to prevent fraud, and to do their job they need real data from real people. 

When you set up your app account and add an ID document we collect certain data for research and development purposes. We can’t provide too much detail of exactly what we collect and exactly how research and development use different data, as we don’t want people to be able to get round our security and fraud checks. However, all research and development have are things like the country code of your mobile number (example: +44 = UK), photos, or sections of the video or phone movement measurements. The country information helps us for things like selecting relevant and representative data and understanding anomalies, issues and inconsistencies in results.

To test and develop our liveness technology we analyse selfies you take in the app, such as when you take a new account photo and when you’re asked to take a photo for security purposes to verify it’s really you, and we take still images from the three word liveness videos you may do.

To test and improve our age-estimation technology the research and development team need images of faces and the verified age of that face. So they use photos you take in the app and still images from the video. For the verified age they use the month and year of birth from the ID document you add that contains this information. They also get gender if that is on the ID document as well as the document type and country of issue. This is used to prevent bias and improve the accuracy of our technology as set out below. 

Our age-estimation technology is an app feature so you can have an estimated age to share with others, before you add or instead of adding an ID document (that has a verified date of birth on it). We also offer our age-estimation technology to some third party companies who need to check ages. For example, when buying age-restricted products or to view age-appropriate content online. We have published and regularly update a white paper on our age-estimation technology, available on our website.

We currently use third-party technology to do a face match between photos you take with the photo on your ID document to make sure you only upload your own documents. We are developing our own technology to do this face matching which we will also be able to offer to other third party companies. To develop, test and improve this technology research and development need both photos you take in the app and a cropped high-quality image from your ID document. They do not have any other information about you.  

Tackling accuracy, bias and duplicate data

Research and development follow accepted research good practice and tag some image data with information on gender or skin tone or other features. Having these tags makes sure our research data is balanced and representative. This is an important part of making sure our research results are free from bias and our technology works for everyone. It also means we can accurately report on how well it works for different groups of people. Having month and year of birth for age-estimation technology also improves accuracy compared to only having the year of birth.

One of the other challenges for research and development is duplicate information, for example, when users delete their accounts and set up another one. To detect and eliminate duplicate data research and development receive a hashed version of your mobile number. The hashing means the number is represented as a string of letters and numbers so research and development never see your actual number and have no way to find it out. This allows research and development to determine if this string of letters and numbers already exists in their database so they can detect and eliminate duplicate data.

Can your research and development team identify me?

The research and development team doesn’t have any other information about you. They can’t see how you have used the app and who you have shared your identity with, which is stored separately and encrypted in our main database. 

We keep information used for research and development purposes on a separate research and development server, with strict access controls, for as long as it is relevant to the specific project.  

We do not use data from US citizens in our research and development work.

We hope you understand why biometrics are an essential security part of our app, but if you change your mind you can withdraw your agreement at any time by deleting your account in the app settings. You can do this by going to the app > More > Settings > Delete my account. 

There isn’t a non-biometric version of the app, so without biometrics the app just doesn’t work. 

You can opt out of having your data used for research and development purposes in the app settings by going to the app > More > My data > Biometric consent. This will allow you to continue to use the app which will include the essential biometric security features. Opting out means that your data will no longer be sent to research and development and any data we already have that is available for research and development to use will be deleted. Please note that if your data has already been used to train or develop a model or machine learning algorithm, it is not possible to extract your data from that model. 

• You can see all the information we hold on you in the app
• If you need to update information you can do so. 
• You can opt out of certain analytics in the app. 
• If you want to delete your information, you must use the ‘delete account’ option in the app. If you just delete the app then the link to your information is lost and it will remain in our system with no way to find it.

Please click the link below for information on which rights apply to the app personal information. 

For the purposes of the California Consumer Protection Act, we do not sell your data.

Please send any rights requests to: privacy@yoti.com

You are entitled to know what personal information we hold about you and to receive a copy of it.

We do not have access to your personal information that we have verified and stored on our servers. The only way we can access the information is if you provide us with the encryption key (which is a set of unique numbers stored securely on your device). Only you hold the keys to decrypt your account information.

You can access all the personal information in your account through your app. You can get a copy of this information by using the export data function in the app settings. You can also see your sharing receipts by logging into Hub. You can get a copy by taking a screenshot or by using your browser’s ‘Save as’ function, and third party companies can download their copies of share receipts.

If you have contacted our Customer Support or had other contact with us leading to us holding information on you, you can make an access request to: privacy@yoti.com 

When you use your app, we collect some information about your phone and how you are using the app. This information is collected and stored automatically through in-house and third-party tools, as set out in the ‘Analytics’ section.

We get Advertising IDs from Adjust along with event information such as ‘installed app’, ‘completed sign up’ and so on. If you want to access this information about your device, you will need to provide us with the Advertising ID from your phone, as that is the only way we can search for the information. 

