1. Introduction
This Privacy Policy explains how Proper User UAB, a company incorporated and registered
in the Republic of Lithuania (“Proper,” “we,” “us,” or “our”), collects, uses, stores,
and protects your personal data when you use:
- Proper User (web platform)
- Proper ID (mobile application)
- Any related services (collectively, the “Services”).
Proper User UAB acts as a Data Controller under the General Data Protection Regulation
(EU) 2016/679 (“GDPR”).
By using our Services, you acknowledge that you have read and understood this Privacy Policy.
2. What Personal Data We Collect
We collect personal data in two stages: Pre-Verification (Web) and Full Verification (App).
2.1 Account Information (Proper User)
- First name
- Last name
- Email address
- Username
- Password (encrypted)
- IP address
- Account activity logs
2.2 Verification Data (Proper ID App)
- Phone number
- OTP verification logs
- Government-issued ID documents
- Passport / Driver’s License images
- Live selfie images
- Video selfie recordings
- Liveness detection results
- Residential address
- Proof-of-address documents
- Location verification (country-level only)
- Biometric authentication data (Face ID / device-level authentication)
2.3 Business Data (KYB, if applicable)
- Company name
- Registration number
- Tax information
- Business documents
- Ownership information
2.4 Technical Data
- Device information
- App usage logs
- Security logs
- Audit trail records
3. Special Categories of Data (Biometric Data)
During the verification process, we process biometric data (such as facial recognition
and liveness detection) solely for identity verification purposes.
Such processing is based on:
- Explicit consent under Article 9(2)(a) GDPR
- Compliance with legal obligations where applicable
Biometric data is used strictly for verification and fraud prevention.
4. Legal Basis for Processing
We process your data under the following legal bases:
- Performance of a contract (Article 6(1)(b) GDPR)
- Legal obligation (Article 6(1)(c) GDPR)
- Legitimate interests (Article 6(1)(f) GDPR)
- Explicit consent (Article 6(1)(a) and Article 9 GDPR)
5. How We Use Your Data
We use personal data to:
- Create and manage accounts
- Perform identity verification
- Issue Proper ID numbers
- Generate OTP authentication codes
- Prevent fraud and identity misuse
- Comply with KYC / AML regulations
- Respond to support requests
- Maintain security and audit logs
- Enable platform integrations (verification status only)
We do not sell personal data.
6. Data Sharing
We do not share raw identity documents with third-party platforms.
When interacting with partner platforms:
- Only verification status is shared
- No original documents are transmitted
- User consent is required before sharing
We may share data with:
- Identity verification service providers
- Secure cloud hosting providers
- Regulatory authorities where legally required
All third-party processors operate under GDPR-compliant agreements.
7. International Data Transfers
Where data is transferred outside the European Economic Area (EEA), we ensure:
- Standard Contractual Clauses (SCCs)
- Adequate protection mechanisms under GDPR
8. Data Retention
We retain personal data:
- As long as the account remains active
- As required by legal or regulatory obligations
- For fraud prevention purposes
Upon account deletion, data may be retained for legal compliance or dispute resolution.
9. User Rights Under GDPR
You have the right to:
- Access your personal data
- Correct inaccurate data
- Request deletion (“Right to be Forgotten”)
- Restrict processing
- Object to processing
- Data portability
- Withdraw consent at any time
To exercise your rights, contact:
support@properuser.com
You also have the right to lodge a complaint with the Lithuanian Data Protection Authority.
10. Security Measures
We implement:
- Encrypted data storage
- Secure camera-only document capture
- Access control systems
- Audit logging
- Secure authentication mechanisms
- Role-based internal access
No system can guarantee 100% security, but we take industry-standard measures.
11. Location Data
Location verification:
- Is country-level only
- Is one-time
- Is not continuous tracking
- Requires explicit consent
We do not monitor real-time movements.
12. Cookies (Web Platform)
Proper User uses cookies for:
- Essential website functionality
- Security
- Session management
Non-essential cookies require user consent.
A separate Cookie Policy may apply.
13. Children’s Privacy
The Services are strictly for individuals aged 18 and above.
We do not knowingly collect data from minors.
14. Changes to This Policy
We may update this Privacy Policy from time to time.
Material changes will be communicated through the platform.
Continued use of the Services constitutes acceptance of updates.
15. Contact Information
Data Controller:
Proper User UAB
Republic of Lithuania
Email: support@properuser.com
Website: www.properuser.com
For data protection inquiries, contact:
support@properuser.com
