Your security and right to privacy is important to us. Riverr Pte. Ltd. (“Riverr”) respect the rights of our “clients”, “visitors” and the “users” of Riverr’s “Platform” that includes Apps and websites and all electronic services, applications and internal links on the platform.
Overall, Riverr collects data:
To offer our users an efficient, data-driven data management platform;
To provide identity verification services;
To meet the legal, accounting and tax requirements;
To provide information about the Platform - for example about new features;
To find and fix any ‘bugs’ or errors at the Platform;
To provide offers and marketing;
To authenticate your access to certain parts of the Platform and confirm your consent to our General Terms or other agreements;
To personalise your experience on the Platform and the websites;
To improve the Platform and the services that Riverr provides;
To address specific inquiries you make at Riverr;
To address and confirm the execution of documents and templates;
To enable you to use our services, including check your payment information, and billing for the services you use;
To send newsletters and messages to you.
You can choose to share personal information with other Parties in documents and drafts you send. We will not sell, rent, loan, trade, or otherwise disclose your information with third parties unless such disclosure is necessary to: comply with a court order or other legal process.
Personal Information (Identifiable)
Riverr collects personal information such as name, email and telephone number when you register at the Platform. This information is necessary to make sure that your data are valid.
Riverr may also utilise your email and telephone number to inform you about the Platform and new features that might be relevant to you. Riverr may also use your email for the purposes of customer support and marketing related matters. You are always entitled to unsubscribe from marketing emails. Unsubscribing can be done in the bottom of the emails you might receive.
The platform enables a “user’s” documentation, like certificates to be shared securely and seamlessly in a cryptographically secured electronic format known as a “verifiable data”, or “verifiable certificate”. The “user” will receive verifiable data in his digital wallet as part of the platform and have the ability to control who they share their data with.
Trusted and recognised entities such as trusted third party organisations can access the verifiable data if granted access by the “user”. The “users'' ID will be verified in different ways through Riverr Identity Services either by using third-party national login (eID) (example of such is SingPass in Singapore) or by using identity document for ID (proof) and facial recognition to compare the person (match) with their passport picture.
This solution is meant to ensure certificates are authentic, reduce the work of endorsing certificates and reduce the workload of uploading certificates to the third-party systems.
To provide our Identity Services, we need to collect certain information about our “clients'' users. When verifying the identity of a user, we’ll ask for an image of their identity document as well as a picture or video of their face. We’ll then seek to verify whether the identity document is likely to be genuine and whether the person in the photo or video is likely the same person pictured in the identity document. We will also look to identify signs of fraud (for example, someone wearing a mask to impersonate another person or conceal their own real identity). If the user is successful on both the document and facial verification checks, Riverr client will likely consider the user to have proven their identity. Identity documents containing national ID number and passport numbers are not visible to any third-parties and are only processed on a highly restricted basis. All data stored is 256-bit SSL encrypted. To do all of this, we closely examine the information contained in the images, including the machine readable data (such as an identity document barcode) and the image metadata (such as the name of the camera model used to take the image). The Riverr Identity Lifecycle is described below for the “client”, “user” and “data-providers” on how we collect that information.
1. The “Client” Users
Are individuals whose identities we verify or otherwise check on behalf of our clients. We collect users’ information from clients or directly from the users themselves. This information might include an image of an identity document (e.g. a passport or a driver's license), photos (at times, taken in quick succession for anti-fraud purposes) or a video of the user, and the biometric facial identifiers in those images. This enables us to help the client verify that the user is the true owner of the identity document and has not shown signs of fraud. In some circumstances, we may also collect device identifiers and IP addresses to help us understand whether a device has previously been used in relation to suspected fraudulent activity and whether Riverr is permitted to provide Identity Services in the country in which the user is located.
2. The “User”
Users are individuals whose identities we verify or otherwise check on behalf of our clients. We collect users’ information from clients or directly from the users themselves. This information might include an image of an identity document (e.g. a passport or a driver's licence), photos (at times, taken in quick succession for anti-fraud purposes) or a video of the user, and the biometric facial identifiers in those images. This enables us to help the client verify that the user is the true owner of the identity document and has not shown signs of fraud. In some circumstances, we may also collect device identifiers and IP addresses to help us understand whether a device has previously been used in relation to suspected fraudulent activity and whether Riverr is permitted to provide Identity Services in the country in which the user is located.
