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TRUstiks Privacy Policy

Effective date: 10.09.2026 Last updated: 10.09.2026 This Privacy Policy explains how personal data is processed in connection with TRUstiks, an age verification service provided by CAV Solution OÜ.

1. Who We Are

Service: TRUstiks Website: trustiks.com Service provider: CAV Solution OÜ Registry code: 16135498 Linda tn 2 20309 Narva Estonia In this Privacy Policy, “TRUstiks”, “CAV Solution”, “we”, “us” and “our” refer to CAV Solution OÜ. Privacy contact: support@trustiks.com

2. About TRUstiks

TRUstiks provides age verification services for businesses operating websites, online services, e-commerce platforms, payment terminals, vending systems, self-service terminals and other supported applications. Depending on the Verification method selected by the Customer, TRUstiks may determine whether an End User satisfies a required age threshold by using:

• facial age estimation;
• identification document analysis;
• face-to-document comparison;
• or a combination of supported verification methods.

TRUstiks is designed to minimise the amount of personal information disclosed to the Customer. For normal automated integrations, including API, terminal, website and plugin integrations, the Customer receives only an age-verification decision: APPROVED or REJECTED. Personal data extracted from an identification document is not automatically transmitted to the Customer's website, terminal, point-of-sale system or other external application.

3. Who This Privacy Policy Applies To

This Privacy Policy applies to:

End Users

Individuals who undergo an age Verification through TRUstiks.

Customers and Distributors

Businesses and organisations that use TRUstiks and persons authorised to manage their TRUstiks accounts.

Website and Dashboard Users

Persons who visit trustiks.com or use the TRUstiks Dashboard.

4. Data Protection Roles

The data protection role of CAV Solution depends on the processing activity.

4.1. Age Verification

Where a Customer uses TRUstiks to verify the age of an End User, the Customer generally determines:

• why age verification is required;
• where the Verification is performed;
• the required age threshold;
• and what happens following an APPROVED or REJECTED result.

In such circumstances, the Customer generally acts as the data controller and CAV Solution acts as a data processor processing personal data on behalf of the Customer. The processing relationship between CAV Solution and Customers may additionally be governed by a Data Processing Agreement.

4.2. CAV Solution's Own Processing

CAV Solution may act as an independent controller where it determines the purpose of processing, including for:

• TRUstiks account administration;
• billing and payments;
• service security;
• prevention of fraud and abuse;
• compliance with legal obligations;
• management of its business;
• communications with Customers;
• and other processing necessary for CAV Solution's own legitimate business operations.

5. Information Processed During Verification

The information processed depends on the Verification method used.

6. Facial Age Estimation

Where facial age estimation is used, TRUstiks may temporarily process:

• an image or video frame containing the End User's face;
• an age estimate generated by the age-estimation system;
• confidence or technical information generated by the age-estimation system;
• information necessary to determine whether the configured age threshold has been satisfied.

Facial age estimation is intended to estimate age. It is not intended to determine the End User's exact date of birth or identify the End User against a general population database. Where no identification document is used, the Age displayed in the TRUstiks Dashboard represents an estimated age generated from facial analysis.

7. Identification Document Processing

Where document-based Verification is used, TRUstiks may temporarily analyse an image of an identification document. The document-processing system may technically recognise information contained in the document. TRUstiks applies data minimisation immediately during this process.

7.1. Information That May Be Retained

TRUstiks retains only the following document-derived information:

• date of birth;
• document type;
• document issuing country;
• document expiry date.

TRUstiks may also retain a boolean indication showing whether a document number was successfully detected. For example: Document number found: Yes The document number itself is not retained.

7.2. Information That Is Not Stored

The following information is discarded during processing and is not stored in the TRUstiks database or application logs:

• first name;
• last name;
• identification document number;
• nationality;
• Machine Readable Zone (MRZ) data.

Where such information is technically recognised during OCR processing, it is discarded instead of being written to persistent storage.

