Effective Date: 22 January 2021
Date Last Updated: 15 December 2021
If you are a California resident, please click here for more information about your specific privacy rights.
If you are in the European Union, please click here for more information about your specific privacy rights.
If you are in another territorial region, please refer to Sections 16 to 19 of this Notice for more information about your specific privacy rights.
Daon is a privately held software company that has pioneered methods for securely and conveniently combining biometric and digital identity capabilities with large-scale deployments that span payments verification, digital banking, wealth, insurance, telecommunications, and securing borders and seamless travel. Daon creates products to help manage identities in six continents, across the full digital identity lifecycle including onboarding, authentication and recovery. Throughout the world, Daon has developed identity assurance software that allows government and commercial enterprises to establish trust that someone is who they claim to be.
The Daon VeriFly Application (“Application”) is a smart digital wellness passport that allows real-time verification of COVID-related credentials such as health questionnaires and diagnostic test results on your mobile device.
Daon understands that you entrust us with your personal information with the expectation that it will be used only for specific purposes. We respect your expectation and place a high priority on protecting this information by limiting its use. At Daon, protecting your privacy is fundamental to the way our company and its subsidiaries conduct our business.
This Privacy Notice (Notice) applies only to the personal information collected by the Application both within the Application and when accessing services online, through Daon’s websites. In the U.S. this Privacy Notice is provided by Daon Inc, in Europe it is provided by Daon Technology and in Asia and Australia it is provided by Daon (Australia) Pty Ltd., Inc (“Daon,” “us,” “we,” or “our”). We collect and process information about you as described in this Privacy Notice ("Notice"). We are committed to protecting the privacy of those with whom we interact. This Notice contains details about how we collect, use, and share Personal Information that we obtain from and about you when you use the Application to represent you have completed all COVID-related travel requirements and streamline the process for boarding certain airline carrier’s international flights. This Notice does NOT apply to any other interactions you have with Daon or the Application, such as if you provide information to obtain other passes through the Application. Please read this Notice carefully.
As part of the Application, we offer individuals a traveller verification service for air travel with certain airline carriers to destinations with COVID-19 travel restrictions. We do not warrant or otherwise guarantee that you will be able to travel to your intended destinations; that the information and data provided to us by you or on your behalf is true and accurate; or that you will not be exposed to COVID-19 when receiving arranged COVID-19 laboratory testing services, at airports, during air travel, or at your intended destination. We do not provide medical advice or services or laboratory services. Individuals with health disorders, medical conditions, or any condition requiring medical supervision, or who receive COVID-19 test results, assume full responsibility for obtaining professional medical assistance. Consult your physician or qualified health care professional regarding any symptoms, medical conditions or test results.
Without limiting anything else herein, we specifically disclaim any express or implied warranties or merchantability of fitness for any particular usage, application or purpose for the traveller verification service, and make no representations with respect to the accuracy, reliability, completeness, timeliness or usefulness of such information. You understand that the traveller verification service depends on the information provided by you or on your behalf. Without limiting anything else herein, we reserve the right to treat such information as true and accurate, and you shall be solely responsible for such information, including its accuracy. We shall not be liable to you or anyone else for any loss or injury caused in whole or in part by procuring, compiling, delivering or reporting such information through the Application. In no event, shall we be liable to you or anyone else for any decision made or action taken or not taken by you or anyone else in reliance on such information available through the Application. At all times, you remain fully responsible for ensuring you satisfy all travel requirements set by your airline carrier and your destination country.
Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing Personal Information about another individual, you represent that you are authorized to share the other individual’s Personal Information and your interactions and exchanges comply with applicable data protection laws. Whenever you interact with us on behalf of a minor, such as by providing or accessing Personal Information about a minor, you represent that you are authorized to act in the capacity of a parent or guardian of the minor and consent to the processing of the minor’s Personal Information, including Protected Class information, such as health information, and the transfer of their Personal Information out of its originating country to a third party country for the purpose of providing the services in our Application. Full details of the location where data will be transferred can be found in Section 20 below. You shall have sole responsibility for any violation of privacy laws as a result of a failure to inform the other individual about how their Personal Information will be processed or to obtain any necessary consent from such individual.
We may update this Notice from time to time. The current Notice will be effective when posted. Please check this Notice periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Notice by posting an update on this page. When required under applicable law, we will seek affirmative consent from you before making material changes to the way we handle Personal Information previously collected from you. If you do not provide such consent, Personal Information will continue to be used in a manner that is consistent with the version of this Notice under which it was collected.