3. The “Data Providers”
We also keep logs of how our clients, users, and data providers interact with our Identity Services. This might include timestamps of when the information was submitted to Riverr, and information about the device used to submit that information. Sometimes, we receive information we don’t need to provide our Identity Services. For example, instead of a picture of their identity document, a user might upload a completely unrelated image. When this happens, we seek to delete this data.
Passing a Riverr Check
If we’re able to verify the identity of a user and the user is able to pass all requested checks, we notify the client who can then continue with their onboarding process.
Not Passing a Riverr Check
If we’re unable to verify the identity of a user or the user isn’t able to pass all requested checks, we recommend to the client that they conduct additional checks before continuing with the onboarding process. We sometimes help with those additional checks too.
Developing our Identity Services
To further develop our Identity Services, we train our computers to recognise specific patterns in information and make predictions about new sets of information based on those patterns. This is known as machine learning.
We’ve gathered a substantial and unique set of images from around the world, from which we can train our machine learning models to locate and extract the information in documents, to detect fraudulent documents, and to engage in facial verification. We also train our human analysts to perform those tasks so they can assist when our machine learning models aren’t best suited for the task or are still learning. Sometimes, we’ll also re-run and re-submit checks to ensure our Identity Services are working properly, particularly when testing a new feature or service for quality assurance. Together, these developments help make Riverr’s Identity Services stronger and safer for all clients and users.
We use information to provide and maintain our Identity Services on behalf of clients on the basis that the user has consented to the processing or otherwise requested Identity Services, the client has a legitimate or lawful reason for requesting Identity Services, or the processing is necessary to carry out a task in the public interest or for reasons of substantial public interest. We also use information to further develop our Identity Services on the basis that the processing is necessary in the legitimate interest of the client or Riverr, the processing is necessary to carry out a task in the public interest or for reasons of substantial public interest, the processing is necessary for scientific research purposes, or the user has provided their consent.
Facial Biometric Comparison
When providing our Identity Services, we will frequently extract and compare numerical biometric data from facial images to understand whether two faces are likely to be a match. We do this on behalf of our clients for two reasons. Primarily, we will check whether a user owns their identity document by comparing an image of their face to the facial image contained in the identity document. When we do this, we do not retain the extracted numerical biometric data for any length of time beyond this comparison. In addition, we may also check whether we have previously verified a user on behalf of a specific client to help that client understand when a user may be generating multiple identities. We do this by comparing the facial image of a user to the facial images of other users previously verified on behalf of that specific client. To provide this check quickly, we store the numerical biometric data extracted from the previously collected facial images until the client deletes those original images.
Automated Decision Making and Riverr Reports
Processing payment information
If you are using one of our paid plans, Riverr will use a third party to process your payment information. Riverr will not store any payment information, but will use Stripe to process the payments.
If you invite a third-party to the Platform to Connect, the email of the third party will be stored on the Riverr platform in order for you to monitor the invitation. Riverr cannot control what information our users enter into the platform thus will not be held responsible for any such information. Platform may track and collect the Internet Protocol (IP) address when you visit and use the Platform.
Riverr can track and collect the following categories of Information when you visit and use the Platform: the domain servers; types of computers (including mobile devices such as tablets and smartphones); navigation paths used while visiting the website or platform; browser settings; installed plug-ins; local preferences storage; screen resolutions; local time zones; font lists; the user-agent information, and the types of web browsers that are used to access the Platform.
Your use of Riverr's Platform might involve you sharing, uploading or inputting various content containing personal information into the Platform, including but not limited to: data, attachments, and conversations. This content is encrypted and stored by us. You control who you invite to view or sign the content and how your content is shared with others. In general, Riverr does not monitor that content. We strongly recommend that you do NOT store any sensitive information (cf. Article 9 in the General Data Protection Regulation).
Automatically Collected Data
Behaviour: We are using session-recordings to analyse user behaviour on the Platform in order to understand how the Platform is being used and in the end optimise user experience on the Platform. Session-recordings are conducted without seeing the content you have on the Riverr platform.