8. Face-to-Document Comparison

Where the Verification method includes both a live face and an identification document, TRUstiks may compare the face captured during Verification with the photograph contained in the identification document. The system generates a comparison result such as: Matched or Not matched. The purpose of this processing is to determine whether the person undergoing Verification corresponds to the person depicted in the identification document. TRUstiks does not use this functionality to search for the End User in a general facial-recognition database. Where such processing constitutes biometric processing under applicable data protection law, the Customer is responsible for ensuring that an appropriate legal basis and, where required, an applicable condition under Article 9 GDPR exists for the processing.

9. Information Returned Through the API

TRUstiks separates the automated Verification decision from information visible to authorised users in the Dashboard. For standard API, terminal, web, plugin and other automated integrations, the Verification result returned to the Customer is: APPROVED or REJECTED. The automated Verification response does not provide the Customer's external system with:

• facial images;
• identification document images;
• age;
• estimated age;
• date of birth;
• document type;
• document country;
• document expiry date;
• document number;
• name;
• surname;
• nationality;
• MRZ information;
• OCR data;
• detailed face-comparison data.

Technical protocol or error information may additionally be exchanged where necessary for operation of the integration, but it is not intended to disclose additional identity information about the End User.

10. Information Available in the Customer Dashboard

Authorised Customer and Distributor users may manually access a limited summary of their own Verifications through the TRUstiks Dashboard. The Verification result panel may contain:

Face

Matched or Not matched This field is displayed only where face-to-document comparison was performed. It is not displayed for face-only age estimation.

Age

Age expressed in completed years. Where an identification document was used, Age is calculated from the date of birth extracted from the document. Where only facial age estimation was used, Age represents an estimate generated by the facial age-estimation system.

Status

For example: Approved or Rejected.

Created

The time at which the Verification began.

Completed

The time at which the Verification was completed.

11. Information Not Available to Customers and Distributors

Customers and Distributors cannot access the following information through their Dashboard or standard API:

• date of birth;
• document type;
• document issuing country;
• document expiry date;
• identification document number;
• first name;
• last name;
• nationality;
• MRZ data;
• raw OCR data;
• facial images;
• identification document images.

These restrictions are enforced on the server and database level. The information is not merely hidden in the Dashboard interface. Customer and Distributor accounts do not receive these restricted fields from the TRUstiks server and therefore cannot obtain them through browser developer tools or direct access to the standard Customer API.

12. Super Administrator Access

Certain retained Verification information may be accessible to specifically authorised TRUstiks Super Administrators for internal operational purposes. During the applicable retention period, such information may include:

• date of birth;
• document type;
• document issuing country;
• document expiry date;
• age;
• confidence information;
• indication that a document number was detected;
• face-comparison result;
• Verification status;
• Verification decision;
• relevant technical information.

Restricted Verification data is protected by access controls. Customer and Distributor roles do not have direct access to raw Verification records. Access to restricted data is intended only for legitimate internal purposes such as:

• technical diagnostics;
• troubleshooting;
• service operation;
• investigation of processing problems;
• security;
• fraud and abuse investigation;
• support;
• internal audit;
• compliance.

Where retained personal data is stored in encrypted form, encryption is used as an additional security control. Encrypted personal data remains personal data under applicable data protection law.

13. Retention of Facial and Document Images

Facial images and identification document images are stored only temporarily. They are automatically deleted no later than 15 minutes after the Verification. Images are not retained as part of the permanent Verification history. The deletion process is automatic and does not require action by the End User or Customer. Customers and Distributors cannot access these images through the Dashboard or standard API. TRUstiks does not maintain a permanent database of End User facial photographs or identification document photographs.

14. Retention of Document-Derived Information

The following document-derived fields may be retained for up to 90 days following a Verification:

• date of birth;
• document type;
• document issuing country;
• document expiry date.

