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Surt Privacy Policy

Effective Date: October 1, 2025

Welcome to the Privacy Policy (the "Policy") of Surt and its related, affiliated or subsidiary companies (collectively "Surt"). The purpose of this Policy is to inform you how we collect, use, and share your information to provide identity verification and fraud prevention products and services (collectively the "Services").

When we refer to "you" or "your" in this Policy we mean any individual who interacts or uses our Services. By using the Services, you represent that you understand and agree to this Policy, and consent to the collection, use, and sharing of information as described in this Policy. If you do not consent to our practices, you can choose not to use the Services.

Privacy Policy Changes

We reserve the right to modify this Policy at any time without notice. All changes are effective immediately upon posting. Your continued use of the Services after changes are posted constitutes your acknowledgement of the modified privacy policy and agreement to abide and be bound by that privacy policy. For reference, the effective date of this Policy is posted at the top of this page. Therefore, it is important that you periodically check this page for changes made to this Policy.

INFORMATION WE COLLECT

Surt may collect information about you when you interact with our Services including information that you voluntarily provide when you use the Services from one or more of your devices or otherwise interact with the Services. A description of the types of information we may collect is described in detail below.

  • Identifiers such as first name, last name, copy of government-issued ID, Social Security Number, date of birth, telephone number and postal address.
  • Internet and Other Electronic Network Activity such as internet protocol (IP) address, 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 used to access the Services.
  • Usage Data includes information about how users use the Services, such user's activity, time spent, user stats, referring/exit pages, and clickstream data.
  • Marketing and Communications Information such as marketing campaign data, click-throughs, user preferences and consent in receiving marketing communications, e-mails, phone, text, email and webchat communications.
  • Audio and Visual Information such as audio recordings, or selfie photograph or video.
  • Biometric Information such as a faceprint (i.e. face geometry of a person's facial features). See our Biometric Information Policy for additional details.
  • Geolocation Data such as precise geolocation data through GPS, Wi-Fi, wireless network triangulation, or other methods. We may also approximate your location using your IP address or wifi signal.

Information We Collect When You Use the Services

Automated technologies or interactions

As you navigate around the Site and/or use the Services, Surt may collect certain information using various technologies. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, time zone setting and location, language preferences, device type and ID, and other technical information from the devices you use to access our Services.

Cookies and Tracking Technologies

We and our service providers use cookies, pixels, and other tracking technology to recognize your browser or device and to capture and remember certain information about your activities on our Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features of the website may not function properly.

Analytics

We use third party analytics providers such as Google Analytics, to assist us in better understanding how users use our Services. These providers collect usage data, including IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our Site. In addition to reporting usage statistics, Google Analytics can also be used to help show more relevant ads on Google properties (like Google Search) and across the web. For more information on Google Analytics, visit Google's Privacy and Terms. You can access the Google Analytics Opt Out Browser Add-on, currently located here. You can also opt out of advertising cookies using the Google Ad Settings.

USE OF YOUR INFORMATION

Our primary purpose for processing your information is to provide our customers with the Services. We may also process your information for the following business purposes:

  • Provide our Services and to operate our business.
  • Verify your identity and account information in connection with our customer's Services.
  • Resolve disputes and/or questions about our Services.
  • Problem troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data.
  • Enforce our Terms for use of our Services and the terms of this Policy.
  • Customize, measure and improve our Services.
  • For our own internal business purposes.
  • Protect our interests, including establishing, exercising and defending legal rights and claims.
  • As necessary to comply with legal requirements, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities.
  • For purposes disclosed at the time you provide/we request your information or as otherwise set forth in this Policy.

INFORMATION WE SHARE

Customers

We share your personal information with our customers for the purpose of verifying your identity, preventing fraud, and complying with legal requirements.

Service Providers

We may use third-party service providers to perform certain business services and may disclose your information to such service providers as needed for them to perform these business services. Service providers include, but are not limited to, hosting services, account authentication and identity verification services, artificial intelligence model providers, geolocation, and risk/fraud providers.

Internal Third Parties

We may share your information with our parent, subsidiaries, affiliated entities, successors, predecessors, assigns, licensees, or business partners, and others who may use the information for the purposes described above.

Business Transactions

We may do business with 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 your information may be transferred to the new owners who may use your information in the same way as set out in this Policy.

Legal Process

Subject to applicable law, we may disclose information about you i) if we are required to do so by law, regulation or legal process, such as a subpoena; ii) in response to requests by government entities, such as law enforcement authorities; iii) when we believe disclosure is necessary or appropriate to prevent physical, financial, or other harm, injury, or loss; or iv) for the purposes of cooperation with law enforcement agencies' and/or in connection with an investigation of suspected or actual unlawful activity.

CHILDREN

The Services are intended for users aged eighteen (18) and older. If you are under the age of eighteen (18), you are not authorized to provide us with any personally identifying information, nor access or use our Services in any manner whatsoever. By using the Services, you represent that you are eighteen (18) years of age or older.

USE OF THE SERVICES

By accessing and using the Services, you acknowledge and agree that the Services are intended for use by users located in the United States of America. Unless expressly stated to the contrary, we make no representation that the Services are appropriate or will be available for use in other locations.

NOTICE TO CALIFORNIA RESIDENTS

Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for their own direct marketing purposes. Requests should be submitted via email to [INSERT] and should include CALIFORNIA PRIVACY RIGHTS in the subject line. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

Your 'Do Not Track' Browser Setting

Some web browsers incorporate a Do Not Track ("DNT") feature that signals to the websites that you visit that you do not want to have your online activity tracked. Our Site does not currently respond to DNT signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on the websites.

CONTACT INFORMATION

If you have any questions about our privacy practices or this Policy, please contact us at: contact@surt.ai.

BIOMETRIC INFORMATION POLICY

This Biometric Information Policy describes how Surt and its and its related, affiliated or subsidiary companies (collectively, "Surt") treat the photos and/or video images of your face, including scans of facial geometry extracted from those images (i.e. a faceprint), which may be considered biometric data in some jurisdictions.

Surt acts as a service provider or processor for our customers when providing identity verification and fraud prevention products and services ("Services"). In order to provide these Services, we may require you to provide a government issued identification and a photo or video selfie that contains an image of your face. Surt and/or our service providers, use artificial intelligence technology to analyse the identification and photographs / video you submit, and the device you use to submit the photographs and documents.

Consent

By using our Services, you consent to Surt and our contracted service providers, collecting, storing, and using your biometric information for the purposes identified below.

Purpose for Collection of Biometric Information

Surt and its services providers may use biometric information for the following purposes:

  • To verify your identity
  • To prevent fraud
  • To improve products and services
  • To comply with legal obligations

Data Retention

This information is retained no longer than 3 years after your last interaction with us, provided we have no other legal obligation to retain such information for any longer period.