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Creators must provide government-issued identification and tax identification numbers before cashing out earnings or KICKs, with this information collected directly by named and unnamed third-party identity verification providers on Kick's behalf.
This analysis describes what Kick's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a mandatory identity and background check requirement tied to creator payout eligibility, involving collection of government-issued IDs and tax numbers by third-party processors whose identities are not fully disclosed in the provided policy text. This creates a layered data processing structure where sensitive personal data is handled by subprocessors operating under their own terms.
Under this provision, creators seeking to receive earnings from Kick are required to submit government-issued ID and tax identification information to third-party verification providers before any payout is processed. The agreement states these providers process the information solely to deliver identity verification and background check services to Kick.
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"identification information, including government issued IDs and tax ID numbers prior to creators cashing out any earnings or KICKs through the Services. We use third-party identification verification service providers to collect this information directly and facilitate all identity and background checks. These providers will only process this information to provide us with the identity verification and background check services.Excerpt from Kick's Privacy Policy
1) REGULATORY LANDSCAPE: Collection of government-issued identification and tax identification numbers engages data protection obligations under GDPR Article 9 and equivalent special category or sensitive data frameworks in applicable jurisdictions. In the United States, the collection of tax identification numbers implicates IRS reporting obligations and may engage state identity theft protection statutes. The Australian Privacy Act's provisions on sensitive information are also relevant given Kick's domicile. 2) GOVERNANCE EXPOSURE: High. The collection of government-issued IDs and tax identification numbers represents processing of sensitive personal information with heightened data protection obligations in multiple jurisdictions. The delegation of this collection to unnamed third-party verification providers requires documented data processing agreements and may require data protection impact assessments under GDPR Article 35. 3) JURISDICTION FLAGS: EEA and UK creators face heightened exposure, as government ID processing may constitute sensitive data processing requiring explicit consent or another permissible legal basis under GDPR. Illinois users should note that identity verification involving biometric elements could engage the Illinois Biometric Information Privacy Act depending on the methods used by the verification provider, though the policy does not specify whether biometric data is collected. 4) CONTRACT AND VENDOR IMPLICATIONS: The policy states that unnamed third-party identity verification providers collect this information directly, which means Kick's contractual relationship with these providers and the scope of their data processing obligations are not fully disclosed. Procurement and compliance teams should request disclosure of all subprocessors handling government ID and tax data and review applicable data processing agreements. 5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that data processing agreements with identity verification providers satisfy applicable subprocessor requirements under GDPR and UK GDPR, including restrictions on further processing. The lawful basis for processing government-issued ID data, and whether consent or contractual necessity is the operative basis, should be documented. Retention periods for government ID data collected by third-party providers should be confirmed.
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This provision establishes a mandatory identity and background check requirement tied to creator payout eligibility, involving collection of government-issued IDs and tax numbers by third-party processors whose identities are not fully disclosed in the provided policy text. This creates a layered data processing structure where sensitive personal data is handled by subprocessors operating under their own terms.
Under this provision, creators seeking to receive earnings from Kick are required to submit government-issued ID and tax identification information to third-party verification providers before any payout is processed. The agreement states these providers process the information solely to deliver identity verification and background check services to Kick.
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