Privacy Policy

Effective Date: 10/18/2023 


Securing data and protecting privacy is one of our top priorities at ITI. We understand you trust us to provide a frictionless experience, to keep your data safe, and to protect your privacy. Importantly, we will never sell or rent your personal information. We are transparent about what we know about you, how we protect that information, and how you engage with ITI from the very beginning, starting with our Privacy Policy below.  


Our Privacy Policy describes: 

  • The types of personal information we obtain 
  • How we may use personal information 
  • With whom we may share that information 
  • The choices available to you regarding our use of information 
  • The measures we take to safeguard your personal information, and  
  • How you can contact us about our privacy practices

The Information We Collect 

We obtain personal information about you through your use of the ITI Kiosk. 


The types of personal information we may obtain include: 

  1. Contact details (Such as name, email, postal address, and telephone number); 
  2. Physical characteristics (such as gender and height); 
  3. Government-issued identification information (such as Social Security number or other government-issued ID number) 
  4. Demographic information (such as race/ethnicity, age, eligibility to vote, etc.); 
  5. Biometric Data such as digital photographs (i.e., images of your face taken by the kiosk); 
  6. Information about your use of the ITI kiosk; 
  7. Payment information (collected by our third-party payment processor and thoroughly encrypted); 
  8. Information about your health (for determining use of visual aids such as eyeglasses and contact lenses, mental health; etc.); 
  9. Other information you may provide to us or authorize others to provide to us (such as shopping and language preferences). 

 How We May Use the Information We Obtain 


Biometric Data and Other Personal Information, Including Health Information 


We may use biometric data, health information and other personal information we obtain about you to: 

  1. Facilitate, manage, operate, and administer ITI’s kiosk functionalities; 
  2. Conduct routine ITI systems performance measurements; 
  3. Verify applicants’ and users’ identities, including authenticating users  
  4. Comply with and enforce applicable legal requirements and policies, including this Privacy Policy. 


With your express consent, we may also use information in other ways, such as when you choose to use a service or participate in a program we may offer jointly with another entity. 


 Non-Biometric and Non-Health Personal Information 

  1. Authenticate users of ITI’s services; 
  2. Verify and validate users against existing records; 
  3. Conduct routine ITI systems performance measurements; 
  4. Communicate with you and respond to your questions; 
  5. Detect fraud; 
  6. Operate, evaluate, and improve our business (including developing new products and services; analyzing our products and services; managing our communications; and performing accounting, auditing, and other internal functions) 


We may also use the information we obtain about you in other ways when we provide specific notice at the time of collection. 


Information We Share 


We never sell or rent personal information about you.  

We do not share or disclose personal information except as described in the privacy policy.  


Biometric Data and Other Personal Information, Including Health Information 

 With your explicit consent, we may share biometric data, health data, and other personal information we obtain about users with : 

  1. Government service providers (such as verification and data analytics); 
  2. Government Agencies; 
  3. Third Party Services; 
  4. Other government agencies, if required by law; 
  5. Other third parties with your express consent (such as when you choose to use a service or participate in a program that we may offer jointly with another entity). 


Non-Biometric and Non-Health Personal Information 

In addition to the disclosures described in Section 3.A above, we also may share non-biometric and non-health personal information (except for government-issued identification numbers and payment card and financial account numbers) we obtain about you with our verified service providers for the purposes described in Section 2.B of this Privacy Policy. 


Service Providers 

We contractually prohibit our service providers from using or disclosing our users’ personal information, other than to perform agreed services or comply with legal requirements. We require these service providers to appropriately safeguard the privacy and security of the consumer's personal information they collect, use, disclose or otherwise process for us. 


Disclosures for Other Purposes 

We may disclose information we obtain about you: 

  1. If law or legal process requires us to do so (such as a court order or subpoena); 
  2. In response to requests by government agencies (such as law enforcement authorities); 
  3. To establish, exercise, or defend our legal rights; 
  4. When we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; 
  5. In connection with an investigation of suspected or actual illegal activity; 
  6. Otherwise with your consent or at your direction. 


We reserve the right to transfer information we have about you if we sell or transfer all or part of our business or assets, as permitted or required by law. Should such a transfer occur, we will use reasonable efforts to direct the transferee to use the personal information in a manner that is consistent with this Privacy Policy. We also may share the information we obtain about you in other ways when we provide specific notice at the time of collection. 


Access and Correction 

We will provide a copy of the personal information we maintain about you upon your request as required by law. To help protect your privacy and security, we will take steps to verify your identity before granting access. If we deny an access request, we will notify you of the reasons for the denial and offer an opportunity to challenge our decision.  


If you believe the personal information we maintain about you is inaccurate, you may request that we edit the information by contacting us as indicated in Section 9 of this Privacy Policy. Please note that changes to your personal information may require us to reevaluate your eligibility for participation in ITI’s services and obtain new copies of government-issued identification documents or either of the foregoing. 


How We Protect Personal Information 

We maintain administrative, technical, and physical safeguards. These are designed to protect personal information against accidental, unlawful, or unauthorized: destruction, alteration, access, disclosure, or use.  


To safeguard certain sensitive information (such as biometric data and government-issued identification information), we implement security measures such as encryption, firewalls, and intrusion detection and prevention systems. 


In addition, some examples of security measures we use to safeguard personal information include: 

  1. Procedures for identifying and classifying personal information; 
  2. Implementing safeguards appropriate to the sensitivity of the information; 
  3. Access control procedures to verify business need before access to personal information is granted; 
  4. Procedures for the periodic review of access permissions; 
  5. Procedures for terminating access to personal information when there is no longer a business need for access; 
  6. Personnel security controls designed to reduce the risk of human error, theft, fraud, or misuse of facilities; 
  7. Physical and environmental security procedures designed to prevent unauthorized access, damage or interference to business premises and information;. 
  8. File Integrity and Change Detection monitoring to identify and protect against unauthorized modification of customer data; 
  9. Annual outside audits to ensure compliance with industry standards; 


In the unlikely event of a breach of ITI’s systems resulting in unauthorized access to your personal information, ITI will provide notice as required by law. While ITI has implemented privacy and security safeguards at every step of the kiosk user experience, please keep in mind that kiosks are located in public settings and ITI cannot guarantee the absolute privacy of the user experience at the kiosk. 


Retention of Personal Information  

You may request that we remove any personal information we maintain about you as provided by applicable law. To request the removal of your personal information, you may contact us as indicated in Section 9 of this Privacy Policy. Following the removal of your information, we may retain limited information to comply with your request to not be contacted in the future, unless otherwise required by law. 


Children’s Personal Information 

We recognize the importance of protecting children's privacy. We do not knowingly collect personal information of children under the age of 13. If you have a reasonable suspicion that we have collected data on an individual 13 years of age or younger, please contact us as per Section 9 below to have it removed. ITI kiosks are designed for use by individuals who are at least 17 ½ years of age. 


Updates to our Privacy Policy 

We may update this Privacy Policy periodically to reflect new ITI kiosk features or changes in our personal information practices. We will post a notice at the top of this Privacy Policy of any significant changes to this Privacy Policy. We will also state when this Privacy Policy was most recently updated. We will provide other notices to you as required by law. 


How to Contact US 

If you have any questions or comments about this Privacy Policy, any privacy-related concerns, or would like us to update information we have about you or your preferences, please contact us by calling us at: 866-563-0590 .  You also may write to us at: