Privacy policy

The data controller for personal data collected through certaby.com is Amir Naghieh, a sole trader trading as Certaby. Our postal address is on the legal information page. Reach our data-protection contact at dpo@certaby.com. We are registered with the Information Commissioner's Office, registration number ZC273024.

From you (the customer): your account email, your firm's name, how you heard about us if you choose to say, your check history, the inputs you submit (FRNs, postcodes, names), Stripe billing metadata, and any message you send us through a form or by email. If you record a customer's risk and source of funds on a transaction, we also hold your answers and any evidence files you upload (for example bank statements or a mortgage offer). If you attach a signed end-user and stockist undertaking to an export shipment record, we hold that file, including the names and signatures of your customer's signatory. We don't track you across the web.

Digital ID checks: if you send someone a digital ID check link, we pass their name, email address and (if you gave it) date of birth to Vouchsafe, the identity service that runs the check. On their phone, Vouchsafe collects a photo of their ID document and a short selfie video (biometric data, used only to check that the face matches the document). Instead of a document, a person who has a right to rent share code can give it and their date of birth to Vouchsafe in its own check, and take a short selfie video, which Vouchsafe compares with the photo on their Home Office record (biometric data, as for a passport); we receive back the outcome, the details read from the Home Office record (name, date of birth, the dates of their permission and its reference) and Vouchsafe's PDF report of the check, which shows the share code, their date of birth, the Home Office's page of the check, a still image from the selfie and the face match, and for a tenant is their Right to Rent record. A tenant can also type the share code and their date of birth on our page; we pass them, with the firm's name and whether it acts as landlord or letting agent, to Vouchsafe, which checks them on the Home Office's online right to rent service, and we receive back the Home Office's page of the check (a PDF) and the photo on their Home Office record, for the firm to compare with the tenant. We delete a share code and date of birth typed on our page once the Home Office has answered; if the automatic check can't finish, we keep them for the firm's own check on GOV.UK and delete them once the firm records it, and in any case 6 months after the tenant gave them. For a passport, we receive back the outcome, the details read from the document (name, date of birth, document type, issuing country, expiry date and the last four characters of the document number) and Vouchsafe's PDF report of the check, which can include a copy of the document and a still image from the selfie. We keep the report so the firm can show what was checked (the Right to Rent rules ask for a clear copy of the check to be kept). We don't receive the selfie video.

Source of funds reviews: if a firm asks us to review someone's source of funds, we email that person a link. Through it they tell us where the money comes from and upload their bank statements and any supporting documents (a mortgage offer, a gift letter). Certaby's reviewer reads them and writes a report for the firm: the accounts checked (holder, bank, sort code and the last four digits of the account number), the money coming in, where the money for the transaction came from, anything that needs a closer look, and what the documents themselves show (for example the program a PDF was made with). The person's answers, documents and the report go to the firm that asked, and are used only for the checks the money-laundering rules ask for. Bank statements can show other details of someone's life; we read them only for this.

From upstream registers: whatever the official register returns for the entity you queried. We pass it through; we don't enrich it with anything they didn't publish.

To deliver and audit your checks (the PDF certificate's hash-verifiability requires us to retain inputs and outputs), to bill you correctly, to respond if you raise a support issue, and to comply with our own UK MLR / accounting obligations.

Check inputs + outputs: 7 years (matches the standard UK record-keeping period for AML/KYC), with one exception: a right to rent share code and date of birth a tenant types on our page of a Right to Rent link are deleted once the Home Office answers, or once the firm records its own check, and in any case 6 months after the tenant gave them. Risk and source of funds records and the evidence files uploaded with them (including the statements and documents a person uploads for a source of funds review, and its report), and signed undertakings attached to an export shipment record: 7 years, stored encrypted in AWS London, and only the account that uploaded them can open them. Digital ID check reports (the PDF with the person's photo and an image of their ID, for a share code typed on our page, the Home Office's page of the check and the photo on their Home Office record, or for a share code given in Vouchsafe's own check, its report, which shows the share code and date of birth; for a tenant these make up the Right to Rent record): kept, encrypted in AWS London, until 5 years after the firm marks the transaction complete (6 years after the check if it is never marked complete), then deleted; the firm can delete a report sooner. That is the period the money-laundering rules ask firms to keep these records (5 years after the relationship ends); the Right to Rent rules ask for the tenancy plus one year. The short record of the check (who checked, the document type, the last four characters of its number, the date and the result) stays with the transaction. Vouchsafe keeps the document images (or the share code and the Home Office's page) and the selfie video in the UK under its own retention settings while we are its customer. Payment and credit records: 7 years. Account email + Stripe metadata: as long as your account is active + 6 years thereafter. Emails to our addresses: we keep a copy for four months, so none is lost if a mailbox rejects it. Marketing emails: we don't run a marketing list; emails we send to businesses are covered in section 7.

You can request access, correction, deletion, or export of your personal data at any time. Email dpo@certaby.com. We respond within one calendar month. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint.

For your clients' data, we act as your processor: see our data processing terms. We use Stripe (billing), Cloudflare (hosting, email routing and the four-month email copy), AWS in eu-west-2 (compute + storage), Clerk (authentication), Resend (transactional email), and Anthropic (sorting messages sent through our contact forms and drafting our replies). Each has its own UK GDPR-compliant DPA in place with us.

For a digital ID check only, the person's name, email address and (if given) date of birth go to Vouchsafe (a trading name of Interrobang Limited, company 14466175), a digital verification service on the GOV.UK register, which stores their data in the UK. Vouchsafe collects the ID document, or a right to rent share code and date of birth, and the selfie from the person directly. For a right to rent share code typed on our page, the code, the tenant's date of birth and the firm's name and role go to Vouchsafe, which checks them on the Home Office's online right to rent service.

For a PEP check only, the person's name (and their date of birth and nationality, if you give them) is also sent to OpenSanctions Datenbanken GmbH in Berlin, which runs the PEP database we search. Sanctions screening never leaves our own copy of the official lists.

Some pages show a video from our YouTube channel, in YouTube's privacy-enhanced mode: YouTube stores nothing about you unless you play the video, and then Google's privacy policy applies.

We sometimes email limited companies and limited liability partnerships about Certaby, at the business email address they publish (for example in a trade directory). We rely on legitimate interests: each email is about a service that helps the firm meet its own legal duties, and it is sent to the firm, not to a private address. We keep the firm's name, that address, when we wrote and whether it replied or asked us to stop, for at most two years. Every email says how to stop: reply "no thanks" and we never email that address again (we keep it on a do-not-email list so it isn't added back). We don't email sole traders or partnerships unless they have asked us to.