The information we collect is de-identified and combined together (aggregated) and it is not possible to search or get the information using your name or your phone’s identifiers (for example, the IMEI number which is like a serial number for your phone). So we cannot provide you with this information as it is not linked to you specifically.

You are entitled to correct personal information we hold about you that is inaccurate.

If you think that any of the information in your app account is not accurate, you can take steps to correct it. You can manually add an address, archive old addresses and change your email. You can also simply replace an outdated ID document. You can also delete your account and set up a new one. Yoti only has access to the information in your account for up to 28 days after it is first provided to Yoti. 

If you change your name, you can currently only update your app account by adding a document with the new name.

If you have contacted our Customer Support or had other contact with us and want to make a correction request, please email: privacy@yoti.com

In certain circumstances you are entitled to ask us to delete the personal information we hold about you.

Please see the ‘Updating your information’ section under the ‘Information collection and use: Adding information to your app’ heading for more information on archiving documents or replacing your details with new ones. 

If you want to close your account and delete your information, you can do so from within the app. You may also find these FAQs helpful (in English only): https://yoti.my.site.com/lloydsbanksupport/

If you have any other deletion request, please email: privacy@yoti.com 

In certain circumstances you are entitled to object to Yoti processing your personal information. 

Based on how this right works, and the choices you have in the app settings (such as to withdraw consent to biometrics, delete data or the app, or to turn off analytics), there are unlikely to be any other circumstances when this right applies. If you want to contact us about your objection rights, please email: privacy@yoti.com

In certain circumstances you are entitled to ask us to restrict our processing of your personal information.

You can ask us to do this if: 

• you dispute the accuracy of your personal information; 
• our processing of your personal information is unlawful but you prefer restriction to deletion;
• we no longer need the information but you need it for legal reasons; or
• you have objected to our processing and we are still dealing with this objection.

If you want to contact us about your restriction rights, please email: privacy@yoti.com

In certain circumstances you are entitled to receive the personal information you have provided us in a structured, commonly used and machine-readable format.

This right is most likely to apply to information you have provided:

• to set up and use your app; 
• so we can respond to you; or
• so we can deliver the app features you want to use.

You can download the personal information you have added to your app account from the app settings.

If you have contacted our Customer Support or had other contact with us and want to make a portability request, please email: privacy@yoti.com

You can also complain to your local privacy regulator. 

As a UK company, we are regulated by the UK Information Commissioner’s Office (ICO) who is responsible for making sure that companies comply with the law on handling personal information. https://ico.org.uk/global/contact-us/

You can use this form to make a complaint about the handling of your personal information by an Australian Government agency or a private sector organisation.

Understanding how people use our app is essential. We need to know what’s working, and what isn’t, so we can improve. As a business, we need to know how many people are using our app, where they are in the world, and which features are most popular.

We collect information about your device and your use of the app using in-house and third-party analytics. We de-identify the information we collect so we can’t identify you personally. We also combine information so that no analytics report is ever about an individual user. Unlike most other companies, we don’t build individual profiles of the people who use our app. We simply look for trends and patterns to inform business decisions. 

You can opt out of certain analytics in the Lloyds Bank Smart ID > More > Settings > Account settings > Analytics. Some information is generated automatically when you use our products, and we can’t turn this off. 

See the Analytics section in our general privacy information page for information on what analytics are, why we use them, and your choices.  

Adjust is a third party company that we use for our app. We use Adjust performance and analysis technology in our app. This allows us to us to track and analyse which marketing channels or sources, and which adverts, are producing the best results in directing users to download the app, and to help us understand how our users are using our app.  Adjust collects information on which ad you clicked on and on which site, and whether you installed the app.  If you install the app, Adjust also collects information on when certain events happen (such as completing sign up, successfully adding an ID document, first use of Yoti Password Manager). 

To provide this service, Adjust uses two identifiers which they anonymise using a technology called ‘hashing’. Hashing means turning the actual information into a string of numbers and letters to hide the real data. For example: 85da15a402360fe8ad2e80d958ded300ac9ffb955e3d7cff89007bb340e2b8d5).

How Adjust works 

One identifier is the Advertising ID that Apple or Android gives your phone (depending on which operating system your phone uses). The second identifier is your IP address which is like an address for your phone from your mobile network provider, and which may change if you take your phone to a different location.  Adjust hashes these identifiers. Adjust then provide us with a list of Advertising IDs and country location (based on IP address). We filter the Advertising IDs by things like country, iOS or Android users, or events such as ‘completed sign up’. We then pass relevant Advertising IDs to advertising partners to be able to show our adverts to the right people on their platforms. Once the advertising partner receives the IDs they hash them. The only information Yoti has is the Advertising ID from your device and the events associated with that ID.

We use Adjust with different advertising networks that allow us to show adverts on these networks. Adjust also pass back the Advertising ID to these networks so they can build ‘lookalike marketing models’. This activity is how companies make sure they target their adverts at the right types of users, and users see adverts that are most relevant to their interests. The advertising networks use the Advertising ID and any associated information they have to create groups of people who share similar characteristics. They use these groups to deliver targeted ads. They use the information they have about you to determine which groups you are in, and so which adverts you see. 

