Skyfire KYA Service Terms

1.1 Services

If you have registered for the Skyfire KYA Service then the following applies to you. You may choose to verify your identity and save your personal information submitted to us (“Identity Information“). The advantage of saving your Identity Information to, and verifying your identity with, Skyfire is that you or any software program or system that you authorize to conduct transactions on your behalf (your “Associated Agents“) can generate encrypted identity (and payment) authorization tokens (“Access Authorizations“) that enable you and your Associated Agents to speed up interactions with services that accept Skyfire Access Authorizations to verify your identity (“Connected Services“).

As part of the process of becoming a Verified User of the Skyfire KYA Service, you will be directed to one of Skyfire’s service providers that conducts certain user verification tasks for Skyfire (a “Verification Service Provider“). Our Verification Service Provider is currently Persona Identities, Inc., but we may use one or more other service providers for this function in the future. The Verification Service Provider will ask you to submit a photo of your government issued identity document, together with a selfie to: (i) verify the authenticity of the identity document and, (ii) confirm that you are the individual pictured in the identity document. The Verification Service Provider may also request additional information to corroborate identity details.

The Verification Service Provider will generate a verification result for Skyfire. You must successfully complete this verification check step to become Verified User of the Skyfire KYA Service. We do not receive your biometric information from our Verification Service Provider and we do not store your biometric information in your Skyfire account.

If you have any questions about the outcome of a verification check relating to you or your identity document, please contact us at [email protected]. It’s important to note that this Privacy Policy does not apply to our Verification Service Provider’s use of your personal data or its privacy practices and we encourage you to read their privacy policy for further information on their use of your personal data.

Use of your Identity Information is managed by you. The Identity Information stored in your Skyfire account is not readable by Skyfire in its encrypted form, and can only be unencrypted when you (or your Associated Agent) generates and sends an Access Authorization to a Connected Service and the Connected Service authenticates and unencrypts the information contained in the Access Authorization.

When you submit an Access Authorization to a Connected Service, the Connected Service will have access to any Identity Information contained in the Access Authorization. The Connected Service will hold the information you submit under the Connected Service’s privacy policy, and not this Skyfire Privacy Policy.

Skyfire may also collect, store and use additional metadata relating to your Identity Information, including but not limited to IP address, device ID, and how often you generate and use Access Authorizations, for the purposes of security and fraud prevention (“MetaData“). MetaData is stored separately from your Identity Information.

If you want to delete your Identity Information from the Skyfire KYA Service, you may do so by sending an email to [email protected]. If you choose to delete your Identity Information from Skyfire, please note that any Connected Services that you have submitted Access Authorizations to in the past may still have your Identity Information. If you would like to request the Connected Service to delete any copies of your personal data they obtained through Access Authorizations you submitted to them, please contact the Connected Service directly.

Skyfire will be the controller of your personal data provided to, or collected by or for, or processed in connection with the Skyfire KYA Service. Skyfire will seek your consent to process and share your personal information via the Skyfire KYA Service and will process your data in compliance with our Privacy Policy at www.skyfire.xyz/privacy-policy.

1.2 Your responsibilities

By agreeing to these Skyfire KYA Service Terms, you represent and warrant (promise) that you:

• Allow Skyfire to act on instructions we receive from you, including the generation of Access Authorizations that contain Identity Information;

• Are the person identified in your government identification documents submitted for verification;

• Have the right to provide any information you share with us in connection with the Skyfire KYA Service, and that this information is accurate and up-to-date;

• Are over 18 years old; and

• Will comply with all other applicable local, state, national and foreign laws, treaties, regulations and conventions that relate to your use of the Skyfire KYA Service.

Any access to or use of the Skyfire KYA Service by anyone under 18 years of age is expressly prohibited. By accessing or using the Service, you represent and warrant that you are 18 years old or older.

1.3 Restrictions

By agreeing to these Skyfire KYA Service Terms, you promise that you will NOT use the Skyfire KYA Service for any purpose which is not authorized by Skyfire (including commercial or competitive purposes). In particular, you must NOT:

• Falsely claim to be someone else (except where you are establishing identify on behalf of another person with their specific lawful authority);

• Falsely claim that you are associated with someone else;

• Collect information about the Skyfire, or the Skyfire KYA Service without Skyfire’s written consent;

• Modify, frame, render (or re-render), mirror, truncate, inject, filter or change any content or information contained in the Skyfire KYA Service, without Skyfire’s written consent; or

• Circumvent any measures implemented by Skyfire aimed at preventing violations of these Skyfire KYA Service Terms.

2.1 Fees

You agree to pay Skyfire the Skyfire KYA service fee (as set forth on the Skyfire Pricing Page at www.skyfire.xyz/pricing). Skyfire reserves the right to impose or revise fees for the Skyfire KYA Service at any time. If Skyfire introduces a new fee, or increases a fee, for the Skyfire KYA Service, then Skyfire will notify you at least 30 days before the new or revised fee applies to you.