For the purposes of this Notice Daon Technology is the controller for the personal information we process, unless otherwise stated. For all data protection enquiries and/or concerns in connection with your EU privacy rights please contact our Data Protection Officer at privacy@daon.com or any of the other ways to contact us at Section 13 as might apply to you.
Your Airline Carrier is the controller of any US CDC Passenger Disclosure Attestation data, where applicable, which will be processed in accordance with your Airline Carrier’s privacy policy and as provided for herein.
Personal Information refers to any information relating to an identified or identifiable natural person or household.
We collect information about you and how you interact with us in several ways, including:
We may combine information that we receive from the various sources described in this Notice and use or disclose it for the purposes identified below.
The types of information that we may collect about you are:
We may use each category of your information described above in the following ways:
We may share your Personal Information with the categories of recipients described below:
We may also de-identity, anonymize, or aggregate Personal Information to share with third parties for any purpose as legally permissible.
In order to provide you with the services in our Application, your personal data, including health data, may be transferred out of your originating country to a third party country. Full details of the location where data will be transferred can be found in Section 20 below.
We also collect (and may permit third parties to collect via our Application or website) information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access our Application or website, the pages you accessed while visiting our Application or website, and the Internet address from which you accessed our Application or website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our Application, website and/or services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and to personalize online content. These cookies and other technologies may be used to track you across devices and across other apps or websites over time.
To provide you with more relevant and interesting experience, we may work with third party companies to display ads or customize the content on the Application or website and on other apps or websites. These companies may use cookies and similar tracking technologies as described in this Notice to gather information about your visits to the Application or website, as well as your visits elsewhere on the Internet. These companies use this information to provide you with more relevant advertising known as interest-based advertising. For more information about third-party advertisers and how to prevent them from using your information, please visit http://www.networkadvertising.org/choices/. This is a site offered by the Network Advertising Initiative ("NAI") that includes information on how consumers can opt-out from receiving interest-based advertising from some or all of NAI's members. The Digital Advertising Alliance (“DAA”) offers a choice mechanism with respect to certain types of data collection and use by third parties available at www.aboutads.info. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.
Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honour DNT signals from website browsers at this time. However, you may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.
We maintain reasonable security procedures and technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, disclosure, alteration, or use.
We will retain your personal information, for no longer than is necessary to enable you to use the Application, unless we need to keep your information to comply with applicable legal, regulatory, or other obligations, or the information is required for business reasons (such as to resolve disputes, provide service and enforce agreements). In any event, we will retain your information for the period stated in our retention schedule on our website, at which point Daon will take steps to securely and permanently dispose of your personal information, according to applicable laws and regulations.
Interactions with us are intended for individuals 18 years of age and older. Our interactions are not directed at, marketed to, nor intended for, children under 18 years of age. We aim to ensure, though we cannot guarantee, that personal information relating to children is not inadvertently provided to us by taking reasonable measures to establish data quality. If you suspect that personal information relating to a child aged less than 18 who is under your parental control or guardianship has been provided to us, please report this to us by using one of the Contact methods at Section 13 below. In all cases where we may inadvertently be provided with personal information relating to children, the information in the relevant parts of this Notice applies to children, as well as adults.
When interacting with us you may encounter links to external sites or other online services, including those embedded in third party advertisements or sponsor information, that we do not control. We are not responsible for the privacy practices and data collection policies for such third-party services. You should consult the privacy statements of those third-party services for details.
If you have questions regarding this Notice, please contact us at:
To opt-out of receiving promotional email messages from us, please click on the "Unsubscribe" link contained at the bottom of each email or by contacting us using the information above.
This Section applies only to California residents whose information is subject to the California Consumer Privacy Act and supplements the information provided above.
Sources of Personal Information
The categories of sources of Personal Information are detailed in Section 6 above.
Uses of Personal Information
The business and/or commercial purposes for which we collect Personal Information are detailed in Section 7 above.