Data Processor Agreement
“Clients” of the Platform will receive a Data Processor Agreement to be read and signed. The agreement states the rights and obligations of both parties for when Riverr is processing personal information on behalf of the Data Controller. This Agreement is based on a standard which has been designed to ensure the Parties’ compliance with Article 28, sub-section 3 of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), which sets out specific requirements for the content of data processing agreements.
The Data Processing Agreement contains, but is not limited to, the following points:
that Riverr shall solely be permitted to process personal data on documented instructions from the Data Controller unless processing is required under EU or Member State law to which Riverr is subject.
that Riverr shall ensure that persons authorised to process personal data on behalf of the Data Controller have undertaken to observe confidentiality, or is subject to a suitable statutory obligation of confidentiality.
that Riverr shall take all the measures required pursuant to Article 32 of the General Data Protection Regulation.
that Riverr shall meet the requirements of the General Data Protection Regulation in order to engage another processor (subprocessor).
that Riverr shall assist the Data Controller with appropriate technical and organisational measures, in the fulfilment of the Data Controller’s obligation.
that Riverr shall be under obligation, at the Data Controller’s discretion, to erase or return all the personal data to the Data Controller.
that Riverr is able to show documentation to the data controller.
You can request the full Data Processing Agreement by contacting us.
Riverr has the Data Controller’s general consent for the engagement of subprocessors. Riverr shall, however, inform the Data Controller of any planned changes with regard to additions to or replacement of other data processors and thereby give the Data Controller the opportunity to object to such changes. Such notification shall be submitted to the Data Controller a minimum of 14 days prior to the engagement of sub-processors or amendments coming into force. If the Data Controller should object to the changes, the Data Controller shall notify the Data Processor of this within 7 of receipt of the notification. The Data Controller shall only object if the Data Controller has reasonable and specific grounds for such refusal.
Relation to the Law
We may share your personal information with public and legal authorities if Singapore or EU-law obliges us to. For example, if we have a justified belief that it is necessary to comply with EU's General Data Protection Regulation or if we suspect that you use of the Platform violates EU- or Member State laws.
Provided further Riverr will only disclose data to the extent necessary for Riverr to meet underlying business requirements such as legal and compliance. Provided further that Riverr agrees that, prior to submitting to the third Party any personal data or customer information, all necessary authorisations and consents as may be required in compliance with the applicable Privacy Laws havebeen obtained.
Security measures - this is how we protect your personal information
We are entitled and under the obligation to make decisions about the technical and organisational security measures that are to be applied to create the necessary level of data security and to protect your personal information against loss, misuse, publicity or unauthorised access. We use firewalls, encryption techniques, and authentication procedures to maintain the security during your sessions on the Platform.
Riverr will ensure that data in the custody of Riverr is protected against any accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful Processing. Riverr will implement appropriate security measures in storing collected Information, depending on the nature of the information.
Unauthorised access to personal information
You can control who you are sharing content and user information with. To prevent unauthorised access, maintain data and ensure the appropriate use of Information, we have implemented commercially reasonable physical, technical and administrative control mechanisms to protect your information. However, we cannot control the actions of other users with whom you share your content and we are not responsible for third party circumvention of any privacy settings or security measures on the Platform.
You may decline to submit personally identifiable information through the Platform, in which case Riverr may not be able to provide certain features and functionalities of the Platform to you - for example, storage of your documents or digital signature. If you decide to terminate your use of the Platform, You can request access to your personal information, and request us to comply with the right to Data Portability at any time, including when and if you decide to terminate your use of the Platform. You can also request that your personal information is deleted. Some information will be stored at least, and at a maximum of 5 years after you terminate your use of the Platform in order for us to comply with any legal obligations - for example regarding tax and accounting obligations.
Our Platform is not directed to persons under the age of 13. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for an account on the Platform. If we become aware that we have collected personal information from a child under age 13 without verified consent of a parental or guardian, we take steps to remove that information. We can not control if our users collect and store data of persons under the age of 18. In general, we advise our users to collect parental consent before they collect and store data of anyone under the age of 18.
Riverr’s Platform is an online tool to facilitate the process of creating, signing and storing data. It is always your responsibility to ensure that information and content that you enter and upload on the Platform is your property (or has obtained permission to do so). The information and content shall be correct and is not against the law or the rights of others. It is also your responsibility to provide the correct receiver in the transmission of data in the module “connect”.