Legal
Privacy Policy
DraftThis document is a draft under legal review and is not yet in force.
This policy explains how [a preencher] handles personal data, including biometric data, when someone completes a verification through Ipsis. In those verifications, the company that sent you the link is the controller of your data, and we process it only on its behalf and on its instructions.
1. Who decides about your data
When you verify your identity through a Ipsis link, the company that sent the link is the controller: it decides why your identity is checked and what happens with the result. [a preencher] is the processor and handles the data only to run the verification for that company.
For our own website and business contacts, [a preencher] is the controller.
2. What we process in a verification
- Images of the identity document you choose (RG, CIN, CNH or passport data page).
- Data read from the document: name, CPF, date of birth, document number and expiry date.
- Images captured during the live movements and the selfie compared with the document photo.
- Comparison scores. The numeric representation of your face (template) exists only in memory during the comparison and is never stored.
- Technical data: IP address, browser (user agent), timestamps and the record of your consent.
3. Why and on what basis
The data is used only to verify that you are a real person, present in front of the camera, and the holder of the document, for the company that asked for the verification. Biometric data is sensitive personal data under the LGPD (art. 11) and a special category under the GDPR (art. 9): before any capture, the page asks for your specific consent, naming the company as controller.
4. How long we keep it
Images are kept for the retention period configured for the company's account, which can be zero days (deleted as soon as the session is decided). A daily job deletes images whose period has ended. The company can also delete a session's images and personal data at any time through the API.
5. Sub-processors
We use the providers below to run the service. Each one is bound by a contract with data protection obligations.
Cloud infrastructure
Provider: [a preencher]
Country: [a preencher]
Document reading (vision model)
Provider: [a preencher]
Country: [a preencher]
6. International transfers
Document reading may take place outside Brazil, at the provider listed above. Transfers rely on the mechanism stated in the data processing agreement: [a preencher]. An option to read documents inside Brazil is on our roadmap.
7. How we protect it
- Every image is encrypted by the application with AES-256-GCM before it reaches storage.
- Storage is private: images leave only through an authenticated API route.
- Every query is scoped to the company's account.
- The capture link token stays after the
#of the address, which browsers never send to servers. - Every relevant step leaves an audit event.
8. Your rights
You can ask for access, correction, deletion or information about your data. Because the company that sent the link is the controller, send your request to it; if you write to us, we forward it and help the company answer.
9. Contact and data protection officer
Data protection officer: [a preencher], [a preencher]. Other privacy questions: ipsis@tolky.to.
10. Changes
When this policy changes, we update the version and the effective date at the top of this page.
Other documents: Terms of Service Data Processing Agreement