Your personal data (Data) are processed in the context of the agreement entered into between you and us on the use of the services of VERIMI GmbH, including the use of our website and our app. These Data include, for example, your name, your address, your email address and further information about you. In terms of this Confirmation, 'processing' is a general term that encompasses any form of dealing with Data.
The following provides you with information on the processing of your Data in the context of VERIMI's use of these. Where the following refers to provisions contained in the General Data Protection Regulation (GDPR), these provisions shall apply (just like the duty to state the legal basis) as of 25 May 2018. Irrespective thereof, the other confirmations are already effective provided not expressly stated otherwise.
Purposes and legal basis for our processing of Data
In order to register with us, you may use either our website or our app or you may consent to the transfer of Data to us by third parties vis-a-vis that third party. You may not use VERIMI without submitting the information that is set out as mandatory at registration. The legal basis for the processing of this Data is Art. 6 (1) sentence 1 point (b) GDPR, since such processing is necessary for the performance of the agreement entered into between you and us.
You are then able to provide further Data voluntarily or to permit third parties to transfer these to us and to store these with us for use in the context of using our services, in particular where you provide consent to the transfer of such Data to third parties for the purpose of registering with third parties or the administration of your legal relationship to these third parties. The legal basis for the processing of such Data is your consent pursuant to Art. 6 (1) sentence 1 point (a) GDPR.
An essential, but similarly voluntary, function of VERIMI is that you may verify yourself and your Data through VERIMI and that you may use your Data in relation to third parties. The legal basis for the processing of such Data is your consent pursuant to Art. 6 (1) sentence 1 point (a) GDPR.
In the context of our agreement with you, we also process Data in order to show you use that has already taken place in the recent past and to make corresponding suggestions for further use, including the services of partners. The legal basis for the processing of such Data is Art. 6 (1) sentence 1 point (b) GDPR, since such processing is necessary for the performance of the agreement entered into between you and us.
We also process Data in order to send you newsletter emails on the basis of any consent to this that you may have provided. The legal basis for the processing of such Data is your consent pursuant to Art. 6 (1) sentence 1 point (a) GDPR.
Finally, we also process Data in your and our interest in order to ensure the integrity, trustworthiness and availability of the data processing systems, i.e. in particular the security and availability of your Data with VERIMI. It is not possible to make use of our website and our app without the processing of Data for this purpose. The legal basis for the processing of such Data is Art. 6 paragraph 1 no. 1 point (f) GDPR; our legitimate interest is the maintenance and secure provision of our services.
No data transfer outside of the EU
The Data collected by us will be stored exclusively on servers located in the European Union. No transfer of Data to businesses outside of the European Union will take place without your express consent. This also applies to any service providers used by us for data processing.
Recipients of Data
We will transfer or receive your Data on the basis of our User Agreement with you or on the basis of your consent only by way of a secure connection to the recipients selected by you or from these.
In order for us to offer to you all of the functions of VERIMI, we also make use of selected service providers who process data upon our commissioning and on our behalf. In doing so, we only provide data in the context of legally-permissible processing to service providers who have been carefully selected and commissioned in writing. These shall receive only those Data that are required for them to perform their tasks. These include the following categories of subcontractors: identification service providers, software developers, server hosting providers, newsletter senders, customer support, web analysis services.
Duration of data storage
We store your Data for the duration of the existence of your VERIMI account. However, you may cancel or also lock your VERIMI account at any time. We will then delete your Data unless we are obliged at law to continue to store or maintain these. Where Data are still required for the settlement of outstanding transactions, deletion will take place at the earliest once these transactions have been settled.
Your use of VERIMI through third parties
Through our website, you may be access third parties where you may also use VERIMI and our functions. In using these third-party services, the third party will enter into its own agreement with you and may potentially obtain consent from you to the use of your Data. The Data provided at registration and in the use of these third-party services will be processed by the third party and shall only be provided to us on the basis of any consent provided by you to that third party.
All Data stored with us or at any processors are protected using current security standards against unauthorised access, loss and modification. Comprehensive technical and organisational security precautions are taken for this with standards that at least match legal requirements.
Your rights and opportunities to lodge complaints
(1) You have the following rights that you may assert against us with respect to the Data relating to you:
- right of access,
- right to rectification or erasure,
- right to limit processing,
- right to revoke your consent,
- right to object to processing,
- right to data portability (as of 25 May 2018).
You may assert all of these rights by turning to our data protection officer at email@example.com.