Sharing Personal Information
The categories of third parties to whom we disclose Personal Information for a business purpose are detailed in Sections 7 and 8 above and summarized below.
|
Categories of personal information (as described in Section 6 above) |
Categories of Third Parties to which we disclose personal information for a business purpose |
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Identifiers |
· Affiliates and subsidiaries · Third party service providers · For legal, security and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure |
|
Payment and fraud detection informations |
· Affiliates and subsidiaries · Third party service providers · For legal, security and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure |
|
Personal information subject to the California Consumer records Act |
· Affiliates and subsidiaries · Third party service providers · For legal, security and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure |
|
Protected class and demographic information |
· Affiliates and subsidiaries · Third party service providers · For legal, security and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure |
|
Commercial information and preferences |
· Affiliates and subsidiaries · Third party service providers · For legal, security and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure |
|
Internet or other electronic network activity information |
· Affiliates and subsidiaries · Third party service providers · For legal, security and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure |
|
Auditory, electronic, visual, thermal, olfactory, or similar information |
· Affiliates and subsidiaries · Third party service providers · For legal, security and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure |
California Consumer Privacy Act Rights
Subject to legal limitations, certain California residents may exercise the following rights by emailing us at privacy@daon.com or by writing us at 4097 Monument Corner Drive, Suite 550. Fairfax, VA 22030.
You may submit a request to exercise your Californian privacy rights to us by using any of the contact methods at Section 13 as might apply to you. We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.
When making a request, please provide the following information:
Verification: In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we will need to independently verify each member of the household. For a Specific Pieces Report, we will request Personal Information sufficient to verify your identity to a reasonably high degree of certainty and will seek a signed declaration, under penalty of perjury, that you are who you say you are. In most cases, we will seek to match at least three data points to information we already have about you for this verification process. For a Categories Report or a Request to Delete, we will request Personal Information sufficient to verify your identity to a reasonable degree of certainty. In most cases, we will seek to match at least two data points to information we already have about you for this verification process.
In certain circumstances, we may require additional or different data in order to verify your identity. If you make a request (1) for a Specific Pieces Report, (2) as an authorized agent, or (3) on behalf of a household, we will contact you via email following your initial request to obtain information specifically needed for your type of request.
Authorized Agents: Authorized agents may exercise rights on behalf of consumers. If you are an Authorized Agent, we will request proof from you that you are authorized to act on behalf of the consumer (such as a written and signed authorization from the consumer) and may also seek to verify the consumer as described above, or we will accept a legal Power of Attorney under the California Probate Code. We will also require evidence of your (the agent's) identity and proof of registration with the California Secretary of State.
Timing: We will respond to Requests to Delete and Requests to Know within 45 calendar days, unless we need more time, in which case we will notify you and may take up to 90 calendar days total to respond to your request.
California Shine the Light: If you are a California resident, you may opt out of sharing your Personal Information with third parties for the third parties' direct marketing purposes. Please contact us at privacy@daon.com if you would like to do so.
Pursuant to the EU General Data Protection Regulation (GDPR) below is specific information which relates to the processing of personal information of data subjects who are in the EU. This section references relate to the sections above in this Notice.
Purpose of Processing
The business and/or commercial purposes for which we process personal information are detailed in the Section 7 and are part of the following general purposes: (a) performing services, (b) auditing, (c) legal and compliance, (d) quality assurance, (e) security, (f) debugging, (g) short term, transient use, (h) internal research, and (i) corporate transactions.
If we intend to process your personal information for any additional purpose(s), we will provide you with information on the other purpose(s) and seek your prior consent.
Legal Basis
The legal basis for the processing of your personal data is one of the following:
Please note that the provision of personal information is a requirement of the contract you entered into with us when downloading the Application and is necessary to enable us to provide our services to you through the Application. Where you have provided your consent for us to process your personal information, you have the right to withdraw your consent at any time.
The legal basis for the processing of your Protected Class Information is as follows:
Sharing Personal Information
The categories of third parties to whom we disclose personal information for a business purpose are detailed in the Section 8 and are summarized as follows: (a) affiliates and subsidiaries, (b) third party service providers, (c) legal, safety, and security, (d) corporate transactions, (e) with third parties from whom you seek credentials, and (f) otherwise with your consent.
Transfer of Personal Information
We store your data within the European Economic Area/European Union. Personal information of EEA Citizens may be processed by Daon Inc. in the U.S., Daon (Australia) Pty Ltd. in Australia, and Daon Ltd. Belgrade in Serbia for the purpose of providing customer service and support and to enable us to provide our services to you through the Application. Full details of data transfers out of originating country can be found in Section 20.
