Privacy policy

This policy explains how FusedFrames Technologies Ltd (“we”, “us”), the controller of your personal data, collects and uses it when you use the Check Twice app and our website, check-twice.com. Our Biometric policy explains how we handle images of your face.

Who we are

FusedFrames Technologies Ltd is registered in England and Wales (company number 17097980), at 23 King Street, Suite 191, Cambridge CB1 1AH, United Kingdom. It is also registered with the Information Commission (ICO) under registration number ZC195987. You can contact us about your data at legal@fusedframes.com.

What we collect and why

To sign up, you must give us your phone number, a scan of your face and your photo ID. Without them you can’t use Check Twice. For each use below we give our legal basis under data protection law.

Your account

We keep your phone numbers and text you codes, such as to sign in, add a phone number or delete your account. For each phone you sign in on, we keep its model, its language, an address for sending it notifications and codes that keep your account secure. We also keep when you last used Check Twice, and what you agreed to and when.

We use these to run your account, sign you in, send you texts and notifications about your account and keep it secure. If you add or ask for a phone number that someone else on Check Twice holds, we tell them, and tell you if it becomes free where we can. We never share your phone number, or your agreement to our texts, with anyone for their own marketing or messages.

Legal basis: to provide Check Twice to you (our contract with you).

Verifying your identity

When you sign up, you take a live scan of your face and photos of your photo ID, and the app reads your passport’s chip if it has one. We use these to check that you are a real person, that you match a genuine photo ID in your name, that you are 18 or over and that your photo ID is not already used on Check Twice.

From this we keep one photo of your face (your face photo), the name printed on your photo ID, the kind of photo ID and the country that issued it, whether its chip was read and a one-way code made from its number, which can’t be turned back into it. We delete the rest when the check ends, including photos of your photo ID, the data on its chip or barcode, your date of birth, your address and your photo ID’s number.

Legal basis: your explicit consent to these checks, which we ask for before your first scan, and our contract with you. After the check, we keep that code in our legitimate interests in preventing fraud, such as duplicate accounts.

Checking it’s you

Before some actions, such as signing in on a new phone, deleting your account or using Retake face photo, you take a quick photo that we compare with your face photo. Your face photo may be replaced by a later photo you take in the app. Some checks, such as Reverify, also ask for your photo ID. The face photo others see is the one from your sign-up, or from your last sign-in on a new phone, Reverify or Retake face photo, and we keep it for that.

Legal basis: your explicit consent and our contract with you.

Using Check Twice

• Contacts: if you allow it, the app turns the phone numbers in your contacts into codes on your phone to show which of them are verified. Names never leave your phone and we never upload your contacts. We keep which verified people each of your phones has saved. When someone you have saved joins, your phone can tell you, by the name you saved them under. You can turn this off in the app.
• Requests: when you ask someone to verify, or someone asks you, we keep who asked whom, when and the result.
• Links: when you make a link, we keep its name and notes, what it shows, the phone numbers of anyone you limit it to, when it was opened and who opened it in the app.
• Blocks, hides and reports: we keep whom you block or hide your verification from, reports others make about you and any report you make, with your reason and words.
• Invites: we keep your invite code, who you named as your inviter and who named you.

Legal basis: our contract with you. We review reports and suspend accounts in our legitimate interests in keeping people safe and preventing fraud.

Help, feedback and leaving

If you use Report an issue or Give feedback, we keep what you write and any photos you add. If you answer “Why did you leave?”, we keep your answer but not who gave it. If you test a beta of Check Twice, we receive your email address and any feedback you send through TestFlight or Google Play.

Legal basis: our legitimate interests in helping you and improving Check Twice.

Analytics

Our servers record how people use Check Twice, such as which steps they finish, under a code instead of your name or phone number. We record your phone’s system, which kind of photo ID you used and whether its chip was read, but never your name, phone numbers, face, anything else from your photo ID or anything you type. Once you’re verified, you can turn this off at any time with Share analytics, in Account, then Security & privacy. Before then, email legal@fusedframes.com.

Legal basis: our legitimate interests in understanding how Check Twice is used, so we can improve it.

Our website

• Contact form: your name, email address, any company and website you give, the topic you choose and your message, so we can reply.
• Get notified: your email address, so we can tell you when Check Twice launches, until we do or you unsubscribe.
• Visits: the pages you open and your network address, to show you the website and protect it from attacks and automated abuse. Analytics cookies only if you accept them (see Cookies). If you open an invite link, we count that it was opened, without knowing who you are.

