What personal data is processed, and how is it used?

‍At Cleverli Solutions Limited, we conduct due diligence checks, including background checks on politically exposed persons, sanctions, adverse media, and identity and document verification, to help mitigate potential compliance risks.

The checks we undertake mean that, depending on what our partners have requested, we could process the following aspects of your data:

Name data – your first, middle and last names, as well as any previous names and any aliases you regularly use;
Birth data – your date of birth, your country of birth, your nationality and any other nationalities and citizenships that you have;
Contact data – your telephone numbers and email address;
Residential data – your residential address and previous addresses for the number of years that our customer requires;
Financial data – your employment status, how much you earn, as well as proof of your income;
Identity data – an image of your identity document showing your picture, the issue and expiry dates, the official reference number, the type of document it is and the country of issue;
Address verification data – an image of a document showing your residential address, the type of document it is and the date of issue; and
Video data – a short recording of you which you initiate and where you follow automated instructions that may involve speaking during the recording.

The data we use to complete the process may be provided by you, our partners, or a combination of both.

‍Through a combination of AI and review by Cleverli Solutions Limited analysts, the above data is used for the following purposes:
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‍To undertake background checks on you, which include checking for adverse media against publicly available sources, undertaking sanctions screening against a range of sanctions lists, assessing whether you are a politically exposed person and assisting our partner in understanding whether there are any other fitness and probity issues which they may wish to consider;

To undertake social media and internet checks on you, which means that we will analyse your social media and other online presence to identify potential risks;
To carry out proof of life checks to validate your identity;
To ensure the identity and address verification documents you have provided are authentic and legitimate, and
To help our partner stay informed of any change in your status or reputation in the media.When our checks are completed, our partner will receive a report with all of the personal data provided for our checks.

The report will also include the results of any screening that we have carried out and our reasons for discounting any screening results, where applicable.
The report will contain a link to the video data and a snapshot of the video as a still image of you.

‍Where is the data stored?

‍All of the data that we process about you is held in a UK data centre. The data that we hold is all of the data that is input by you or our partner for the purposes of our partner's KYC process, as well as the results of our analysis including the video of you and the report we issue to our partner.

‍Who can see your data?

Our partner will be able to see all of the data you input and the resultant report.
Our analysts will be able to see your personal data for the purposes of undertaking the screening when requested by our partner so that our data remediation process can be completed. Access to your data by the analysts is subject to access logs, and any access to your identification documentation images and video recordings is logged separately.

If an issue needs to be resolved, members of our IT team who are responsible for the smooth running of our systems may see your data.

We may also have to share your data with a law enforcement agency if we are required to do so.

‍Do we use your data for marketing purposes?

‍We will not use your data for marketing purposes, and we will not provide your data to any third party so that they can market their products or services to you.

‍How long do we keep your data?

‍We will maintain records and data to comply with our statutory, legal, and regulatory responsibilities and what we deem to be reasonable practice where no record-keeping period is set down in law or other rules.

We will destroy data in line with these retention periods. Our commencement date for any retention period will typically be when the report has been made available to our partner or when our monitoring of the customer ceases as requested by our partner.

If you have specific queries concerning retention periods, please email dpo@cleverli.com for more information.

‍What are your rights?

‍If you wish to see the data processed about you by Cleverli Solutions Limited, please email the Data Protection Officer at dpo@cleverli.com.

‍Isle of Man residents

‍Under the Isle of Man data protection legislation, you have additional rights, such as the right to rectification of incomplete data and the right to erasure of data. You also have the right to receive the personal data you provide to us in a structured, commonly used, and machine-readable format and to transmit this data to another controller without hindrance from us.

If you wish to exercise any of these rights, please email the Data Protection Officer at dpo@cleverli.com.

If you wish to make a complaint about how we have processed your data, please email the Data Protection Officer at dpo@cleverli.com.

You can also contact the respective Information Commissioner at:

United Kingdom: ico.org.uk
‍Isle of Man: 01624 693260 or by emailing ask@inforights.im