Appropriate safeguards are in place via standard data protection clauses adopted by the EU Commission signed between Daon Inc., Daon (Australia) Pty Ltd. and Daon Ltd Belgrade with Daon Technology which will be provided on request. If we share your personal data with external third parties outside of the EEA, we use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the GDPR. However, any transfer of your data out of the EEA may result in access to this data by local public authorities for monitoring purposes or public health, as permitted under local surveillance or public health laws.
Data Retention
We will retain your personal information, for no longer than is necessary to enable you to use the Application, and to comply with our legal obligations, resolve disputes, enforce our agreements and for other business reasons permitted by applicable laws and regulations. In any event, we will retain your information for the period stated in our retention schedule, at which point Daon will take steps to securely and permanently dispose of your personal information, according to applicable laws and regulations.
Data Subject Rights
If you wish to access, correct, delete or update your personal information, restrict or object to processing or exercise a right to data portability (where technically feasible) please refer to the functionality available within the Application on the user profile page or email us at privacy@daon.com. We will respond to reasonable requests in accordance with relevant data protection laws.
Automated Individual Decision-Making
If you choose to share a government Digital COVID Certificate with us, or for your health test laboratory to share your health information with us directly, you consent to our use of individual automated decision making using your special category health data, to determine whether you have met the travel health requirements for your travel destination. If you do not consent or would like to obtain human intervention, please select the alternative method in the Application to provide your COVID health information.
Compliance
We work to high standards when it comes to processing your personal information. If you have any queries or concerns about our approach to protecting your information, we welcome the opportunity to make things right for you and encourage you to contact us by one of the methods at Section 13.
If you are not satisfied with our response, you have the right to lodge a complaint with your national data protection authority.
For the purposes of relevant data protection laws and regulations applicable across Europe, Middle East, and Africa (EMEA) region excluding the European Union (EU), below is specific information which relates to the processing of personal information of data subjects located in countries where the Application is available. This section references relate to the sections above in this Notice. The information provided at Section 15 above applies to individuals in EMEA unless otherwise specified with respect to named countries below.
16.1. Israel
Pursuant to the Protection of Privacy Law and associated Regulations the privacy rights outlined at Section 15 above apply to individuals in Israel subject to the specific information below which exclusively relates to the processing of personal information of data subjects who are in Israel. This section references relate to the sections above in this Notice.
Legal Basis
The legal basis for the processing of your personal data is one of the following:
The legal basis for the processing of your Protected Class Information is as follows:
Data Subject Rights
If you wish to access or to correct your personal information, please refer to the functionality available within the Application on the user profile page or email us at privacy@daon.com. We will respond to reasonable requests in accordance with relevant data protection laws.
Transfer of Personal Information
We store your data within the European Economic Area/European Union. Personal information of Israeli Citizens may be processed by Daon Inc. in the U.S., Daon (Australia) Pty Ltd. in Australia, and Daon Ltd. Belgrade in Serbia for the purpose of providing customer service and support and to enable us to provide our services to you through the Application. Full details of data transfers out of originating country can be found in Section 20.
Appropriate safeguards are in place via derogations such as obtaining your consent, or relying on contractual performance or necessity to establish, exercise, or defend legal claims or other legal mechanisms designed to protect your personal data to standards equivalent to Israeli data protection law, such as entering into a data processing agreement with the recipient of your data abroad.
16.2. Switzerland
Pursuant to the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection applicable in Switzerland at the time of writing, Section 15 applies to Swiss data subjects in its entirety subject to the following provision.
Data Subject Rights
If you wish to access, correct, delete or update your personal information, or restrict or object to processing please refer to the functionality available within the Application on the user profile page or email us at privacy@daon.com. We will respond to reasonable requests in accordance with relevant data protection laws.
Pursuant to the Personal Information Protection and Electronic Documents Act (PIPEDA) the privacy rights outlined at Section 15 above apply to individuals in Canada subject to the specific information below which exclusively relates to the processing of personal information of data subjects who are in Canada. This section references relate to the sections above in this Notice.
Legal Basis
In addition to Section 15, we may rely on the following legal basis for the processing of your personal data:
The legal basis for the processing of your Protected Class Information is as follows:
Data Subject Rights
If you wish to access, correct, delete or update your personal information, or restrict or object to processing please refer to the functionality available within the Application on the user profile page or email us at privacy@daon.com. We will respond to reasonable requests in accordance with relevant data protection laws.
