Siip is designed to let you prove what is necessary without revealing more about yourself than required. You remain in control of your data and only share what a service truly needs.
This privacy statement covers the use of the Siip identity wallet: within the Siip app, within apps from organizations where the Siip wallet is integrated ("trusted by Siip" apps), and in web solutions that utilize Siip.
Wherever you use the Siip wallet, the terms of this statement apply to the data for which Siip acts as the data controller, including the creation of the wallet and the authenticity checks performed in that context. If you use the wallet within an organization's app or website, that organization's own privacy policy will also apply to how they handle your data.
A verified, reusable digital identity
With Siip, you get a single, verified, and reusable digital identity. Siip verifies your identity once, allowing you to reuse it across various organizations without having to provide your details every single time. Creating and reliably maintaining this reusable identity is the core of our service.
A wallet that belongs to you
Siip provides you with a self-sovereign identity, putting you in complete control of your data. Your identity details and other attributes are stored in an encrypted format within your own wallet, directly on your phone (decentralized). They are not stored in a central Siip database, and we have no access to them. You decide exactly what information to share and with whom, as it is often sufficient to simply provide a verification result. For example, you can prove you are 18 or older without revealing your actual date of birth.
How does sharing your data work?
You decide when to share information. Siip facilitates this sharing within the agreement between you and the organization you are interacting with. When you scan a QR code or accept a right (such as a ticket), the app shows you which organization is requesting which data and for what purpose. The requested data is only shared once you provide your consent or confirm the action.
We always share as little as possible. For example, sometimes an organization only needs to know that you are 18 or older, not your date of birth or your full identity. Whenever possible, we only share the required outcome rather than the underlying data.
In this statement, you can read which data we process, why we do so, and how much control you have over it. We have tried to keep it as clear as possible. Please take your time to read the statement before making any important decisions.
What we consciously do not do
This is the most important thing to understand, as it determines who you should contact for which data.
1. Siip is the data controller for your Siip account and the underlying technology.
This concerns your email address, your customer numbers, and security features used to recognize and secure your account, as well as the identification and secure transfer of your wallet between devices. For this data, you can read how we handle it in this statement.
2. The organization with which you share data is the data controller for what happens thereafter.
Siip facilitates the sharing of data within the agreement you enter into with such an organization, for example, a hotel, a festival, or a football club. That organization determines the purpose for which it uses your data, how long it retains it, and with whom it shares it. For that processing, the privacy policy of that organization applies, not this one. In that case, we provide the technical wallet functionality to share (validated) data upon your consent.
In short: for your Siip account, you come to us; for what an organization does with your data, you go to that organization. You will always find additional information about this in the app and via the organization whenever it is relevant.
3. In some cases, Siip and the organization are jointly responsible.
This applies when linking your account to an organization and sharing the requested data (such as your registration email address and customer number). We also jointly determine which data you can share from your wallet. You can contact either us or the organization with questions regarding this aspect. We will work together to ensure you receive an answer.
For your Siip account, we process a limited amount of data:
Your email address and/or phone number. We use these to create your account and verify that it is you, via a verification code sent by email or SMS. We also use your email address to reach you regarding your account.
Your customer numbers. To make your reusable identity work, we use internal customer numbers linked to your account within Siip. You have a general customer number at Siip; we never share this with organizations or others. In addition, we create a separate customer number for every organization you interact with. These customer numbers are non-descriptive: they have no meaning outside of Siip because only we can make the link to you. This allows you to reuse your identity time and again, while organizations cannot recognize or link you to each other. Customer numbers are personal data; we process them to make the service work and to keep your account separated per organization. Legal basis: performance of the agreement, supplemented by our legitimate interest in integrity and security (Article 6(1)(b) and (f) of the AVG (Dutch GDPR law)).
Security features. In addition, we process some non-readable security features (internal platform identifiers) that serve exclusively to prevent fraud and monitor the integrity and security of the platform. Legal basis: our legitimate interest (Article 6(1)(f) of the AVG (Dutch GDPR law)). We inform you of the existence, purpose, and legal basis of these features, but not their value and precise operation: disclosing that would undermine the very security and fraud prevention they serve and would affect our trade secrets (Article 15(4) of the AVG (Dutch GDPR law) and Recital 63).
Security and usage data. For the security and reliability of the app, we keep limited technical data (e.g., login attempts and error messages). We use this for security and fraud prevention, not for advertising, behavioral analysis, or building profiles.
How we verify the authenticity of your identity document
This only applies to services where you verify your identity with an identity document. Not every service requires this. You can see in the app whether this applies to your service.
To ensure that an identity document is genuine and not forged, we read the chip in the document. A photo or scan is easy to replicate nowadays and does not provide a reliable check; the chip does. The check follows an international standard (ICAO9303) for travel documents (the same technology used by the government, for example, in the DigiD app).
For this check, the data from the chip is verified as a single block. It cannot be viewed separately. The issuing authority has placed a single digital signature over the entire data block. Only if that entire block remains unchanged is the signature valid and the document demonstrably authentic. Therefore, there is no way to pre-select individual fields, as authenticity can only be determined for the whole.
