Privacy Policy Notice: Data Collection, Processing, Transmission,
and Use for Identification Purposes

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Identity Verification: Collection, Processing, and Use of Personal Data for Identification Purposes‍ ‍

As part of the identity verification process, Persona Identities, Inc. ("Persona") collects, processes, and transmits certain personal data to Atheneum Partners to verify expert identities and prevent fraud or impersonation.‍ ‍

Identity verification includes biometric verification: a live photograph (selfie) of you is captured and compared against the photograph on your government-issued identity document, including checks that a live person is completing the process. This biometric processing is carried out by Persona in accordance with its Privacy Policy and is based on your explicit consent (Art. 9(2)(a) GDPR), obtained before verification begins. You may withdraw this consent at any time; withdrawal does not affect the lawfulness of prior processing, but will affect your Atheneum Expert Network profile status and require re-verification to restore access. Biometric data is retained by Persona for no more than five years. Biometric verification against a government-issued photograph does not apply to experts verifying in South Korea. ‍ ‍

At your request, Persona will delete your personal data. Atheneum processes and retains your data in accordance with the Atheneum Expert Agreement and stores it for the duration of your membership in the Atheneum Expert Network, or until you request its deletion, subject to any retention required by applicable law.

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Data Collected, Processed, and Transmitted‍ ‍

The following categories of data are processed for identity verification:‍ ‍

  • Personal Information: Salutation, title (optional), first name, surname, name affixes, maiden name, date of birth, place of birth, nationality, and a photo of the individual being identified.

  • Biometric Data: A live photograph (selfie) and the biometric identifiers derived from it for comparison against your identity document photograph and for liveness detection.

  • Address Details (for identity documents): Street address, house number, postal code, and city of residence.

  • ID Document Information: Type of ID, ID number, issuing country, date of issue, expiration date, issuing authority, front and back images of the ID, and images of security features.

  • Contact Details: Mobile phone number (for authentication via SMS) and email address (for support in case of technical issues).

  • Additional Data: Audio and video recordings of the identification process conducted via video chat (where applicable).

  • Technical and Device Data: Collected automatically by Persona during verification: IP address and derived approximate location, network and connection information (including detected use of a VPN, proxy, or Tor), device and browser identifiers (including browser fingerprint), operating system, GPS location (where enabled), and referring web page. Used for fraud prevention and security.

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Identity Verification in South Korea

This Part applies only to experts verifying their identity in South Korea. The data categories outlined above does not apply, with one exception: Technical and Device Data is collected by Persona in all verification flows, including South Korea. No identity documents, document images, address details, or audio/video recordings are collected, and no biometric comparison against a government-issued photograph is performed. Atheneum does not collect, process, or store Resident Registration Numbers (RRNs) and does not accept Korean identity documents displaying an RRN.‍ ‍

How verification works: Your identity is verified through South Korea's government-recognised digital ID methods: mobile carrier (PASS) or i-PIN – offered through Persona and performed by Korea Credit Bureau (KCB), an identity verification provider designated by the Korean government. You enter your details, depending on the method, directly into a KCB-hosted window. That information is processed by KCB and your mobile carrier, or i-PIN provider to confirm your identity. It is not shared with Persona or Atheneum. Where a selfie is requested as part of the flow, it is used for liveness confirmation only.‍ ‍

Data Atheneum receives: On successful verification, Persona receives and transmits to Atheneum your verified full name (in Korean script), verified date of birth, a sex/residency code, and a Korean national/foreigner code. If verification fails, no data is returned. Your RRN is never collected, transmitted, or stored. ‍ ‍

The role of KCB: KCB receives and processes your personal data for the purpose of identity verification. KCB acts as an independent data controller for the personal data it processes to perform the verification, it is not a processor or sub-processor of Atheneum or Persona. ‍ ‍

Your rights under PIPA: You may have rights under South Korea's Personal Information Protection Act to access, correct, or delete your personal data and to withdraw consent. Withdrawing consent will affect your Atheneum Expert Network profile status and will require re-verification to restore access.

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Your Rights as a Data Subject

‍You have the right to request access to your stored data from Atheneum or Persona at any time. Additionally, you may revoke your consent for data processing by contacting the relevant entity. Please note that withdrawing consent will impact the status of your Atheneum Expert Network profile and will require re-identification to restore access.

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Data Controllers and Data Protection Officers

Data Controller

‍The entity responsible for processing personal data in the identification process, as defined under Article 4(7) of the General Data Protection Regulation (GDPR), is Atheneum Partners GmbH. For further details, please refer to Atheneum's Privacy Policy and Data Protection Information, available electronically on Atheneum's website.

‍For identity verification in South Korea, Korea Credit Bureau (KCB) acts as an independent data controller for the personal data it processes to perform the verification.

Data Protection Officer

‍Atheneum has appointed a Data Protection Officer. Contact details are provided in Atheneum's Privacy Policy Notice, available at: https://www.atheneum.ai/privacy-policy-notice

‍For additional details on how Persona processes and protects your data, please refer to Persona's Privacy Policy, available at: https://withpersona.com/legal/privacy-policy