Transfer of Personal Information
We store your data within the European Economic Area/European Union.
Personal information of Canadian individuals may be processed by Daon Inc. in the U.S., Daon (Australia) Pty Ltd. in Australia, and Daon Ltd. Belgrade in Serbia for the purpose of providing customer service and support and to enable us to provide our services to you through the Application. Full details of data transfers out of originating country can be found in Section 20.
Appropriate safeguards are in place via standard data protection clauses adopted by the EU Commission signed between Daon Inc., Daon (Australia) Pty Ltd. and Daon Ltd. Belgrade with Daon Technology which will be provided on request. If we share your personal data with external third parties outside of the EEA we use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries in order to ensure equivalent levels of protection of your personal information.
Compliance
We work to high standards when it comes to processing your personal information. If you have any queries or concerns about our approach to protecting your information, we welcome the opportunity to make things right for you and encourage you to contact us by one of the methods at Section 13.
If you are not satisfied with our response, you have the right to lodge a complaint with the relevant national data protection authority depending on the province where you are located, including the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner of Alberta, Office of the Information and Privacy Commissioner for British Columbia, and the Quebec Information Access Commission.
Pursuant to applicable laws and regulations across the countries in the Asia-Pacific (APAC) region where the Application is available, the privacy rights outlined at Section 15 above apply to individuals located in these countries subject to the specific information below which exclusively relates to the processing of personal information of data subjects who are in APAC. This section references relate to the sections above in this Notice. The Application is not currently available in, and our interactions are not directed at, marketed to, nor intended for citizens of, China or South Korea. The primary applicable laws and regulations for countries where the Application is available in APAC include, but are not limited to:
Legal Basis
The legal basis for the processing of your personal data is one of the following, depending on the purpose of processing it in accordance with applicable laws and regulations in the respective countries where the Application is available in the APAC region:
Please note that the provision of personal information is a requirement of the contract you entered into with us when downloading the Application and is necessary to enable us to provide our services to you through the Application. Where you have provided your consent for us to process your personal information, you have the right to withdraw your consent at any time.
Where the specific country where you are located recognises the concept of Protected Class Information or equivalent, the legal basis for processing such information about you is one of the following, in accordance with applicable laws and regulations:
Transfer of Personal Information
We store your data within the European Economic Area/European Union and may need to disclose your personal information to data processors in accordance with Section 8 above.
We store your data within the European Economic Area/European Union. Personal Information of individuals who are located in the APAC region may be processed by Daon Inc. in the U.S., Daon (Australia) Pty Ltd. in Australia, and Daon Ltd. Belgrade in Serbia for the purpose of providing customer service and support and to enable us provide our services to you through the Application. Full details of data transfers out of originating country can be found in Section 20.
Appropriate safeguards are in place via standard data protection clauses adopted by the EU Commission signed between Daon Inc., Daon (Australia) Pty Ltd. and Daon Ltd. Belgrade with Daon Technology which will be provided on request. If we share your personal data with external third parties outside of the EEA we use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries in order to ensure equivalent levels of protection of your personal information.
Data Subject Rights
Depending on the specific APAC country where you are located, you may be able to exercise a range of rights in connection with your personal information. The privacy rights available to you under applicable laws and regulations are listed below for each country within the APAC region where the Application is available.
If you wish to exercise your privacy rights, please refer to the functionality available within the Application on the user profile page or email us at privacy@daon.com. We will respond to reasonable requests in accordance with relevant data protection laws.
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APAC Country |
Data Protection Rights Available |
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Australia |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Right to withdraw consent · Control access to, and request erasure of health records regulated by the My Health Record Act · Right to lodge a complaint with data protection authorities |
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New Zealand |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Right to lodge a complaint with data protection authorities |
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Hong Kong |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Right to lodge a complaint with data protection authorities |
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Japan |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Limited right to erasure of personal data · Limited right to restrict data processing · Limited right to lodge a complaint with data protection authorities in respect of 'My Number’ social security and tax identification data Please note that data subjects can only request erasure of personal information, discontinuation of data processing, or discontinuation of transfer of personal information when its processing by the organisation is found to be unlawful. |
Pursuant to applicable laws and regulations across Latin American and Caribbean countries and territories where the Application is available, the privacy rights outlined at Section 15 above apply to individuals located in these countries or territories, subject to the specific information below which exclusively relates to the processing of personal information of data subjects who are present in Latin America, including Central and South America and the Caribbean regions. This section references relate to the sections above in this Notice.
Legal Basis
The legal basis for the processing of your personal data is one of the following:
Please note that the provision of personal information is a requirement of the contract you entered into with us when downloading the Application and is necessary to enable us to provide our services to you through the Application. Where you have provided your consent for us to process your personal information, you have the right to withdraw your consent at any time.
The legal basis for the processing of your Protected Class Information is as following:
Transfer of Personal Information
We store your data within the European Economic Area/European Union. Personal Information of individuals who are located in Latin America or the Caribbean may be processed by Daon Inc. in the U.S., Daon (Australia) Pty Ltd. in Australia, and Daon Ltd. Belgrade in Serbia, for the purpose of providing customer service and support and to enable us to provide our services to you through the Application. Full details of data transfers out of originating country can be found in Section 20.
Appropriate safeguards are in place via standard data protection clauses adopted by the EU Commission signed between Daon Inc., Daon (Australia) Pty Ltd. and Daon Ltd. Belgrade with Daon Technology which will be provided on request. If we share your personal data with external third parties outside of the EEA we use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries in order to ensure equivalent levels of protection of your personal information. Where mandated by applicable laws and regulations, we will request you to expressly provide your consent prior to effecting a transfer of your personal information outside the country where you are located.
Data Subject Rights
Depending on the specific country or territory where you are located in Latin America or the Caribbean you may be able to exercise a range of rights in connection with your personal information. The privacy rights available to you under applicable laws and regulations are listed below for each country within Latin America and the Caribbean where the Application is accessible.
If you wish to exercise your privacy rights, please refer to the functionality available within the Application on the user profile page or email us at privacy@daon.com. We will respond to reasonable requests in accordance with relevant data protection laws.
|
Country |
Data Protection Rights Available |
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Costa Rica |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Right to erasure of personal data |
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Guatemala |
· Right to grant consent prior to the transfer or commercialisation of data subjects' personal data · Right to consent regarding the use of data subjects' personal data · Right to rectify inaccurate or incomplete personal data · Other rights that the Constitutional Court deems worthy of protection |
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Honduras |
n/a |
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Mexico |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Right to erasure of personal data · Right to object to/opt-out of processing personal data · Right to withdraw consent · Right to restrict processing |
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Nicaragua |
· Right to request information about personal data · Right to rectify, modify, complement, or update personal data · Right to erasure of personal data |
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Panama |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Right to erasure of personal data · Right to data portability · Right to object to/opt-out of processing personal data |
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El Salvador |
· Right to access personal data · Right to reasonable control of the transmission or distribution of personal information |
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Argentina |
· Right to access personal data · Right to rectify inaccurate or incomplete personal data · Right to erasure of personal data · Right to withdraw consent |
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Brazil |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to restrict data processing · Right to data portability · Right to object to the processing of personal data · Right to withdraw consent · Right to request that personal data be anonymized · Right to lodge a complaint with the data protection authority |
|
Chile |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to restrict data processing · Right to withdraw consent · Right to object to the processing of personal data |
|
Colombia |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to restrict data processing · Right to withdraw consent · Right to object to the processing of personal data |
|
Ecuador |
· Constitutional right to privacy · Constitutional right to access personal information · Right to confidentiality of health data per sector- specific laws |
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Guadeloupe |
n/a |
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Guyana |
n/a |
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Peru |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to restrict data processing · Right to withdraw consent · Right to object to the processing of personal data |
|
Uruguay |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to withdraw consent |
|
Antigua |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete |
|
Aruba |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete |
|
Bahamas |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to restrict or object to processing for direct marketing purposes |
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Barbados |
n/a |
|
Bermuda |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to ‘block’ (restrict) processing |
|
Cayman Islands |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to ‘block’ and ‘stop’ (i.e. restrict and object to) processing · Right to compensation for failure to comply |
|
Cuba |
n/a |
|
Curaçao |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data |
|
Dominican Republic |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to erasure of personal data · Right to object to/opt-out of processing for direct marketing purposes |
|
Grenada |
n/a |
|
Haiti |
n/a |
|
Jamaica |
n/a |
|
Martinique |
n/a |
|
Puerto Rico |
n/a |
|
St. Kitts & Nevis |
n/a |
|
St. Lucia |
· Right to access the data subject’s own personal data · Right to rectify/correct the data subject’s own personal data where inaccurate or incomplete · Right to prohibit processing of personal data for direct marketing purposes |
|
St. Martin |
· Right to access the data subject’s own personal data |
|
St. Vincent |
n/a |
|
Trinidad & Tobago |
· Right to not have personal information collected, used or disclosed unless the data subject has provided consent; · Right to access their information and challenge any organisation on compliance with the privacy Principles; · Right to challenge an organisation's compliance with the Principles and receive timely and appropriate engagement from the organisation; and · Right to lodge a complaint with the Commissioner if their request for access to their personal information is denied. |
|
Turks & Caicos |
n/a |
Note that the countries marked by “n/a” as ‘not applicable’ have not implemented data protection legislation that has entered into force at the time of writing.
