1. Introduction
Proper User UAB, a company incorporated and registered in the Republic of Lithuania
(“Proper,” “we,” “us,” or “our”), operates the Proper ID mobile application (“App”).
This Privacy Policy explains how we collect, process, store, use, and protect personal
data, including biometric data, when you use the App.
Proper User UAB acts as the Data Controller under the General Data Protection Regulation
(EU) 2016/679 (“GDPR”).
2. Categories of Personal Data Collected
We may collect and process the following categories of personal data:
A. Identification Data
- Full name
- Date of birth
- Email address
- Phone number
- Government-issued identification details
- Proper ID number
B. Identity Documents
- Images of identification documents captured via live camera
- Passport / ID card / driver’s license
- Proof of residential address
C. Biometric Data
- Facial images
- Video selfie recordings
- Liveness detection data
- Facial comparison data
Biometric data is processed solely for identity verification and fraud prevention.
D. Location Data
- One-time GPS-based country-level location verification
We do not perform continuous tracking.
E. Technical Data
- Device information
- IP address
- App usage logs
- Authentication logs
- OTP generation logs
3. Purpose of Processing
Personal data is processed for:
- Identity verification (KYC)
- Fraud prevention
- Regulatory compliance
- Authentication requests
- Partner platform verification
- Security monitoring
- Audit trail maintenance
4. Legal Basis for Processing
We process personal data under the following GDPR legal bases:
- Article 6(1)(b) – Performance of a contract
- Article 6(1)(c) – Legal obligation
- Article 6(1)(f) – Legitimate interests (fraud prevention, security)
Biometric data is processed under:
- Article 9(2)(a) – Explicit consent
- Article 9(2)(g) – Substantial public interest (where applicable)
5. Biometric Data Processing
By using the App and completing identity verification, you explicitly consent to:
- Capture of facial images
- Recording of live video selfies
- Liveness detection processing
- Facial comparison analysis
Biometric data is:
- Used strictly for verification
- Stored securely
- Not sold
- Not shared with partner platforms
We may retain biometric verification records as required by law.
6. Data Sharing
We may share:
- Verification status only (e.g., verified / not verified)
- Age confirmation
- Country-level confirmation
We do NOT share:
- Raw identity documents
- Biometric files
- Video recordings
- Uploaded images
Data may be disclosed to authorities if legally required.
7. Data Retention
We retain data:
- For as long as your account remains active
- As required by regulatory obligations
- As necessary for fraud prevention and audit purposes
Biometric and identity verification records may be retained in accordance with
compliance requirements.
8. International Transfers
If third-party service providers are located outside the EEA, we implement:
- Standard Contractual Clauses
- Adequacy mechanisms
9. Security Measures
We implement:
- Encryption in transit and at rest
- Secure storage systems
- Restricted access controls
- Audit logging
However, no system is 100% secure.
10. Your Rights Under GDPR
You have the right to:
- Access your data
- Rectify inaccurate data
- Request erasure (subject to legal limits)
- Restrict processing
- Object to processing
- Data portability
- Withdraw biometric consent (which may limit App functionality)
Requests may be submitted to support@properuser.com
11. Withdrawal of Consent
If you withdraw consent for biometric processing, we may be unable to provide
verification services, and your Proper ID may be suspended.
12. Children
The App is intended for individuals aged 18 and over.
We do not knowingly process data of minors.
13. Changes to This Policy
We may update this Policy from time to time.
Continued use constitutes acceptance of updates.
14. Contact
Proper User UAB
Republic of Lithuania
Email: support@properuser.com
Website: www.properuser.com
