Privacy Notice

Who we are

Cognau (an Altailab product) provides liveness verification, a short camera check that confirms a live human is present, and separately, identity document verification. An organization can use either on its own. The two are described separately below because they collect different things and keep them for different lengths of time. Contact for anything in this notice: [email protected].

Two roles apply. When you complete a verification inside another organization's product, that organization is the controller and Cognau is its processor. For this website, and for anything you send us through it, Cognau is the controller.

Verification sessions

• What: live video of your face during the check, signals derived from it, basic device and connection information (browser type, screen properties, IP address), and the verification result.
• Why: to verify that a live human is present and to protect the check against fraud. The analysis is automated, and you are informed of this at the time of the check; no verification runs without your explicit consent given on the consent screen.
• Legal basis: your explicit consent (GDPR Art. 9(2)(a)) for biometric processing; legitimate interest for fraud-prevention signals that are not biometric.
• How long: the video itself is never stored. If you do not complete the check, everything captured is deleted within 24 hours. If you do complete it, a small number of still images are kept alongside the result for up to a year, so the organization you verified with can review the check. The session record that remains (the result, the scores, and the device and connection information above) is kept for the duration of our contract with that organization. The full schedule, including the optional opt-in face template, is published in our Biometric Data Policy.

We never collect your name, government ID, or address during a liveness check, we do not compare your face against any database unless you explicitly opt in to re-recognition, and we never sell personal data. A liveness check on its own never involves an identity document. If the organization also asks you to verify a document, that is the separate check described next, and it is told to you before it begins.

Identity document verification

This is a separate service from the liveness check. It runs only when the organization you are verifying with has switched it on, and you are told before it starts. An organization can use either check on its own, or both together.

• What: images of the identity document you present (both sides, where the document has two) and the personal data printed on it, which typically includes your name, date of birth, document number, issuing country and expiry date. We do not compare the portrait on your document against your face.
• Why: so the organization can establish who you are, usually because it is legally required to.
• Legal basis: the organization's, not ours. It decides that the check is necessary and instructs us to carry it out. Comparing the portrait on a document against the person's face would be biometric processing and would rest on explicit consent (GDPR Art. 9(2)(a)). The screen shown before a document check does not ask for that consent, so the comparison is not part of the service and is off for every organization. If we ever offer it, the consent screen will ask you first, and this notice will change before it does.
• Who decides: the organization's own staff review the document and make the decision, and we provide an initial automated signal to assist them. We do not decide the outcome. An organization may separately choose to have a clear-cut automated recommendation applied without a person reviewing it; that is off unless they ask for it, it is their decision rather than ours, and where it is on you have the right to ask for human intervention, to express your point of view, and to contest the result (GDPR Art. 22(3)).
• How long: one year from submission by default, and the organization can set a different period, because identity records are commonly subject to legal retention periods measured in years. Either way, document data is not covered by the schedule that applies to liveness checks. To find out the period that applies to you, ask the organization you verified with, or contact us and we will pass your request to them.

This website

If you send us a request through the deletion request form we store what you submit (an email address to reply to, the organization you verified with, roughly when, and any reference you quote) together with the IP address and browser user-agent of the submission. We use it to handle your request and nothing else, and a closed request is deleted 90 days after we close it. What survives is an audit record that a request with that reference arrived and was closed, with no contact details in it.

We previously ran a waitlist form on this site. It has been retired: accounts are created directly on the dashboard now, and that signup is covered by the dashboard's own terms. Submissions made to the old waitlist are still held and are still covered by this notice and by your rights below.

Analytics and cookies. This site uses a self-hosted, cookie-free analytics service to count page views, and Google Analytics, which sets cookies in your browser and shares aggregate usage measurement with Google. Neither is used on the verification screen itself, and neither receives biometric data. You can block both with any standard tracker-blocking extension or browser setting.

Who processes data for us

We use a small number of infrastructure providers (hosting, databases) and, for this website only, analytics providers including Google, under contracts that require confidentiality and compliance with applicable data-protection law. A current list of sub-processors is available on request at [email protected].

Changes

We'll update this page and its “last updated” date before any material change takes effect.