After 90 days these fields are automatically removed from the Verification record. Deletion is performed by an automated scheduled retention process. After the fields have been removed, TRUstiks may retain an indication that the retention process was performed, including the date on which the information was removed. This allows TRUstiks administrators to distinguish an intentionally cleaned record from missing or corrupted data.

15. Verification Information Retained After 90 Days

After the 90-day document-data retention period, TRUstiks may continue to retain a minimised Verification record. This may include:

• Verification identifier;
• Customer identifier;
• Device identifier;
• Verification start time;
• Verification completion time;
• age at the time of Verification;
• age-estimation or recognition confidence information;
• boolean indication that a document number was detected;
• face-comparison result where applicable;
• Verification status;
• APPROVED or REJECTED decision;
• relevant technical processing information.

These records do not contain:

• facial images;
• identification document images;
• first name;
• last name;
• identification document number;
• nationality;
• MRZ data;
• date of birth after expiration of the 90-day retention period;
• document type after expiration of the 90-day retention period;
• document issuing country after expiration of the 90-day retention period;
• document expiry date after expiration of the 90-day retention period.

TRUstiks currently retains these minimised Verification records as part of the historical service record for operational, statistical, security, billing and service-management purposes. CAV Solution periodically reviews the categories of information retained and may introduce additional retention limits where information is no longer necessary for the relevant purpose.

16. Device Telemetry

TRUstiks may receive technical telemetry from supported physical terminals and other Devices. Telemetry may be processed for:

• diagnostics;
• monitoring;
• troubleshooting;
• operation of Devices;
• investigation of technical failures;
• service reliability.

Device telemetry is retained for 5 days. After 5 days, telemetry is automatically deleted.

17. Sales Records

Where TRUstiks receives information relating to a completed sale, a separate sales record may be created. Sales records are stored separately from Device telemetry. Deleting Device telemetry does not delete an independently created sales record. Sales history may be retained for business, operational, statistical, billing, accounting and historical purposes. Where a sales record contains personal data, such data remains subject to applicable data protection law and this Privacy Policy.

18. Verification Data Retention Summary

TRUstiks currently applies the following retention model: Facial image: Maximum 15 minutes. Identification document image: Maximum 15 minutes. First name and last name: Not stored. Identification document number: Not stored. Nationality: Not stored. MRZ: Not stored. Device telemetry: 5 days. Date of birth: 90 days. Document type: 90 days. Document issuing country: 90 days. Document expiry date: 90 days. Calculated or estimated age: Retained as part of the minimised Verification history. Recognition confidence information: Retained as part of the minimised Verification history. Document-number-detected flag: Retained as part of the minimised Verification history. Face-comparison result: Retained as part of the minimised Verification history. Verification status and decision: Retained as part of the minimised Verification history. Sales records: Retained separately for applicable business and operational purposes.

19. Why We Process Verification Information

Depending on the relevant processing activity, personal information may be processed for:

Age Verification

To determine whether an End User satisfies the age threshold configured by the Customer.

Document Processing

To calculate age and perform relevant document-related Verification checks.

Face-to-Document Comparison

To determine whether the person undergoing Verification corresponds to the photograph presented in the identification document.

Security

To protect TRUstiks, Customers and End Users against misuse, fraud, attacks and unauthorised access.

Technical Operation

To operate the Services, investigate failures and troubleshoot technical problems.

Customer Support

To investigate specific Verification or service-related issues.

Billing

To determine usage of the Services and calculate applicable charges.

Statistics and Service Management

To understand service usage, reliability and operational performance.

Legal Compliance

To meet obligations applicable to CAV Solution.

20. Legal Basis for Processing

The appropriate legal basis depends on the circumstances in which TRUstiks is used. Where CAV Solution processes Verification data on behalf of a Customer acting as controller, the Customer is responsible for determining and documenting the appropriate legal basis for requiring age Verification. CAV Solution processes such data according to the Customer's documented instructions and the applicable Data Processing Agreement. Where CAV Solution acts as an independent controller, processing may be based, depending on the circumstances, on:

• performance of a contract;
• compliance with a legal obligation;
• legitimate interests pursued by CAV Solution or a third party;
• consent where consent is required and appropriate;
• another legal basis permitted by applicable law.

Where special categories of personal data, including biometric data within the meaning of the GDPR, are processed, an applicable condition under Article 9 GDPR must also exist.

21. Automated Processing

TRUstiks uses automated systems as part of age Verification. Depending on the Verification method, automated systems may:

• estimate age from a face;
• detect and read information from an identification document;
• calculate age from date of birth;
• compare a live face with a document photograph;
• determine whether a configured age threshold has been satisfied;
• generate an APPROVED or REJECTED Verification result.

The Customer determines what action its own service takes after receiving the Verification Result. For example, the Customer may use the result to allow or refuse access to age-restricted goods, services or content. Automated age-estimation systems may produce incorrect estimates. Where an identification document is not used, an age value generated from a face is an estimate and should not be interpreted as the End User's confirmed exact age.

22. Data Minimisation

TRUstiks is designed to limit the amount of personal data retained and disclosed. In particular:

• Customers' automated integrations receive only APPROVED or REJECTED;
• facial and document images are deleted within 15 minutes;
• names are not retained;
• identification document numbers are not retained;
• nationality is not retained;
• MRZ data is not retained;
• only a boolean indication is retained when it is necessary to record that a document number was detected;
• document-derived fields retained for operational purposes are automatically removed after 90 days;
• Customers and Distributors receive only a limited Verification summary in the Dashboard.

23. Customer Account Information

Where a person creates or manages a TRUstiks account, CAV Solution may process information such as:

• name;
• company or organisation;
• business contact information;
• email address;
• authentication and account information;
• account role and permissions;
• Devices associated with the account;
• subscription information;
• billing information;
• invoices;
• support communications;
• security and account activity.

This information is processed separately from temporary End User Verification images. Account information is retained for as long as necessary to operate the Customer relationship and afterwards where required for contractual, accounting, tax, security or legal purposes.

24. Payments

TRUstiks may use an external payment service provider to process:

• subscriptions;
• recurring charges;
• usage-based fees;
• invoices;
• other payments.

Payment card information may be submitted directly to the payment service provider rather than being stored by CAV Solution. CAV Solution may receive limited information from the payment provider, such as:

• payment status;
• payment transaction identifier;
• payment method type;
• invoice information;
• limited card information where provided by the payment service provider.

Payment service providers process payment information under their own applicable privacy and data protection terms.

25. Service Providers and Subprocessors

CAV Solution uses third-party service providers where necessary to operate TRUstiks. These may include providers of:

• cloud infrastructure;
• hosting;
• databases;
• artificial intelligence processing;
• document processing;
• email delivery;
• authentication;
• security;
• monitoring;
• payment processing;
• customer support.

Where a provider processes personal data on behalf of CAV Solution, CAV Solution applies contractual and organisational safeguards as required by applicable data protection law. Where required by GDPR, subprocessors processing Customer personal data are governed by appropriate data-processing terms. CAV Solution may maintain and publish a current list of relevant subprocessors separately from this Privacy Policy.

26. International Data Transfers

Some service providers may process personal data outside Estonia or outside the European Economic Area. Where GDPR requires safeguards for an international transfer, CAV Solution uses an applicable transfer mechanism, which may include:

• a European Commission adequacy decision;
• Standard Contractual Clauses;
• or another transfer mechanism recognised under applicable data protection law.

Additional safeguards may be applied where required.

27. Information Security

CAV Solution applies technical and organisational measures designed to protect personal data. These measures may include:

• encryption;
• role-based access controls;
• database-level access restrictions;
• authentication;
• separation of Customer and administrative access;
• automated deletion procedures;
• restricted administrative permissions;
• security logging;
• infrastructure and network security;
• monitoring for unauthorised access.

