Identity Verification Policy

1. Purpose

This Identity Verification Policy describes how Worqen OÜ ("Worqen") verifies the identity of Users before they can post jobs, apply to jobs, send invitations, fund escrows or receive payments. It supplements the Terms of Service and the Privacy Policy.

2. Why we verify

• To comply with our obligations under the Estonian Money Laundering and Terrorist Financing Prevention Act (MLTFPA), the EU Anti-Money-Laundering Directives, the Brazilian Anti-Money Laundering Law (Law 9,613/1998) and the Indian Prevention of Money Laundering Act 2002.
• To protect Workers and Employers from impersonation, fraud and account takeover.
• To meet our internal sanctions and politically-exposed-person (PEP) screening obligations.
• To maintain the integrity of escrow settlement and dispute resolution.

3. When verification is required

Browsing public listings on the Service does not require an account or verification. To perform any of the following actions, you must complete identity verification:

• Posting a job;
• Applying to a job;
• Sending or accepting invitations;
• Funding an escrow;
• Releasing funds from escrow;
• Withdrawing funds (when withdrawal flows are enabled).

We may also re-verify your identity at any time in response to risk signals, before unlocking certain features, or where we are required by law.

4. Verification provider

Verification is performed by Sumsub (Sum and Substance Ltd, United Kingdom), an FCA-supervised regulated identity-verification provider acting as our processor under EU Standard Contractual Clauses. Sumsub provides the user-facing verification flow, performs document and biometric checks, and reports a result (PASS / REJECTED / RESUBMISSION_REQUESTED) to Worqen. Sumsub's privacy notice is available at sumsub.com/privacy-notice.

5. What is collected

• Government-issued identity document — passport, national identity card or driver's licence (image of front and back where applicable).
• Live selfie with liveness check, used to biometrically match your face to the photo on the identity document.
• Personal data on the document — full legal name, date of birth, nationality, document number, expiry date.
• Proof of address (where required) — utility bill or bank statement dated within the last 3 months.
• Sanctions / PEP screening data derived from the above.
• Device, IP and session metadata captured by Sumsub to detect forgery, replay attacks and bot activity.

6. Retention

We retain different categories of verification data for different periods:

We override these retention defaults only where required by a longer statutory obligation or by an active legal hold (litigation, regulatory investigation, court order).

7. Who can access your verification data

• Sumsub reviewers see your raw documents and selfie during the verification flow under their own privacy notice.
• Worqen Trust & Safety personnel see only the verification result and the disposition metadata listed above. They can re-open a Sumsub case for re-review if a dispute or fraud signal arises within the 30-day Sumsub retention window.
• Other Worqen staff do not have access to verification data.
• We do not share verification data with other Users. Only a generic "Verified" badge appears on your profile after a PASS result.

8. Failure outcomes

8.1 Resubmission requested

Sumsub may request resubmission if the document is unreadable, expired, or fails liveness. You can retry without penalty.

8.2 Rejection

If verification is rejected after reasonable resubmission attempts, your account remains usable in browse-only mode but is blocked from posting, applying, escrowing or being paid. We will tell you in writing the high-level reason for rejection where this does not compromise an active investigation or violate AML "tipping-off" rules under Estonian MLTFPA § 49.

8.3 Account suspension following rejection

Where rejection is based on detected forgery, sanctions match, or other serious risk signal, your account may be suspended pending review. Funds already in escrow are not forfeited but may be frozen pending dispute resolution.

9. Re-verification triggers

We may require re-verification if:

• Your identity document on file has expired;
• You change material profile data (name, date of birth, nationality);
• Risk signals indicate a possible account takeover;
• Three years have passed since your last successful verification;
• You request a higher transaction or withdrawal threshold (when those tiers are introduced);
• An applicable regulator's rules require it.

10. Service levels

• Automated verifications typically complete within a few minutes of submission.
• Manual review (when escalated by Sumsub) is targeted to complete within 72 hours; we will notify you if more time is needed.
• Appeals (see Section 11) are answered within 14 days.

11. Appeals and complaints

You may appeal a rejection or any decision arising from verification by emailing dpo@worqen.com with the subject line "Verification Appeal". Include any supporting documentation. We will respond substantively within 14 days. You may also exercise your data-subject rights set out in the Privacy Policy, including the right to lodge a complaint with your local supervisory authority.

12. Sanctions screening

Verification includes screening of your name and date of birth against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals list, the EU Consolidated sanctions list, the United Kingdom OFSI sanctions list, and the United Nations Security Council sanctions list. We are also required to refuse business with users in comprehensive-sanctions territories (currently DPRK, Iran, Cuba, Syria and the occupied territories of Ukraine). A sanctions match results in account refusal or termination and may be reported to the Estonian Financial Intelligence Unit.

13. Contact

Worqen OÜ — Tallinn, Estonia
Verification questions / appeals: dpo@worqen.com