Yoti uses advertising networks to make sure we only show our adverts to the people who are most likely to be interested in our products and services. The advertising networks also use the Advertising IDs as a suppression list, to make sure they don’t show the app adverts to people who have already installed the app. See the relevant section of Adjust’s privacy policy for more information: https://www.adjust.com/terms/privacy-policy/ 

Opt out of Adjust analytics for all apps using their technology: https://www.adjust.com/opt-out/ 

You can opt out of the app using Adjust analytics in the app settings.

We have two types of in-house analytics when you are using our products: information created when you take actions on your device; and information created automatically by our internal systems when things happen. 

Examples of information created when you take actions on your device.

• Clicking buttons or links
• Adding documents (our analytics don’t collect any personal details from the document)
• Errors
• Completing steps, such as signing up

Examples of information created automatically by our internal systems when things happen.

• App login completed / failed
• Account deletion completed
• Driving licence rejected / Passport accepted
• Sharing request started / completed / failed

You can opt out (in the app settings) of Firebase and our own in-house analytics  on your device. 

We cannot turn off the information that is created automatically, so you cannot opt out of this. 

Our in-house analytics assigns a randomly generated identifier to each user, with a different identifier for each product used. (Yoti Password Manager is a feature of the app not a separate product. The identifier for the app will be different from the identifier for Yoti Sign, for example.) This means we cannot cross-reference the identifiers to understand what different Yoti products you are using. We use an identifier so we can understand things like whether a count of certain actions is one user repeating an action, or multiple users each doing the same action. This helps us to understand things like where many users are having problems.

Even with the identifier, we take steps to make sure that the information we collect is de-identified so that it is not associated with an identifiable user. We do this by automatically deleting information, such as information that relates to an individual, device IDs or detailed location information. We don’t collect more information than we need. For example, we collect a country location from the device, so we do not need to collect your IP address or other detailed location data to get this information. 

The information from our in-house analytics and Firebase provides us with statistics on things like:

• the number of people installing the app;
• the number of accounts created successfully;
• how long it takes on average to carry out certain actions in the app, such as taking a photo, uploading a document;
• how many addresses are uploaded from a document and how many are manually added;
• the number of recovery files set up, account recoveries, and account deletions;
• the percentage of people who stop using the app at certain key points, such as accepting the terms and conditions, taking a photo and so on;
• the number of users per country, age band, and gender.

These statistics are crucial for us to understand how our app is performing, where things are failing, and what kinds of users we have. This information helps us to understand where we need to focus our business, marketing and product development efforts and what app improvements we need to make. 

You can find more information about Firebase here: 

https://support.google.com/firebase/answer/6318039

We also use in-house analytics information to carry out AB testing. This is where some users may see slightly different information or screen layout. We do this to test planned improvements and see whether what we have planned makes a positive difference to the user experience. Sometimes we randomly show the different content to different users. Sometimes we use the analytics information about what actions users take in the app to only show alternative content to some users, such as those who have added a document.

If you have turned off analytics in the app settings, you may still see alternative content, but we will not be able to track how you interact with the content. We aggregate the tracking information to see which content is more successful. 

We use analytics information to determine when to send reminder push notifications, what reminder to send, and which users we send it to. For example, if you have started to upload a document and not completed the action, we may send you a reminder to complete the document upload. If you turn off analytics in the app settings, then we will no longer receive updated information about your actions in the app. We won’t send reminders to users with analytics turned off to make sure they don’t get reminders that are not relevant to what they are doing in the app. 

If you turn analytics back on we will check the status of your account and update it, so that you only get reminders that are relevant to actions you then take in the app. For example, if you turn off analytics and then add a document, we will not know that you have added a document so you would not get any document-related reminders. If after adding the document you turn the analytics back on, we will update your account status to show that there is a document. You would then get any reminders that are relevant to users who have added documents.

There are many different ways to contact Yoti if you wish to exercise your privacy rights or make a complaint, the main contact details are listed below. All complaints regarding your data privacy will be handled and responded to within one month. 

Please also see the ‘Yoti websites and social media’ section for other ways to contact us and our information collection and use practices when you do so. You can also contact us from the Lloyds Bank Smart ID.

If you wish to exercise your right to complain to the regulator you will find their contact details in the section ‘complain to the regulator’ above in section 7. 

Email: privacy@yoti.com; hello@yoti.com 

Website: https://www.yoti.com/contact

FAQs:   https://yoti.force.com/yotisupport/s/

Postal Address: 

Data Privacy Team

Yoti

6th Floor, 107 Leadenhall St, London, EC3A 4AF

We will use this section to update you about past versions of the Privacy Policy and how to access them.

We will use this section to update you on what’s new in this privacy policy. This is the first version of the Lloyds Bank Smart ID Privacy Policy.