In some instances, we may need to transfer your data from the originating country to a third-party country for processing. In this case we will request you to expressly provide your consent prior to effecting a transfer of your personal information. The location of this transfer will depend on your originating country as well as the purpose for processing your data. The table below provides full details of the countries where your data will be transferred, depending on your originating country:
|
Originating Country/Region |
Data transfer |
Type of personal data (which may include Health Data) |
Purpose of transfer |
|
E.U. |
Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
Daon Ltd. Belgrade in Serbia |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
California |
Daon Technology in Ireland and Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
E.U. |
All Data |
Data Hosting |
|
|
E.U. or USA |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
USA |
Daon Technology in Ireland Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
E.U. |
All Data |
Data Hosting |
|
|
E.U. or USA |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
EMEA (Non-E.U.) (excluding: Ukraine, Czech Republic, Belarus, Serbia, Norway, Moldova, Bosnia and Herzegovina, Albania, North Macedonia, Montenegro, Iceland, Andorra, Monaco, Liechtenstein, San Marino, Channel Islands, Isle of Man, Faroe Islands, Gibraltar, Israel, Switzerland, Russia |
Daon Technology in Ireland, Daon Inc. in the USA, Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
E.U. |
All Data |
Hosting |
|
|
E.U. or USA |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
Ukraine, Czech Republic, Belarus, Serbia, Norway, Moldova, Bosnia and Herzegovina, Albania, North Macedonia, Montenegro, Iceland, Andorra, Monaco, Liechtenstein, San Marino, Channel Islands, Isle of Man, Faroe Islands, Gibraltar, Israel, Switzerland, Russia |
Daon Technology in Ireland Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
Daon Ltd. Belgrade in Serbia |
Health Data |
Health Data Review |
|
|
E.U. |
All Data |
Hosting |
|
|
E.U. |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
Canada |
Daon Technology in Ireland Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
Daon Ltd. Belgrade in Serbia |
Health Data |
Health Data Review |
|
|
E.U. |
All Data |
Hosting |
|
|
E.U. |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
APAC (excluding Australia New Zealand Hong Kong Japan) |
Daon Technology in Ireland Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
E.U. |
All Data |
Hosting |
|
|
E.U. or USA |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
Australia New Zealand Hong Kong Japan |
Daon Technology in Ireland Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
Daon Ltd. Belgrade in Serbia |
Health Data |
Health Data Review |
|
|
E.U. |
All Data |
Hosting |
|
|
E.U. |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
Latin America (excluding Costa Rica) |
Daon Technology in Ireland Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
E.U. |
All Data |
Hosting |
|
|
E.U. or USA |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
Costa Rica |
Daon Technology in Ireland Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
Daon Ltd. Belgrade in Serbia |
Health Data |
Health Data Review |
|
|
E.U. |
All Data |
Hosting |
|
|
E.U. |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |
|
|
Caribbean |
Daon Technology in Ireland Daon Inc. in the USA Daon (Australia) Pty Ltd. in Australia Daon Ltd. Belgrade in Serbia |
Customer Service & Support Data |
Customer Service & Support |
|
All Data (excluding Passenger Disclosure Attestation to USA where applicable) |
Technology Development |
||
|
E.U. |
All Data |
Hosting |
|
|
E.U or USA |
Health Data |
Health Data Review |
|
|
Your Airline Carrier where they are located |
Travel Requirement Confirmation (including Passenger Disclosure Attestation to USA where applicable) |
Confirmation that traveler meets the requirements to travel |