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Data protection notice

In accordance with Art. 13 and Art. 14 of the EU General Data Protection Regulation (GDPR (EU) 2016/679), we inform you below about the manner and background to the processing of your personal data in connection with the use of the "electronic identity" (eID) as defined in Art. 3 para. 1 let. i of the E-Government Act (E-GovG, LGBl no. 2011.575).

The following information applies equally to applicants and applicants or their legal representatives, as well as other persons affected by data processing when using the eID.

The data protection provisions of the National Administration of the Principality of Liechtenstein apply, which are in line with the General Data Protection Regulation (EU) 2016/679 of the European Union.

Cryptographic keys and technical information are managed in the eID.li app to guarantee a secure login process. No personal data is stored in the eID.li app in order to protect privacy and personal data from misuse. All data managed and used in connection with eID.li is stored on computers of the National Administration of the Principality of Liechtenstein and the European Economic Area EEA.

I. Responsible bodies

In accordance with Art. 19 para. 2 1st sentence E-GovG, the Liechtenstein National Administration is responsible for managing the eID system.

The body responsible for processing personal data when an eID is issued in accordance with Art. 14 para. 1 E-GovG is the

Foreigners and Passport Office
Giessenstrasse 3, P.O. Box 684
9490 Vaduz
Telephone (general): + 423 236 61 41
E-mail: dsk.apa@llv.li or info.apa@llv.li
Website: https://www.llv.li/apa

The operation of the eID system is the responsibility of the Office of Information Technology (AI in accordance with Art. 19 para. 2 2nd sentence E-GovG:

Office for Information Technology
Heiligkreuz 8, P.O. Box 684
9490 Vaduz
Telephone (general): + 423 236 66 78
E-mail (general): info.ai@llv.li
Website: https://www.llv.li/de/landesverwaltung/amt-fuer-informatik

Please note that you can address questions about data protection directly to the offices listed. General questions on data protection in the area of the Liechtenstein National Administration (LLV) and the Foreigners and Passport Office (APA) as an office of the LLV can also be addressed to the Data Protection Office (FDS) as the data protection officer of the LLV.

II Data processors / sub-processors

European Trust Services GmbH ("ETS" for short, a joint company of Österreichische Staatsdruckerei GmbH and CRYPTAS International GmbH), Franzosengraben 8/4th floor, A-1030 Vienna, was commissioned as the processor for the operation of the state eID system for Liechtenstein.

Sub-processor:

  • Youniqx Identity AG (Tenschertstrasse 7, A-1230 Vienna) - Provision of the eID system as SaaS, support organization, ensuring regular technical updates, maintenance and servicing of the eID system, etc;
  • Identity Trust Management AG (Auenstrasse 100, D-80469 Munich) - Provision of video identification service;
  • Körbler GmbH (Hofweg 1, A-8435 Wagna) - hosting.

III Contact details of the Data Protection Officer of the Liechtenstein National Administration

You can contact the Data Protection Officer of the Liechtenstein National Administration at the following address

Data Protection Office
Peter-Kaiser-Platz 1
9490 Vaduz
Telephone: +423 236 73 08
E-mail: datenschutz@regierung.li
Website: www.fds.llv.li

IV. Legal bases

The legal bases for the processing of personal data in connection with the issuance and use of the eID and the operation of the eID system can be found primarily in Chapter IIa. ("Electronic identification") of the E-GovG, in Articles 11 - 21 and Chapter III. of the E-Government Ordinance (E-GovV, LGBl No. 2020.459), Articles 6 - 12.

The processing of personal data in connection with the electronic identity (eID) by the Liechtenstein National Administration is therefore carried out to fulfill legal obligations (Art. 6 para. 1 let. c GDPR) or to perform tasks in the public interest (Art. 6 para. 1 let. e GDPR).

The Liechtenstein National Administration has to fulfill a wide range of legal tasks for the purposes described below.

V. Data subjects concerned

eID.li and the eID.li app are available to natural persons in Liechtenstein and abroad.

VI Purpose of the processing

The eID is the state digital identity of the Principality of Liechtenstein for natural persons. It therefore constitutes personal data within the meaning of Art. 4 no. 1 GDPR. Every natural person is entitled to an eID (Art. 13 E-GovV).

The purpose of using the eID is based on Art. 12 E-GovG: "The eID serves to uniquely identify a natural person electronically and to verify the authenticity of the person's declaration of intent or action. It replaces the signature in official procedures."

With eID.li or the eID.li app, natural persons can use their digital identity to securely identify and register with online services of the Liechtenstein National Administration and public authorities in the EU/EEA member states and with web services of private providers and carry personal proof, e.g. the electronic driver's license.

