Bhutan NDI Privacy Policy

One of our (“our”, or “ours”) main beliefs is privacy. The amount of data we (“we” or “Bhutan NDI”, or the “Company”) gather on you (also known as “you” or “Customer”) whether you use our website, applications (including web and mobile), APIs, or other cloud-based services that we host on your behalf (the “Services”) is kept to a minimum.

In this document, “digital credential” refers to an equivalent of the physical, paper-based credential like your driving license card. “Personally Identifiable Information”, “PII”, or the “Personal Data” in this document refers to individual data inside your digital credential or the collection of more than one digital credential that is used to uniquely identify you.

We may gather some data in order to connect with you and enhance the Services. The collection, use, and sharing of your personal data in connection with the Services are covered by this privacy policy (the “Policy”).

Legally Binding Contract —As a basic principle, no data is processed by Bhutan NDI when the app is used. All data is stored only on your end device and Bhutan NDI has no access to this data when: (i) you use Bhutan NDI infrastructure to access a website or a web application; (ii) you use NDI infrastructure to authenticate or access mobile applications and online applications; and use any services or systems that the NDI ecosystem may be utilized to provide services. We do not store any digital credentials tied to you, inside our database server. Any digital credentials stored inside Bhutan NDI Wallet, digital credential issued by verified issuers, including the digital credential issued by the foundational issuer is in your absolute custody.

Notwithstanding clause a. Information Collection, Bhutan NDI may allow specific third-party clients to use the deviceID linked to your use of Bhutan NDI applications. These third-party clients may utilize your deviceID to improve service delivery and fortify security measures. Your deviceID will not be used for tracking or targeting you with advertisements. To secure your privacy and data security, any use of the deviceID by third-party clients will be carried out in compliance with our stringent privacy rules and any data protection regulations.

Legally Binding Contract —Bhutan NDI Wallet collects selfie face data and session video of yours to determine liveness to crossmatch with the reference face data. The reference face data resides at the Ministry of Home Affairs, Royal Government of Bhutan. The face matching is done to establish that you are actually the truthful person that you are claiming to be. The face data utilized for liveness detection or face match is not stored in any of our database servers. A copy of the face data (selfie) is stored securely on your mobile device for ‘Forgot PIN’ functionality available in the Bhutan NDI Mobile Wallet. The ‘Forgot PIN’ functionality is used for resetting the PIN to your Bhutan NDI Wallet in case you have forgotten your PIN. During the ‘Forgot PIN’ process, your new selfie is matched against this stored copy. This data is not accessible to any other apps on your mobile device.

Legally Binding Contract —The digital credentials stored inside Bhutan NDI Wallet (at the end-user device) are not accessible either in encrypted format or in plain text to NDI Admin or a third party. The digital credentials once issued by verified issuers are not stored in their database as well. This means that the digital credentials are not stored in any location except inside your Bhutan NDI Wallet. When you avail services, you present your digital credentials from the NDI Wallet to the verified verifiers willingly, and present the digital credentials that are required and nothing more.

Legally Binding Contract —During the face matching session for onboarding or restoration of Bhutan NDI Wallet, the face data from the mobile is compared in real-time against reference images that you may have provided to the Ministry of Home Affairs, Royal Government of Bhutan within the Bhutan NDI Premise. No face data is stored or cached on the server side. A copy of your selfie is securely stored in the mobile app (KeyChain) in base64 encoded format.

Legally Binding Contract —Notwithstanding paragraph a. Digital Credentials, your digital credentials may be stored (encrypted and sharded) in the cloud servers upon your consent. This however is done with privacy taken at the forefront of our OFFERINGS and no digital credential is stored in a manner that is readable to the NDI Admin, the cloud service providers or any third parties. In order for you to agree to our wallet backup and restoration scheme, you are required to read, understand and agree to our NDI Wallet Backup and Restoration Policy presented to you when onboarding to the NDI Wallet.

Legally Binding Contract —When you initially onboard the Bhutan NDI Wallet, you will be required to enter your data, including your biometric information (face data) to cross match with the reference data from a valid source like Ministry of Home Affairs, Royal Government of Bhutan. The cross matching is performed at Foundational Credential issuer service. Once the foundational credential issuer confirms the accurate presentment of your data by you, a foundational credential will be issued to you, and all your data stored at the foundational credential issuer will be deleted. This means that the foundational credential is no longer stored anywhere other than in your Bhutan NDI Wallet.

Legally Binding Contract —When you avail other services using the foundation credential, you will be presenting only the digital credential (or a part of the digital credential) that is requested by the party (issuer and verifier) providing the service. Once the party issues a new digital credential or verifies the digital credential, no digital credential issued or verified will be stored in the party’s database except for the cryptographic keys linking you to your digital credential.

Legally Binding Contract —You will be asked to follow instructions to capture images at different angles during the collection of face data for the purpose of cross matching your face data with the one that you may have provided to the Ministry of Home Affairs, Royal Government of Bhutan. An AI based liveness detection technique uses biometric parameters which includes texture analysis, depth and shape of an image, and facial movement to determine that you are a living person. This is done at the client side and no face data is retained for this purpose.