(2) You also have the right to lodge a complaint with respect to the processing of your personal data by us with a data protection supervisory authority.
The person responsible for the processing of data in terms of data protection law is:
Verimi GmbH Oranienstraße 91 10969 Berlin
Please feel free to also contact our customer service with any general questions on VERIMI at:
Data protection officer
Please also feel free to contact our data protection officer with any questions concerning data protection at:
Christian Aretz Verimi GmbH Oranienstraße 91 10969 Berlin
Additional conditions for Mobile Connect
Please note the following data protection information, if you have activated the login function login with mobile phone number by Mobile Connect in the Verimi portal: The login function login with mobile phone number by Mobile Connect, which allows you to authenticate yourself with your mobile phone number, is provided by the participating mobile providers. For this purpose, your mobile phone number is firstly transmitted to a service provider of the participating mobile providers in the background, whereupon your network membership is communicated to VERIMI without storage of personal data. In the second step, this data is forwarded to your mobile provider, where you can easily activate Mobile Connect.
Telefónica Germany GmbH & Co. OHG, Data Protection Officer, Georg-Brauchle-Ring 50, 80992 München, encrypted contact form: https://www.telefonica.de/unternehmen/datenschutz/kontakt/datenschutz-anfrage.html Data Protection Information: https://www.telefonica.de/datenschutzmerkblatt
Vodafone GmbH, Data Protection Officer Dr. Dirk Herkstroeter, Ferdinand-Braun-Platz 1, 40549 Düsseldorf, firstname.lastname@example.org. Data Protection Information: https://www.vodafone.de/unternehmen/verantwortung/datenschutz-im-dialog.html
Telekom Deutschland GmbH, Data Protection Officer, Friedrich-Ebert-Allee 140, 53113 Bonn, email@example.com. Data Protection Information: https://www.telekom.de/datenschutzhinweise/download/014.pdf
Your mobile provider's data protection information will also be made available to you as part of the Mobile Connect activation process.
Additional conditions for Verimi Pay
If you choose to use Verimi Pay, the notices set forth in this section will apply additionally to the other privacy statements:
Processing purposes and legal bases
In order to use Verimi Pay, you give us a direct debit mandate relating to your bank account to collect payments. For this purpose we require information on your bank details and your verified identity data (title, first and last name, name at birth, pseudonym, date of birth, place of birth, nationality, residential address, type of ID document, date of issue, issuing authority, document number and expiry date). We also ask if you are a politically exposed person. If this information is not yet stored in your Verimi account, we will ask you to provide this information.
When using Verimi Pay, we process your personalized security features required to authorize the transaction. In addition, we collect and store the payment and transaction data relating to the transac-tions you have performed. We shall notify this to the credit institution commissioned by us to manage the trust account for payments.
The legal basis for the processing of this data is Art. 6 subsection 1 para. 1 lit. b) GDPR since the pro-cessing is necessary for the use of Verimi Pay within the framework of the user contract existing be-tween you and us.
To enable you to use Verimi Pay, we perform a credit check. For this purpose, we transfer your per-sonal data (first and last name, title, gender, date and place of birth, nationality, residential address) to SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden, Germany and in return receive personal data from SCHUFA relating to your creditworthiness (score points and score group). If, in the event of a breach of contract on your part, a claim is asserted, we will notify SCHUFA of your personal data relating to the respective transaction (title, first and last name, residential address, amount, date, bank details). The legal bases for these transfers are Art. 6 subsection 1 para. 1 lit. b) and lit. f) GDPR. Transfers based on Art. 6 subsection 1 para. 1 lit. f) GDPR may only take place insofar as this is nec-essary to safeguard the legitimate interests of Verimi GmbH or third parties and does not overweight the interests or fundamental rights and freedoms of the person affected.
SCHUFA processes the data received and also uses it for the purpose of scoring and in order to pro-vide its contractual partners in the European Economic Area and in Switzerland as well as other third countries (if a European Commission adequacy decision exists) with information for the assessment of the creditworthiness of natural persons, among other things. Further information on the activities of SCHUFA can be found in the SCHUFA Information Sheet pursuant to Art. 14 DS-GVO or can be viewed online at www.schufa.de/datenschutz.
Matching with terrorism and sanctions lists
We are legally required to match your first and last name with current terrorism and sanctions lists be-fore activating Verimi Pay and at regular intervals thereafter. The legal basis for this processing is Art. 6 subsection 1 para. 1 lit. c) GDPR for compliance with our legal obligations.