Privacy policy clauses for Sumsub
Sumsub is a full-cycle KYC/AML (Know Your Customer/Anti-Money Laundering) identity verification platform that uses document analysis, biometric matching, and regulatory screening to verify user identities and assess compliance risk.
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What data Sumsub collects
Your privacy policy must disclose each of the following data types when you use Sumsub.
When does Sumsub trigger privacy obligations?
Sumsub integration triggers obligations the moment you begin collecting identity documents, selfies, and biometric face-matching data—even during testing. This is not a tracking pixel; it is regulated personal data collection.
GDPR (EEA users): Biometric data collection for identification purposes falls under GDPR Article 9 (special categories). You must have a lawful basis under Article 6 *and* a derogation under Article 9(2)—typically Article 9(2)(a) (explicit consent) or Article 9(2)(h) (employment/regulatory necessity). If you collect from anyone in the EEA, GDPR applies regardless of your location.
