To help the government fight the funding of terrorism and money laundering, federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

What this means for you: when you open an account, we’ll ask for your name, address, date of birth and other information that allows us to identify you. We may also ask to see your driver’s license or other identifying documents.

Vantar collects this information for itself and for Alpaca Securities LLC, which holds your brokerage account. Wyrr may also rely on it to provide your wallets. See Alpaca’s Customer Identification Program notice.

We verify your identity and screen your Account to:

• meet anti-money-laundering, counter-terrorist-financing and sanctions laws in the countries where we operate
• protect you from identity theft and account takeover
• prevent fraud and keep the Platform safe for everyone
• confirm you’re eligible for the services you apply for

We screen applicants and customers against:

• sanctions lists, including those of the U.S. Office of Foreign Assets Control, the UN, the UK, the EU and Nigeria
• politically exposed person (PEP) lists
• adverse media and fraud databases

We screen at sign-up and on an ongoing basis.

We may also ask about:

• Regulatory status: for example, whether you work for a broker-dealer or exchange, control a public company, or are a PEP, or are related to or closely associated with one
• Source of funds and wealth: where your money comes from

4.1 U.S. customers. We check your name, address, date of birth and Social Security number against reliable, independent data sources, such as credit bureau header data and public records. This is a “soft” check. It doesn’t affect your credit score. Most people are verified in minutes. If we can’t verify you electronically, we may ask you to upload an ID document or proof of address.

4.2 Customers outside the U.S. We use Sumsub, a specialist identity verification provider, which acts on our behalf. You’ll:

1. 1.photograph the front, and if asked the back, of your ID document
2. 2.take a short selfie or video, with a liveness check confirming you’re a real person who is present
3. 3.answer a few questions about your profile

Our provider checks that your document is genuine and hasn’t been tampered with. It then compares your selfie with the photo on your ID.

5.1 What it is. Comparing your selfie with your ID photo creates a mathematical representation of your facial features, called a facial template. This is biometric data. Applicable data protection laws treat it as especially sensitive, and we handle it with additional safeguards.

5.2 How we use it. We and our provider use biometric data only to:

• confirm you’re the person shown on your ID document
• check you’re physically present
• detect and prevent identity fraud

We don’t use it for any other purpose, we don’t sell it, and we don’t use it to identify you in other contexts.

5.3 How long we keep it. We delete biometric templates within 7 days of completing verification. The only exceptions are where we need them to investigate suspected fraud, or the law requires us to keep them, and then only for as long as necessary. We keep the verification result, your ID document images and your selfie image as part of our anti-money-laundering records, for the period set out in section 9.

5.4 Who sees it. Biometric data is processed by our verification provider under a contract that limits its use to verifying your identity. It’s encrypted in transit and at rest. Within Vantar, only staff who need it for verification or fraud work can access it.

5.5 Your choice. We ask for your explicit consent before collecting biometric data. If you don’t want to give it, choose Request manual review or email hello@vantar.co. A member of our team will verify your documents by hand instead. This takes longer than automated verification, and we may ask for additional documents. Choosing manual review will not affect how we treat your application.

You can withdraw your consent at any time by emailing hello@vantar.co. If you do, we will stop using your biometric data and delete any template we still hold, unless one of the exceptions in section 5.3 applies. Withdrawal does not affect verification already completed, and we will continue to keep the records described in section 5.3.

5.6 Consent wording. International applicants see this before the selfie step:

☐ I give my explicit consent for Vantar and its identity verification provider, Sumsub, to collect and use biometric data from my selfie and ID photo to verify my identity and prevent fraud, as described in Identity Verification and the Privacy Policy. I understand I can choose a manual review instead, and that I can withdraw my consent.

After your Account is open, we may:

• screen your Account against sanctions and PEP lists on an ongoing basis
• ask you to confirm or update your information periodically, or when something changes
• ask for more information about the source of your funds or wealth, or about particular transactions
• apply enhanced checks if your Account is higher risk, for example if you’re a PEP
• ask you to verify your identity again, for example after you change your phone number or email, or before a large withdrawal

You must give us accurate, complete and current information, and tell us promptly if anything changes, such as your name, address, residence, citizenship or tax status. Giving false or misleading information is a breach of our Terms of Use and may be a crime.

If we can’t verify your identity, or we identify a risk, we may:

• ask for more information or documents
• limit what you can do, for example deposits, trades or withdrawals
• decline to open your Account, or close it

The law may prevent us from telling you the reason for a decision. Where we can, we’ll explain what’s needed.

If you think someone has used your identity to open a Vantar account, email security@vantar.co straight away. We’ll investigate, close any fraudulent account, and give you the information the law allows to help you report the fraud.

You have rights over your personal information, including:

• access and correction
• deletion and withdrawing consent, where the law allows

See our Privacy Policy. Withdrawing consent doesn’t affect verification already completed. However, if you withdraw consent before you’re verified, you’ll need to use manual review instead. We must keep anti-money-laundering records for the periods in section 9, even if you ask us to delete them.

Questions about verification? Email hello@vantar.co. For privacy requests, email privacy@vantar.co.