Legally Binding Contract —The Company does not have access to any of your PII and won’t be in position to recover your PII, unless you read, understand and agree to NDI Wallet Backup and Restoration Policy.

Legally Binding Contract —During the initial onboarding process or restoration from backup, to establish the identity of the user, your face data (selfie) is captured on the client side (mobile app) and sent to the server for further processing on the server side. The selfie is matched with the one that you may have provided to the Ministry of Home Affairs, Royal Government of Bhutan.

Legally Binding Contract —The face data is retained in the user’s mobile app until the app is uninstalled. However you should also know that no face data is stored anywhere on the server side.

Legally Binding Contract —We do not collect any analytics information from your hardware device, software applications or your usage pattern to target you with advertisement or for any other purposes.

Legally Binding Contract —Bhutan NDI does not share any of your PII data to any third parties. It is under your absolute custody and control to share your PII data to any services that you consume utilizing Bhutan NDI Wallet.

Legally Binding Contract —The face data utilized by Bhutan NDI Wallet is not shared to any third parties as the biometric service is hosted within the Bhutan NDI premise. In fact, the face data used for establishing the Foundational Identity of the user will not be accessible to Bhutan NDI Admin as well.

Legally Binding Contract —Bhutan NDI does not, by any intentional means disclose any of your PII data to any third parties.

Legally Binding Contract —Bhutan NDI does not disclose your face data to any third parties.

Legally Binding Contract —Bhutan NDI takes stringent security measures to protect your digital credentials, including the use of three levels of authentication in the NDI wallet: (i) biometric authentication using facial recognition technology while onboarding to the Bhutan NDI Wallet; (ii) biometric authentication using facial recognition technology while completing a transaction of digital credential; and (iii) use of PIN authentication to complete the transaction of digital credential. On top of that, the Company has put governance policies and regulations to address your rights and responsibilities in the NDI Governance Framework.

These measures are taken to ensure the following:

1. to safeguard User Information;
2. to maintain privacy, security, confidentiality and processing integrity of your digital credentials;
3. to protect from hazards; and
4. to provide access control measures.

Legally Binding Contract —If you choose the Backup Service, you are required to abide by and agree to NDI Wallet Backup and Restoration Policy for backup and restoration purposes of your Bhutan NDI Wallet.

Legally Binding Contract —The Company does not warrant against unauthorized third parties ever being able to circumvent Company security measures or misuse User Information. If any User Information that the Company has in its custody or under its control is compromised due to a security breach, the Company will promptly notify you, in full detail, and will launch an exhaustive investigation into the matter.

Legally Binding Contract —We consider your participation in the NDI ecosystem voluntary and any losses, claims, liabilities, or other causes of action that emerge from a security breach will not subject the Company to responsibility.

Legally Binding Contract —If your Personal Data is incorrect or lacking, you have the right to have it fixed at the relevant source.

Legally Binding Contract —You have the right to refuse to share certain Personal Data with us and the right to request the deletion or removal of your Personal Data for any reason. Your ability to use and access our websites, applications, goods, and Services may be hampered if you choose to exercise either of these rights, though, since many functionalities depend on your Personal Data to work properly.

Legally Binding Contract —Any Personal Data that you retain may be used again for your own purposes.

Legally Binding Contract —You have the right to object to the use of your Personal Data under specific conditions. This includes when your Personal Data is used for purposes like direct marketing, historical and scientific research, or the accomplishment of a task in the public interest, when such use has an effect that has a bearing on your legal status, or when such use is for an automatic decision-making process that has an effect that is materially different from how you use our websites, apps, products, or services. Since your data is in your own custody, you have the absolute right to provide consent for processing and other purposes.

Legally Binding Contract —Please contact us if you have any queries that aren’t answered by this privacy statement or if something seems to be violating your rights as outlined above.

Legally Binding Contract —Our services are only intended for use by adults and/or people who have reached the legal age of majority and are not addressed to minors or people who are younger than the legal age of majority in their respective countries.

Please do not submit any information through our Services or other offers if you are under the age of eighteen, unless your parent or legal guardian has given their approval.

Legally Binding Contract —This Policy may be updated from time to time. If we make any significant changes, we may let you know through the Services, by prominently publishing a notice of the changes on the Site, or by contacting you through your account.

Legally Binding Contract —Any modifications to this policy will take effect fifteen (15) calendar days after either we send you a notice of them or we post a notice of them on our website, whichever comes first. New users of the Services will instantly be affected by these changes.

Legally Binding Contract —Following notification of changes to this Policy, your continued use of the Services constitutes your acknowledgment and acceptance of those changes and your agreement to be governed by the revised Policy.

Legally Binding Contract —The above-mentioned date marks the most recent change to this policy. Prior to voluntarily providing any User Information, please read this policy carefully.