Privacy Policy
Version 3.2: 02/07/2025
1. Introduction
This Privacy Policy is intended to outline the provisions of data privacy applied by SQR across its various services and to the personal data of those parties that interact with those services. It therefore addresses Data privacy from the perspective of;
- Our end-users: those who download the SQR Application to their mobile device and create a reusable and tokenised Digital Identity.
- Our customers’: the personal data of key representatives of our customers to whom we are providing our eKYC dashboard. Please note: where you are a member of staff of a customer, required to create a Digital ID to access and use the eKYC dashboard, your data is managed as if an end-user.
- Personal data of any other third party which is collected and held by us.
This privacy policy applies from the time;
- The SQR Application software (SQR Application), available to download from application stores (Application Sites) and linked from our website http://sqr.id, is downloaded to your mobile telephone or handheld device (Device).
- Any of the services are accessed, through the SQR Application (Services) that are available on the Application Sites, our Website or other sites of ours (Services Sites), unless the Terms of Use state that a separate privacy policy applies to that particular Service, in which case that privacy policy only applies.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. Important information and who we are
The SQR Application and eKYC Dashboard is operated by SQR Group Limited, a company registered in the Isle of Man. Our company registration number is 134592C and our registered office is at Third Floor, Queen Victoria House, Victoria Street, Douglas, IM1 2LF, Isle of Man. We are registered with the Isle of Man Information Commissioner. Our registration number is R508411.
We take the protection and security of your personal information very seriously and this policy sets out our responsibilities under the Isle of Man Data Protection Act 2018 (IoMDPA) and UK General Data Protection Regulation and the Data Protection Act 2018 (which we refer to as ‘UK GDPR’), and any other applicable data protection and privacy laws in the Isle of Man and England and Wales relating to the processing and security of personal information.
SQR has the following accreditations which place additional obligations on us with regard to how we hold, treat, manage and maintain personal data; (1) UK government Digital Identity and Trust Framework (DIATF) and (2) ISO27001 – Information Security Management systems.
SQR Group Limited acts as the data controller for our end users’ personal data, and as joint controller with our relying parties and eKYC dashboard users.
We co-operate with our group companies regarding the provision of the SQR Application and our Services. This means that we and our group companies may jointly determine if and how personal data is processed. Since we and our group companies are controllers of your data when doing so, we will be joint controllers. Our group companies are:
- SQR Group Ltd, a company registered in Isle of Man
- SQRx Limited, a company registered in the United Kingdom
When we refer to ‘’we’’, “us” or ‘’our’’ we are referring to our group companies.
We have appointed a data protection officer (DPO) for both entities. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
- Email address: dpo@sqr.id.
- Postal address: Third Floor, Queen Victoria House, Victoria Street, Douglas, IM1 2LF, Isle of Man
You have the right to make a complaint at any time to:
- Isle of Man Information Commissioner, P.O. Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260 Email: ask@inforights.im (IOMIC).
- The UK Information Commissioner using the following link; Make a complaint about how an organisation has used your personal information | ICO
We would, however, appreciate the chance to deal with any concerns before you approach either the UK or IoM Commissioners’, so please contact us in the first instance at dpo@sqr.id.
3. Keeping our Privacy policy and your information up to date
We keep our privacy policy under regular review. This version was last updated on 2nd July, 2025. It may change and if it does, these changes will be posted to our website and, where appropriate, notified to you by in-Application notification or when you next start the Application or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Application or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our Sites may, from time to time, include links to and from third-party websites, affiliates, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you and they will have their own privacy policies.
4. The data we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data points linked to an SQR account where identity has been obscured or pseudonymized by the application of our technology to certain data attributes, as is the case with SQR QR / H010 Codes.
4.1 Data types
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data: name, address, date of birth, age and gender, nationality and other identity related information submitted to create your Digital ID
- Registration Data: Includes registration information, demographic information, personal description and photographs of both yourself and your personal documentation including, but not limited to: Passport, Driving licences, National Identity cards, utility bills, and bank statements
- Digital Identity Information: Your Digital ID, including information used in identity verification.
- Contact Information: Email address, phone number and other contact detail
- Profile Data: Includes your username and password, product assigned QR/H010 codes, user codes, PEP and sanctions information.
- Biometric Data (Special Category Data): Facial recognition data.
- Usage Data: Includes information about how you use our Applications, Services sites, products and services.
- Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Technical Data: Includes the following each time you visit any of the Services Sites or use the Applications we may automatically collect the following information:
- Technical Data: technical information, including the type of mobile device you use (“Device”), a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting , internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Applications and/or the Website;
- Log / Cookies Data: details of your use of any of the Applications or your visits to our Websites including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access, including the nature of the content that is viewed, related transfer rates, length of viewing, which pages are viewed and other similar data.
- Unique application numbers: When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
We also collect, use and share Aggregated Data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
4.2. Special Category Data Assessment (Biometric data)
Biometric data being classified as “special category data” under the GDPR, requires additional safeguards and justification for its processing.