The check is performed in encrypted form on a secure server. This is done on a server because the authenticity of a document cannot be reliably determined on the phone itself. After the authenticity check, we only store the data required for your service in your wallet on your device; the remaining data is destroyed.
Data from your identity document during the authenticity check. Siip has a legitimate interest in verifying your identity correctly (Article 6(1)(b) and (f) of the AVG (Dutch GDPR law)). For services where Siip verifies your identity, you scan your identity document (passport, ID card, or driver's license) using the NFC chip in your phone, and we perform a brief authenticity check of the document.
The following data is read: the photo (in color), document type, country of issue, prefix(es), name, first names, document number, holder's nationality, date of birth, gender, expiration date, the BSN (for an ID card issued before August 1, 2021, or a passport issued before August 31, 2021), place of birth (driver's license), date of issue (driver's license), issuing authority (driver's license), and vehicle categories (driver's license).
Which data is subsequently kept in your wallet depends on the service. Data that is not required is destroyed immediately after the authenticity check, and what is kept is stored in encrypted form on your own phone. We never use your BSN for ourselves and never as an identifier within Siip.
What happens to your Citizen Service Number (BSN)?
For some services, processing or using the BSN is legally permitted or even mandatory, such as for personnel registration or gambling. Where this is the case, Siip processes the BSN exclusively for that specific service and based on a legal ground. The BSN is then stored securely in your wallet on your device. You can read what happens to your BSN in the information provided by that organization for that service: the privacy statement of that service and the accompanying explanation.
However, when verifying the authenticity of an older identity document, specifically an ID card issued before August 1, 2021, or a passport issued before August 31, 2021 the BSN may be included in encrypted form for a few seconds during the document's authenticity check. This is because the BSN is permanently stored in the chip of those documents, and the chip is verified as a whole. In this process, it is not read separately, not used, and not stored; it is destroyed immediately after the check.
Some services require an extra secure identity check. This may involve a facial check, which verifies that you are a real, present person and that your face matches the photo on your ID. You can see if this applies to your service in the app at the time it is required.
We make the following promises to you regarding this:
Why are we allowed to process your data?
We only process your data if there is a valid reason ("legal basis") for doing so. Depending on the situation, this is:
The legal basis depends on the service. Sharing data with an organization is therefore not always based on consent. For some services, sharing is necessary to perform the agreement, or it is based on a legitimate or legal interest. You can see what is being shared for each situation in the app.
To ensure our apps function, we engage specialized suppliers, for example for sending emails, secure storage, and identity verification. These parties work exclusively on our behalf and according to our instructions, and are not permitted to use your data for their own purposes. Our processors are Amazon Web Services (AWS) for the secure storage and processing of your account and registration data (processing within the EU, in Ireland), Microsoft 365 for our email correspondence with you (processing in the Netherlands), and Cloudflare for the security of our website. We have entered into data processing agreements with these processors that include the EU Standard Contractual Clauses.
A complete and current overview of our processors can be requested by contacting us at privacy@siip.group.
In addition, we may be legally required to provide data to competent authorities, for example, in the context of an investigation. We only do this if the law requires us to. This concerns exclusively your email address and/or phone number.
Your data in your wallet is stored locally on your device. We process your personal data within the European Economic Area (EEA). Your email address, customer numbers, and security credentials are stored with Amazon Web Services (AWS) in Ireland; our email correspondence is processed in Microsoft 365 in the Netherlands. Your personal data does not leave the EEA.
We do not keep your data longer than necessary. For the data for which Siip is responsible, the following applies:
For data processed by an organization about you, that organization's retention periods apply. You can find these in their privacy policy.
We take the security of your data seriously:
You have various rights regarding your data. For the data for which Siip is responsible, you can exercise these rights with us:
Contact and Data Protection Officer
If you have a question about your data or wish to exercise any of these rights, please email our Data Protection Officer at privacy@siip.group. We will respond as quickly as possible and no later than the statutory deadline.
If your request concerns what an organization does with your data, we are happy to help you find your way, but you will need to contact that organization directly. Where necessary, we will forward your request.
European Digital Identity (EUDI)
This reusable identity aligns with the European Digital Identity (EUDI), which Siip is working towards. Siip is working toward supporting the European Digital Identity (the EUDI wallet). In the future, this will provide you with additional safeguards and rights, such as clear insight in advance into exactly what an organization is requesting from you, the ability to disclose only what is strictly necessary, and the option to log in anonymously or under a pseudonym where possible. As soon as these features become available, we will inform you.
Children
If you are 16 years of age or older, you may decide for yourself whether to share your data when consent is required. If you are under 16, you need the consent of your parent or guardian.
We are constantly developing our services, so this statement may change. We will inform you of any significant changes, for example, when you reopen the app. You can find the version and date at the top of this statement.
Do you have questions, ideas, or a complaint about how we handle your data? Please email our Data Protection Officer at privacy@siip.group. We are happy to help.
If you disagree with how we handle your data, you can file a complaint with us. You also always have the right to file a complaint with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).
Siip Custodian B.V., Eekwal 16 8011 LD, Zwolle. KvK 81544995