According to Art. 11 E-GovG, the eID must be used in electronic business transactions between authorities and persons in cases where unique identification is required.

This may be necessary, for example, on the basis of Art. 5 E-GovG, as communication in business transactions between public authorities and companies takes place electronically ("obligation to communicate electronically").

Apart from this, authorities are obliged to communicate with natural persons in accordance with Art. 5 para. 2 E-GovG, provided they have consented to electronic communication and are not entrepreneurs. Special legal provisions of the Service of Documents Act remain reserved.

The eID can be used under the conditions of Art. 12a E-GovG in conjunction with Art. 9 E-GovV. Art. 9 E-GovV in private data applications - provided they ensure secure handling of the eID. This requires authorization from the Office for Information Technology. Further information on this can be found at: https://eid.li/prp

The eID can be blocked temporarily or permanently under the conditions of Art. 18 E-GovG, it can expire and be reactivated.

The eID system is used for the technical implementation of an electronic identification system within the meaning of Art. 3 No. 4 eIDAS Regulation (Regulation (EU) No. 910/2014 on electronic identification and trust services for electronic transactions in the internal market).

The eID system comprises a mobile digital application of the state administration for the unique electronic identification of a natural person (eID app), a technical application that enables the mutual use of notified electronic identification systems among the EEA member states (eIDAS node) and a software of the LLV or a trust service provider (specifically European Trust Services GmbH as processor within the meaning of Art 28 GDPR) as well as the interfaces to the eID app and the eIDAS node. (see Art. 12 para. 1 E-GovV).

According to Art. 12 para. 2 E-GovV, electronic transactions between the eID system and data applications of public authorities or private data holders can be carried out to implement the purpose according to Art. 19 E-GovG.

An eID may be required for the use of certain services. Furthermore, using the eID:

  • Border commuter registration certificates can be issued in digital form (Art. 16 para. 6 Ordinance on the Free Movement of Persons, PFZV, LGBl no. 2009.350);
  • qualified electronic delivery addresses pursuant to Art. 30a ZustellG are deposited or submitted and electronic notifications pursuant to Art. 30b ZustellG, LGBl no. 2008.331, are made via the eID register;
  • Driving licenses are issued in digital form upon request (Art. 122a Traffic Licensing Ordinance, VZV, LGBl no. 1978.020);
  • data from the electronic health dossier is activated by the participants concerned when using a treatment service from the respective EGD healthcare service provider (Art. 5 Ordinance on the Electronic Health Dossier, EGDV, LGBl no. 2022.365);
  • when entering into a business relationship or processing occasional transactions by persons subject to due diligence, the identity of the contracting parties must be established (Art. 6 para. 1 Due Diligence Ordinance, DDO, LGBl no. 2009.098).
  • Holders of an eID can register for all services offered by the state administration at https://www.llv.li .

All persons who have received an eID.li in person at the counter of the Foreigners and Passport Office can register with electronic services of other EU/EEA member states, provided that the state in question supports eIDAS interoperability.

Liechtenstein citizens who have obtained the eID.li via video identification can register with some, but not all, electronic services of other EU/EEA member states, provided that eIDAS interoperability is supported.

Persons without Liechtenstein citizenship who have obtained the eID.li via video identification cannot use it for electronic services of other EU/EEA member states.

Liechtenstein citizens and persons from abroad who have obtained the eID.li at the counter of the Foreigners and Passport Office can use it to register with electronic services of other EU/EEA member states, provided that the eID.li has been integrated as a registration procedure by them.

Liechtenstein citizens who have obtained the eID.li by means of video identification can use it to register with some, but not all, online services of other EU/EEA member states, provided that the eID.li has been integrated by them as a registration procedure.

Foreign nationals who have obtained the eID.li via video identification cannot use it for online services of other EU/EEA member states.

VII Categories of data to be processed

a. General

In principle, the following categories of data can be processed via eID.li. The scope of the personal data actually processed depends on how it is used:

  • First name
  • Surname
  • Date of birth
  • Salutation
  • Maiden name
  • First name at birth
  • Telephone number
  • E-mail address
  • Place of birth
  • First name (if given on ID card)
  • Passport name
  • First name on passport
  • Driver's license
  • Document number
  • Expiration date ID card
  • Date of issue ID card
  • Civil status
  • Gender
  • Place of residence
  • Employment status
  • Authorization
  • eID status (status of the eID according to APA: "active" or "suspended")
  • eID class (eID-FL either A or B)
  • Image ID (ID number of the holder photo)
  • Image (bearer photo, PNG file)
  • userID (UserIdentifier - not to be confused with the PEID)
  • resourceId (OT token of the eID system)
  • Registration code eID
  • Password
  • PEID
  • Place of residence / time of move
  • Language (first language/bilingual)
  • Nationality / information on residence status, if applicable

b. Video identification

Video identification is only available to persons aged 18 and over. Further information on video identification can be found here: https: //www.llv.li/de/landesverwaltung/auslaender-und-passamt/eid.li---ihre-identitaet-im-digitalen-leben/registrierung

Liechtenstein citizens who have obtained the eID.li via video identification can log in to some, but not all, electronic services of other EU/EEA member states, provided that eIDAS interoperability is supported.
Persons without Liechtenstein citizenship who have obtained the eID.li via video identification cannot use it for electronic services of other EU/EEA member states.

