RESILIANT ID / IdNFT APP PRIVACY POLICY

This Privacy Policy explains how Resiliant (“we”, “our”, or “us”) collects, processes, and protects personal data through the Resiliant ID™ mobile application and the IdNFT™ mobile application, used within the Cash Generator app. We are committed to ensuring the privacy, integrity, and security of all user data.

User Overview

Resiliant ID™ and IdNFT™ empower users with personal control over their digital identity. All biometric data and identity documentation uploaded to Resiliant ID™ is encrypted and stored on the user’s device.

Only the user can access, view, edit, share, or delete this data. Biometric checks are conducted solely by our artificial intelligence engine, without human review or intervention.

Resiliant ID™ and IdNFT™ provide a simple ‘Yes’ or ‘No’ identity verification response to authorised third parties, without revealing personal data. If a third party requests access to a user’s photo ID or additional data, explicit consent from the user is always required before any information is shared.

Unlike the standard Resiliant system, when using the Cash Generator version of the app, Cash Generator is, with and after you confirm your permission, allowed to store and retain copies of photo IDs and photographs provided by the user. These records are maintained for compliance and regulatory purposes.

Since all other data is stored locally on the phone, deleting the Resiliant ID™ app from the device deletes all associated data from the system. However, any copies of photo ID or photos retained by Cash Generator will remain securely stored by them in accordance with Cash Generator’s retention policies and regulatory requirements.

Data Protection Commitment

Resiliant™ and IdNFT™ comply with the UK GDPR, EU GDPR, and relevant data protection laws in the regions in which they operate.

We act primarily as a data processor under Article 28 of the GDPR and may act as a data controller under Article 24 in certain cases, depending on the service and context. In both roles, Resiliant™ and IdNFT™ adhere to the highest standards of data privacy and security.

Except where Cash Generator is required to retain copies of IDs and photographs, no personal or biometric data is uploaded to external servers or cloud systems. All other identity data remains securely stored on the user’s mobile device and under the user’s control.

Scope of This Policy

This Privacy Policy applies to:

  • Users of the Resiliant ID™ and IdNFT™ mobile applications within the Cash Generator app

  • Personal data processed on the user’s device

  • Copies of photo IDs and photographs stored by Cash Generator with user consent

  • Any other data shared with third parties with user consent

Although Resiliant does not generally process personal data on its servers, this policy ensures our systems, procedures, and staff comply with applicable UK, EU, and regional data protection regulations if processing becomes necessary.

Responsibilities

a) Resiliant’s Responsibilities
Resiliant ID™ and IdNFT™ are responsible for implementing and maintaining appropriate policies, procedures, and technical safeguards in compliance with applicable data protection laws.

b) Data Protection Officer (DPO)
Our DPO oversees compliance, manages data requests, handles breach notifications, and responds to privacy complaints.
Contact: info@resiliant.com

c) Staff Responsibilities
All Resiliant ID™ and IdNFT™ personnel must comply with this policy, protect data confidentiality, and report any data incidents immediately.

d) Third-Party Processors
Where external processors are used (e.g., for verification services), Resiliant™ and IdNFT™ ensure they meet required legal, contractual, and security standards. Cash Generator may also engage processors where required to fulfil its retention obligations.

Data Security Measures

Resiliant™ and IdNFT™ implement the following to protect user data:

  • Device-based encryption and secure storage

  • Biometric and facial data processed locally

  • No external transmission of sensitive data without explicit consent

  • Strict access controls, hardware protection, and monitoring for authorised backend functions

  • Ongoing vulnerability testing, audits, and employee training

Cash Generator applies additional safeguards to securely retain photo IDs and photographs in line with applicable compliance requirements.

Data Breach Protocol

Any suspected or confirmed data breach must be reported immediately to the DPO and/or CEO, with full details logged and assessed. Although most user data is stored on-device, we maintain internal procedures for breach response where applicable.

Data Subjects’ Rights

Where applicable under GDPR and regional laws, users may have rights to:

  • Access their personal data

  • Request rectification or erasure

  • Restrict or object to processing

  • Exercise data portability

  • Avoid automated decision-making without oversight

Users may exercise these rights by contacting info@resiliant.com.

Data Collected

Data collected and stored exclusively on the user’s device may include:

  • Full name

  • Email address

  • Phone number

  • Photo ID (passport, driving licence, or other documents)

  • Documents signed in the IdNFT/Resiliant ID App

  • Address

  • Facial biometrics

  • Phone IMEI

  • GPS location (if permitted)

  • Voice, palm (vein) print, retina scan, or other identifying data (with explicit consent)

This data is encrypted on the user’s phone and never transmitted unless the user consents explicitly.

Cash Generator may retain copies of photo IDs and photographs submitted by the user, in line with regulatory compliance obligations.

Purpose of Data Collection

Personal data is used solely for identification and compliance checks, such as Know Your Customer (KYC) or Anti-Money Laundering (AML) verification.

Automated validation may be performed against approved datasets or databases, where applicable and with user consent.

Cash Generator’s retention of photo IDs and photographs is required to meet statutory compliance and operational requirements.

Legal Basis for Processing

Data is processed solely on the basis of informed and explicit consent provided by the user. No processing takes place without consent.

Where Cash Generator retains IDs or photographs, this processing is based on legal obligations for compliance and regulatory requirements in addition to user consent.

Data Storage and Deletion

Resiliant does not store or access user data centrally. All user data is encrypted and stored on the user’s phone. Deleting the app removes personal and biometric data from the device.

Any IDs or photographs retained by Cash Generator will continue to be stored securely, even if the app is deleted, in line with Cash Generator’s legal and compliance obligations.

Contact Us

For questions, data requests, or complaints related to this policy or your data, please contact:

Data Protection Officer
Email: info@resiliant.com