The purpose for which SQR collects biometric data is strictly for identity verification and fraud prevention purposes, ensuring the security and integrity of your digital identity.
- Security Measures: Your biometric data is encrypted and stored securely. Access is restricted to authorised personnel, and we implement technical safeguards such as encryption and pseudonymization to protect this data.
- Explicit Consent: We will always seek your explicit consent before collecting and processing any biometric data. You may withdraw your consent at any time by contacting us, and we will cease processing your biometric data.
- Data Minimisation: We collect only the biometric data necessary for the specific purpose of identity verification. We do not use biometric data for any other purposes without your explicit consent.
- Storage and Retention: Biometric data is stored securely and retained only for as long as it is necessary to provide our services to end-users and in support of our Customers regulatory requirements.
- Our processing of biometric data is subject of a Data Protection Impact Assessment (DPIA), ensuring that risks related to this type of data processing are identified and mitigated in compliance with GDPR requirements.
Save as specified above (in respect of Biometric Data), we do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). We do not collect any information about criminal convictions and/or offences.
4.3 If you fail to provide personal data
Where we need to collect personal data in order to provide the Services, under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. How is your personal data collected?
We will collect data from you in the following ways;
5.1 Information you give us
This is information (including Identity, Contact, Marketing and Communications Data) you consent to giving us about you by filling in forms on the Applications and the Services Sites (together Our Sites) or by corresponding with us (for example, by e-mail or live chat).
This includes personal data you provide when you:
- download or register an Application
- subscribe to any of our Services;
- create an account on Our Sites and/or the Applications;
- subscribe to any of our Services or publications;
- search for an Application or Service;
- request marketing to be sent to you;
- give us feedback or contact us.
Location Data: We may be able to identify your IP address from a specific piece of technical information that is collected on occasion. We do not seek out this information, capture nor use it in the provision of our service. The web service that captures this information does not further process nor permanently store this data.
5.2 Information we collect from other sources including third parties or publicly available sources.
We will receive personal data about you from various third parties and public sources as set out below:
- Data aggregators in the market providing PEP, Sanctions and adverse media information in support of regulated services compliance services that SQR offers.
Technical Data from the following parties:
- analytics providers
- search information providers
Identity and Contact Data from publicly available sources (where as an end-user you are sharing your information via SQR in support of regulated activity):
- Voters Roll
- Credit checking services etc
5.3 Cookies
We use cookies to collect information about you and to store your online preferences.
A cookie is a piece of data, a small text file, that is temporarily stored on your hard drive when you access a website. Cookies allow us to recognise whether you have used our service before and help us store your preferences or past actions.
The following cookies may be applied where you make use of Intercom, a third-party integration, on our website:
- intercom-device-id – a Unique device identifier – cookie duration 9 months
- intercom-session – Purpose: Keeping track of sessions – cookie duration 1 week
- intercom-id – Purpose: Unique anonymous identifier – cookie duration is 9 months
Cookies may be applied as a result of our use of Google Analytics, a third-party integration tool we use to track website activity such as session duration, pages per session and bounce rates of individuals using the site, along with information regarding the source of the traffic. If you prefer that your personal data is not processed in this way on our website, you can activate the private browsing feature of your web browser and / or use the cookie banner upon entering the site to capture your preferences.
Please note that if you delete or disable cookies you may not be able to access certain areas or features of our site.
6. How we use your personal data
We collect your personal data in connection with services provided to you and our customers for the purposes of providing you identity authentication to enable you to use a service that you wish to receive.
We will only use your personal data in compliance with the data protection laws of the Isle of Man and the UK and for the purpose of providing you a re-usable Digital identity. You control the sharing of your digital ID and the associated personal data in each instance, by consenting to the sharing with third party identity providers and customers of SQRs eKYC dashboard. Most commonly, we will rely on the following legal basis for the collection, processing and sharing of your personal data;
- in performance of the contract we are about to enter into or have entered into with you in providing you a digital identity
- with your consent
- where the processing is necessary for the purposes of legitimate interests, only where your interests and fundamental rights are not overridden by our interests.
- to meet a legal obligation in such a circumstance where your data within our product / service is appropriately requested by or provided to a regulator, law enforcement or similar authority.
Please see the Glossary for further detail on the various lawful bases upon which we will rely to process your personal data.
We will never:
- Share your personal data with any third party for marketing purposes.
- Profile you for marketing purposes.
- Create aggregate data set(s) that could reveal sensitive information about you.
- Process your digital identity or any of the information that makes up your identity or any of your attributes without your agreement.
- Process or share your biometric data in any way which might facilitate facial recognition screening in public locations by authorities or law enforcement.
7. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
Description
Status
Description
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To install the Application and register you as a new Application user
- 1. Identity
- 2. Registration
- 3. Contact
- 4. Technical
- 5. Biometric (incl facial biometric)
Your consent. Performance of a contract with you
To provide access to eKYC dashboard and register you as a new Application user
- 1. Identity
- 2. Registration
- 3. Contact
- 4. Transaction
- 5. Technical
- 6. Financial
- 7. Biometric (incl facial biometric)
Your consent.