Customer and Distributor accounts cannot directly access restricted raw Verification records. Only specifically authorised administrative access is permitted to restricted internal information. No information system can provide an absolute guarantee of security, but CAV Solution applies measures designed to be proportionate to the sensitivity and nature of the data processed.

28. No Sale of Personal Data

CAV Solution does not sell End User personal data. End User Verification data is not provided to Customers for advertising or unrelated marketing purposes. Facial images and identification document images are not sold, provided to data brokers or made available to Customers as part of Verification history.

29. Use of Verification Data for AI Training

Production facial images, identification document images and personal information collected for an End User Verification are not intended to be used for unrelated advertising or profiling. Where CAV Solution or a third-party provider would use personal Verification data for a materially different purpose, including model training not necessary for providing the contracted Verification Service, an appropriate legal basis and applicable transparency requirements would be required before such processing takes place.

30. Children's Data

The nature of age verification means that TRUstiks may process information relating to persons who are below the age threshold configured by the Customer. TRUstiks therefore applies data-minimisation measures regardless of whether a Verification ultimately produces an APPROVED or REJECTED result. A rejected End User's facial or document image is subject to the same temporary image-retention limit as an approved End User's image. TRUstiks does not disclose a rejected End User's date of birth or identity information through the Customer's automated integration.

31. Cookies and Similar Technologies

trustiks.com and the TRUstiks Dashboard may use cookies or similar technologies necessary for:

• login and authentication;
• security;
• session management;
• preferences;
• operation of the Dashboard.

Where TRUstiks uses non-essential analytics, marketing or similar cookies, additional information and any consent mechanism required by applicable law will be provided.

32. Rights of Individuals

Depending on the applicable processing and CAV Solution's role, individuals may have rights under the GDPR including:

• the right to receive information about processing;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restriction of processing;
• the right to object to certain processing;
• the right to data portability where applicable;
• rights relating to certain automated decision-making;
• the right to withdraw consent where processing is based on consent;
• the right to lodge a complaint with a supervisory authority.

Where CAV Solution acts as processor on behalf of a Customer, CAV Solution may refer the request to or cooperate with the relevant Customer acting as controller. Because facial images and identification document images are automatically deleted within 15 minutes, those images will normally no longer exist by the time a later data-subject request is received. Similarly, document-derived fields subject to the 90-day retention period may already have been deleted when a request is made.

33. How to Exercise Privacy Rights

A privacy request concerning CAV Solution's own processing may be submitted to: support@trustiks.com Where the request relates to age Verification performed for a particular Customer, the End User may also contact the relevant Customer directly. CAV Solution may require reasonable information to verify the identity of a person making a request before disclosing or modifying personal data. We will process requests in accordance with applicable data protection law.

34. Complaints

Individuals have the right to lodge a complaint with a competent data protection supervisory authority. CAV Solution OÜ is established in Estonia. The Estonian supervisory authority is: Andmekaitse Inspektsioon Estonian Data Protection Inspectorate Official website: aki.ee Individuals may also have the right to contact another competent supervisory authority under applicable European data protection law.

35. Changes to This Privacy Policy

CAV Solution may update this Privacy Policy when:

• TRUstiks functionality changes;
• processing activities change;
• retention periods change;
• new integrations are introduced;
• legal or regulatory requirements change;
• service providers or processing arrangements materially change.

The current version will be published on trustiks.com. The date at the top of this Privacy Policy indicates when the current version became effective or was last updated. Where appropriate, Customers may also be informed of material changes through email or the TRUstiks Dashboard.

36. Contact Information

For questions about this Privacy Policy or CAV Solution's processing of personal data: CAV Solution OÜ Registry code: 16135498 Linda tn 2 20309 Narva Estonia TRUstiks: trustiks.com Privacy email: support@trustiks.com