Legal basis: our legitimate interests in replying to you and running our website, and your consent for Get notified and analytics.

Keeping Check Twice working and secure

When something goes wrong in the app or on our website, we receive a report of what went wrong, with details such as the app’s version and your phone’s model and system (or, on our website, your browser), but never your name, phone numbers, face or photo ID. Apple and Google also pass us crash reports when your phone is set to share them, and software from Google in the app sends Google figures about how it runs, never images. We use your network address and keep records to protect accounts and stop fraud and abuse.

Legal basis: our legitimate interests in keeping Check Twice working and secure. Where the law requires us to keep or share data, our legal basis is that legal obligation.

What other people see

• Your contacts: people on Check Twice who have your phone number, and whom you have saved, see that you are verified, your full name as printed on your photo ID, your face photo, the kind of photo ID you verified with, whether its chip was read, when you were last verified and how many people you have helped protect. They also see when you aren’t signed in on any phone. With “Anyone with my phone number” on, anyone on Check Twice with one of your phone numbers sees the same. When you join, people you have saved who have you saved too can be told you joined.
• Your choices: you can hide your face photo from people you choose, one at a time, or from everyone by turning on Hide face photo. With it on, you can still show it to people you choose. Anyone it’s hidden from sees that it’s hidden. You can also hide that you’re verified from people you choose, who then see you as unverified. If you turn on Show impersonation warning, everyone who can see you’re verified sees it. You can change these at any time.
• Invites: if you name who invited you, we may tell them someone they invited is verified, and give your name only if they can already see you’re verified.
• Requests: the person who asked you to verify sees the result, and the person you ask sees your name.
• Links: whoever opens a link you make in the app sees your full name, your face photo, how you verified and anything else you chose to show on it. You can choose Hide face photo for each link. You see when it was opened, and who opened it only if Check Twice shows them as verified in your Contacts. If you open someone else’s link, they may see that you did.

We can’t control what people do with what you show them, such as taking a screenshot.

Legal basis: our contract with you.

If you are not on Check Twice

We may process your phone number if someone on Check Twice has it in their contacts, limits a link to it, blocks it or hides their verification from it. If someone tries to add your phone number to their account, we text it a code. A phone number in contacts becomes a code on their phone, and we keep nothing of it unless you are on Check Twice. We keep a phone number a link is limited to until the link is deleted, and the code of a phone number someone blocks or hides from until they undo it. If you open a link from “Verify them on another phone”, we tell the person the link was made for that it was opened, compare your face with their face photo, tell the person who asked the result and delete the images when the check ends. If you sign in with a phone number that belongs to someone on Check Twice, we compare your face with theirs in the same way.

Legal basis: our legitimate interests, and those of the person who has your phone number, in running Check Twice; for comparing your face, your explicit consent, which we ask for before the camera starts. To object, contact us.

Decisions made automatically

Some decisions are made without a person: whether you are a real person, whether your face matches, whether your photo ID is genuine and in your name, whether you are 18 or over, whether your photo ID is already in use or barred and whether a check was made in our genuine app. They decide whether you can join or pass a check. If you think one is wrong, contact us. A person at FusedFrames will review it, consider what you tell us and reply in writing.

Who we share it with

• Service providers that run Check Twice for us, under contracts that require them to protect your data as this policy does. They are listed on our Subprocessors page. Apple and Google also use some of this data for their own purposes, under their own privacy policies (Apple’s, Google’s), which also cover your use of their phones and app stores.
• Authorities and others where the law requires it, or where needed to protect someone’s safety, prevent fraud or deal with legal claims.
• A new owner if FusedFrames is reorganised, sold or merged, who must protect your data as this policy says.

We never sell your personal data or use it for targeted advertising, and we don’t use it to train artificial intelligence, including large language models. We don’t let anyone track you across other websites or apps through Check Twice.

Where your data is processed

We store and process your data in the United States, and emails you send us in Switzerland. Some service providers, such as Cloudflare, handle data in other countries on its way to and from us. When your data leaves the UK, it is protected by UK adequacy regulations, including the UK-US data bridge where the recipient is certified to it, or otherwise by the UK’s International Data Transfer Agreement or Addendum. You can ask us for a copy of these safeguards.