Performance of a contract with you.
To manage our relationship with you which will include:
- 1. changes to the Applications or any Services
- 2. Notifying you about changes to our terms or privacy policy
- 3. Asking you to leave a review, provide feedback or take a survey
- 1. Identity
- 2. Contact
- 3. Profile
- 4. Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation (to inform you of any changes to our terms and conditions).
To manage our relationship with customers of the eKYC dashboard which will include:
- changes to the Applications, or any Services
- Notifying you about changes to our terms or privacy policy
- Asking you to leave a review, provide feedback or take a survey
- 1. Identity
- 2. Contact
- 3. Profile
- 4. Marketing and Communications
Performance of a contract with you Necessary to comply with a legal obligation (to inform you of any changes to our terms and conditions).
To administer and protect our business and the Applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- 1. Identity
- 2. Contact
- 3. Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re organisation or group restructuring exercise). Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to customers and measure or understand the effectiveness of the advertising we serve to you.
- 1. Identity
- 2. Contract
- 3. Profile
- 4. Usage
- 5. Marketing and Communications
- 6. Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve the Applications, our Sites, products/Services, marketing, customer and end-user relationships and experiences
- 1. Technical
- 2. Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Description
Status
Description
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. In such a circumstance in which we need to use your personal data for an unrelated purpose to those for which it was collected, and as is documented here, we will notify you and we will explain the legal basis which allows us to do so.
8. Disclosures of your personal data & Data Sharing
When you consent to providing us with your personal data, we are also asking for your consent to share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties such as
- GBGlobal
- Amazon Web Services
- Customers (see definition in glossary)
- Relying Parties (see definition in glossary)
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
- Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Third parties will provide the same or equal protection of your personal data as stated in this Policy and in accordance with App Store Review Guidelines:
- Google Play Store
- Apple Store
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. Data Storage and Transfer
We have adopted AWS cloud storage solutions, where personal data is stored and processed on secure servers in the United Kingdom (UK), and the European Union. We may transfer your personal data to the following locations in delivering our service to you;
United Kingdom
Isle of Man
European Union
Philippines
Any transfer of your data outside of the EU is actioned with the appropriate safeguards to ensure ongoing privacy protection in accordance with UK & IOM GDPR data transfer obligations.
10. Data security
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include, encryption, secure storage and regular security assessments.
An obligation of SQR’s DIATF accreditation is to maintain data security policies and practice in accordance with ISO27001. SQR is also ISO27001 accredited.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. All SQR employees and related third parties will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you by email and any applicable regulator, in accordance with applicable law, in the event of any data breach in which any of your personal information collected by the App or an entity in the SQR group of companies is compromised, unintentionally disclosed or misused.
11. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider;
- the amount, nature and sensitivity of the personal data
- the potential risk of harm from unauthorised use or disclosure
- the purposes for processing the data and whether they can be achieved through other means, and
- the applicable legal, regulatory, tax, accounting or other requirements.
As a company providing services to customers operating within the the Isle of Man’s regulatory framework, we may retain your personal data for six (6) years in order to ensure we cover the mandated five (5) year retention requirement for Customer Due Diligence as detailed in the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019.
As a company providing services to customers within the UK regulatory framework, we ensure we aid those customers with their compliance with the UK Money Laundering Financial Compliance regulations such as UK Money Laundering Regulations (MLR 2017) and the mandated five (5) year retention period.
In each instance the sharing of your personal data with these Customers will be shared only with your consent.
Data Deletion and Anonymisation
After the required retention period, we will securely delete or anonymise personal data, unless a longer period is required due to legal, regulatory or operational obligations. In certain circumstances individuals may have the right to request the deletion of their personal data before the end of the retention period, subject to our legal and regulatory obligations.
To exercise the right of deletion please see your legal rights and how to action such a request detailed below.
In some circumstances we will not delete but anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
12. Your Rights
12.1 Under GPDR
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. You have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact compliance@sqr.id.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you to satisfy a request
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12.2 Accessing and Modifying Account Information
These requests may be made in writing by either email or letter with the support of verification via the SQR application (where you have a working account) to confirm your identity.
We make changes to Personal Information that we hold about you for the purpose of verifying the accuracy of correcting, amending, or deleting such Personal Information where it is inaccurate or if it has been processed contrary to the law or this privacy policy.
Glossary
Lawful Basis Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we, you as an end-user or customer of the eKYC Dashboard are subject to.
Third Parties
- Internal Third Parties – Other companies in the SQR Group Limited acting as joint controllers or processors and who are based in the United Kingdom.
- External Third Parties – Service providers acting as processors based in the UK including, but not limited to, external development partners. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators, law enforcement and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Customers – Your SQR Digital ID will be shared (under legitimate interest and with your knowledge and consent) with Regulated businesses who rely on your re-usable SQR ID information in support of their meeting Anti Money Laundering and Countering the Financing of Terrorism obligations.
- Relying Parties – Term used to refer to Customers and / or companies that host digital ID sharing platforms for the purpose of providing end-users seamless access to customer services which require a digital identity.
