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IDCheck and DS Wallet – Version 1.0 – 20/10/2026
The IDCheck and DS Wallet apps are provided by DigitalSign – Digital Certificate, S.A. (the "DigitalSign"), legal person No 507 015 851, based at Largo Padre Bernardino Ribeiro Fernandes, No 26, 4835-489 Nespereira, Guimarães, Portugal.
DigitalSign is a qualified provider of trusted services in accordance with Regulation (EU) No 910/2014 (EIDAS Regulation), as amended by Regulation (EU) 2024/1183, and is listed in the Portuguese list of trust published by the National Security Office.
We have appointed a Data Protection Officer, who can contact through dpo@digitalsign.pt or by letter to the above address.
This policy applies to the following mobile applications published by DigitalSign – Digital Certificate, S.A.:
Remote validation of the identity of those who have to digitally sign a document
Digital wallet for storing, managing and sharing identification data and electronic certificates of attributes as well as for affixing qualified electronic signatures and seals.
It complements the DigitalSign General Privacy Policy, the User Privacy Policy of the Remote Identity Validation Service and the general conditions and contracts of the services you hire. In case of differences in apps, this policy prevails.
Purpose: Check that a person is who he says he is before he is issued a digital certificate or before signing a document in accordance with Article 24 of the EIDAS Regulation and ETSI TS 119 461.
Data
Reasons
Conservation
Images of the identification document and data contained therein (name, number, date of birth, nationality, validity) and, when the document has chip, the data read by NFC
Implementation of the contract and pre-contractual steps (Article 6(1)(b) of the GDPR) and compliance with legal obligation (paragraph c) of the same paragraph)
7 years after the expiry of the certificate issued pursuant to Article 13(f) of Decree-Law No 12/2021 of 9 February
Photograph and video of the face for proof of life
Ditto
Ditto
Facial biometric model (template) used to compare the face with the photograph of the document
Explicit consent, which we asked for on a screen before the capture (Article 9(2)(a) GDPR)
Discarded immediately after comparison; not stored
Result of verification, date and time, and process technical records (session identifier, model and device operating system)
After validation, the data shall be kept for 90 days to allow the issuance of the qualified certificate. If the certificate is not issued within that period, the data shall be deleted.
When your document has a chip, the check can be performed in an entirely automatic way: we read the chip, validate its cryptographic signature and compare your face with the photograph stored in it. This processing is an exclusively automated decision within the meaning of Article 22 of the GDPR, authorised by point (c) of Article 24a of the EIDAS Regulation. If the result is negative, or if you prefer, you may request that the verification be carried out by a human operator, express your point of view and challenge the decision.
When the document has no chip, the final decision is always up to a human operator.
When the verification is intended to issue a certificate qualified by DigitalSign, we are responsible for the processing.
IDCheck does not require account creation.
Purpose: Allow you to create and use your digital wallet: store and submit identification data and electronic certificates of attributes (e.g. driving licence, academic or proof of address), share them with third parties by your decision and sign or seal documents with qualified certificates.
Data
Reasons
Conservation
Account details: name and email address
Execution of the contract (Article 6(1)(b) GDPR)
While account is active; deleted when account is deleted
Device and installation identifiers used to attach the wallet to your device and protect the keys
Execution of the contract and legitimate interest in the security of the service (paragraphs (b) and (f)
While the account is active
Photographs, video and audio collected in initial identification (onboarding)
Execution of the contract and compliance with legal obligation (paragraphs (b) and (c); explicit consent for the biometric component (Article 9(2)(a))
Where a qualified certificate is issued, 7 years after the expiry of that certificate (Article 13(f) of Decree-Law No 12/2021); in other cases until the account has been removed
Details of qualified certificates issued and records of signature and seal operations
Compliance with legal obligation (paragraph (c)), in particular Article 24(2)(h) of the EIDAS Regulation
7 years after the expiry of the certificate
Identification data and attributes stored in the wallet
They're stored in your device, under your control. They are only shared with a third party when you decide and authorize it in the app, and you can only share the necessary attributes (selective disclosure). We don't access the contents of your transactions or save your share history off your device. They're eliminated when you eliminate the account.
Data used in the issuance of qualified electronic certificates of attributes by DigitalSign shall be kept for seven (seven) years from the expiry of the certificate, applying DigitalSign to the same rules for the retention of qualified certificates. This data is not deleted when you delete the account.
We do not collect information about how you use your wallet beyond what is strictly necessary to provide the service, nor do we combine it with data from other services.
The apps only ask for the permissions they need and only use them when performing the corresponding operation:
Camera (IDCheck and DS Wallet): photograph the identification document and capture the face for proof of life.
Microphone (IDCheck and DS Wallet): when the identity check includes video recording with sound or video call.
NFC (IDCheck): read the chip of the identification document.
Storage (IDCheck and DS Wallet): store and open files on the device, for example documents and images.
Internet: communicate with our servers through encrypted connection.
You may withdraw any permission in your device settings, although the corresponding functionality is no longer available.
We don't sell your data or use it for publicity. We only communicate them to:
The data are processed in the European Union. We do not transfer personal data to countries outside the European Economic Area. If this is necessary, we will only do so with the guarantees provided for in Chapter V of the GDPR and we will update this policy.
The data shall be stored with appropriate technical and organisational risk measures, including encryption, access control, operations registration and monitoring. Our information security management system is certified according to ISO/IEC 27001 and our qualified services are audited periodically in accordance with the eIDAS Regulation.
In accordance with Articles 15 to 22 of the GDPR, you may ask us for access to your data, rectification, erasure, limitation of treatment and portability, oppose treatment based on legitimate interest and withdraw consent at any time, without affecting the treatment already carried out.
The right to erasure does not cover the data that we have to keep under legal obligation, in particular the evidence of identification and the data of qualified certificates, which the law requires us to keep for 7 years after the expiry of the certificate.
To exercise any right, write to dpo@digitalsign.pt or the address indicated in point 1. The exercise is free. We respond within one month, which can be extended for another two months in complex requests, in which case we will inform you. We can ask you for additional information to confirm your identity.
You also have the right to submit a complaint to the National Data Protection Commission (www.cnpd.pt) or the supervisory authority of the Member State in which you reside.
We can update this policy to reflect changes in apps or the law. The current version is always on this page, with the date of the last update.