How long we keep it

• Your account, phone numbers and name: until you delete your account.
• Records of what you agreed to: for as long as you have an account, then 6 years, to show what you agreed to.
• Your face photo and the one others see: until you delete your account, even while you hide it. If you don’t use Check Twice for 24 months, we delete them and tell you a month before. Your account stays, but you won’t show as verified until you Reverify.
• Other images from a check: until the check ends.
• An unfinished sign-up: 30 days.
• Your photo ID’s one-way code: with your account. If we suspend or close an account for breaking our terms, until we lift the suspension or for up to 3 years, even after the account is deleted.
• What we report to the authorities: if we report illegal content, what was reported and related account details, for as long as the law requires.
• Your phones’ details: until you sign out of that phone or delete your account.
• Which verified people your phones have saved: until you sign out of that phone or delete your account. We keep your last signed-in phone’s list after you sign out, until you sign in again or 24 months after you last use Check Twice, so your contacts still see you’re verified.
• Requests, results, alerts and when a link was opened: 90 days. A result someone received about you stays with them for those 90 days, even if you delete your account.
• Links, blocks, hides, invites and what you show or hide: until you remove them or delete your account.
• Reports, issues, feedback and reasons for leaving: until we have reviewed them, then 90 days.
• Codes we text you: until they are used, or for a short time if they aren’t.
• Analytics: up to 7 years, under a code. Ask us before you delete your account and we will delete them too.
• Messages you send us, including beta feedback: up to 2 years.
• Error reports and security records: only as long as needed to fix problems and protect Check Twice.

Deleted data, other than biometric data, can stay in our encrypted backups for a short time until they are replaced, and we may keep it longer where the law requires it or to deal with a legal claim. We keep biometric data only as our Biometric policy says.

How we protect it

We encrypt your data in transit and when stored, encrypt sensitive data such as your phone numbers and face photo with our own keys and limit who at FusedFrames can access personal data, keeping a record when they do.

Your rights

You have the right to:

• access your data and get a copy of it;
• correct it (your name comes from your photo ID, so to change it, Reverify with your updated photo ID);
• have it deleted;
• restrict how we use it;
• receive it in a format you can take elsewhere;
• withdraw your consent at any time, without affecting what we did before;
• ask a person to review a decision made automatically.

Your right to object: you can object at any time to us using your data in our legitimate interests, including for analytics, by turning off Share analytics or contacting us.

We give these rights to everyone who uses Check Twice. You can change what you show, turn off Share analytics and remove phone numbers in the app. You can delete your account in the app (Account, then your name, then Delete account, under Leave) or at check-twice.com/delete. Because Check Twice can’t work without images of your face, withdrawing your consent to them ends your account. If you can’t take a quick photo, email support@fusedframes.com and we will delete your account once we have confirmed it’s you.

For anything else, email legal@fusedframes.com. We may need to confirm it’s you, and someone you authorise can ask for you. We may withhold information that would reveal someone else’s personal data, such as who made a report. We reply within one month, and tell you if we need longer.

Cookies

Our website uses:

• Essential storage, which needs no consent: to remember your region, display choices and cookie choice, to keep your place in a check and to protect our forms from automated abuse.
• Analytics cookies, only if you accept: PostHog sets one cookie, kept for a year, to show us how visitors use the website. We treat Global Privacy Control as a refusal. You can change your choice at any time in Cookie settings, at the bottom of our website’s pages.

The app stores on your phone only what it needs to work, such as your sign-in and settings. It has no advertising code.

Children

Check Twice is only for people aged 18 or over. If a photo ID shows someone is under 18, we stop the sign-up and delete what they gave us.

If you live in the US

Where your state’s privacy laws apply:

• You can access, correct, delete and get a copy of your data, and opt out of its sale, targeted advertising and profiling. We don’t sell your data or use it for targeted advertising.
• We use your biometric data, with your consent, and the details from your photo ID only to verify your identity, prevent fraud and show your verified card, except that our analytics record which kind of photo ID you used and whether its chip was read. We never use them to infer anything else about you.
• If we turn down your request, you can appeal by replying to our decision or emailing legal@fusedframes.com. We will answer within 45 days. If you are still unhappy, you can contact your state’s attorney general.
• We don’t respond to Do Not Track signals, as there is no common standard for them.
• We won’t treat you differently for using your rights.
• If you live in Washington, our Washington consumer health data privacy policy also applies.

Changes to this policy

We update this policy when Check Twice or the law changes. We will tell you by text or in the app before any significant change takes effect. The date at the top shows when it last changed.

Contact and complaints

Email legal@fusedframes.com, use our contact form or write to us at the address in “Who we are”. You have the right to complain to us first: we acknowledge every complaint within 30 days and reply in writing. You can also complain to the Information Commission, the UK regulator, at ico.org.uk.