Identity Trust Management AG, as the video identification service and subcontracted processor, processes the following data:

  • Surname
  • First name
  • Date of birth
  • E-mail address
  • Telephone number
  • ID card number
  • Date of issue
  • Expiration date

In an online identification process, personal data is collected by the video ID service provider and transferred to the Foreigners and Passport Office and then deleted.

c. Operation of the eID system

Various attributes that have been assigned to a digital identity can be processed for the operation of the eID system by the AI. These may include

Surname and first name

Date of birth

Identifier

encrypted area-specific personal identifiers that depend on the respective procedure or correspond to the procedural areas and are generated with the help of the eID app;

  • Registration code
  • Telephone number
  • Certificate serial number
  • Certificate validity period
  • Times of the signature processes
  • Domain of the signature recipients
  • Unique ID
  • Push ID
  • document to be signed
  • Contract date

The transmission of eID attributes by private data holders is generally limited to surname and first name, date of birth and identifier in accordance with Art. 9 Para. 2 E-GovV and can only be extended under the conditions of Art. 9 Para. 3 E-GovV.

Depending on the nationality of a person and the identification procedure, the eID.li is assigned to one of three classes (A, B or C). For more information, see https://www.llv.li/de/landesverwaltung/auslaender-und-passamt/eid.li---ihre-identitaet-im-digitalen-leben/fragen-und-antworten

d. eID.li app

Cryptographic keys and technical information are managed in the eID.li app in order to guarantee a secure login process.

With the exception of digital proofs, which must be available even in the event of a network failure, no personal data is stored in the eID.li app. Each time you register for an electronic service, the eID.li app obtains personal data from the register of the state administration and discards it immediately after registration.

Digital proofs, i.e. digitized versions of a document or certificate that are assigned to a person and can be stored in the eID.li app, such as the electronic driver's license, represent the digitized version of the existing ID card and are automatically available if a person has the corresponding proof and this proof is kept in the registers of the LLV. This makes it possible to carry digital evidence.

All data that is managed and used in connection with eID.li is stored on systems of the National Administration of the Principality of Liechtenstein and the European Economic Area EEA.

Devices with biometric support carry out the fingerprint comparison or facial recognition directly on the device and not in an app. The eID.li app uses these internal biometric functions and therefore never comes into possession of biometric data.

VIII. Origin of the data

If the data is not collected directly from the data subjects who apply for the issuance of an eID, the information on the personal data originates from electronic registers of the National Administration of the Principality of Liechtenstein (e.g. ZSD - Zentrale Stammdaten FL) and is only used during registration with the eID.li.
The attributes are always up to date for persons with a residence status in the Principality of Liechtenstein and no changes to marital status, name, etc. need to be disclosed.

Affected eID.li holders residing abroad must notify the Immigration and Passport Office of any name changes, changes in marital status, etc.

IX. Recipients

The responsible bodies only transfer personal data to other public bodies or to its processors in cases prescribed by law (see legal bases above).

X. Storage period

As already explained above, no personal data is stored in the eID.li app- with the exception of digital evidence, which must be available even in the event of a network failure. Each time you register for an electronic service, the eID.li app obtains personal data from the register of the state administration and discards it immediately after registration.

In an online identification process, personal data is collected by the video ID service provider and transferred to the Foreigners and Passport Office and then deleted.
In general, the storage period for data processing is governed by special legal provisions on retention periods or the Archiving Act (LGBl No. 1997.215) and the applicable archiving guidelines. If the purpose of the data processing has been achieved and there are no statutory retention periods (generally 10 years after the dossier is closed) preventing the deletion of the data of data subjects, the personal data is generally transferred to the respective deletion concept. The deletion concepts are based, among other things, on the applicable archiving guidelines.

The storage period for data processing is generally based on the Ordinance of 27 November 2018 on the Management and Administration of Files in the Liechtenstein National Administration (LLV File Management Ordinance LLV-AVV, LGBl. 2018 No. 264) and the special legal provisions on retention periods in the Archives Act, LGBl. 1997.215.

XI. Rights of data subjects:

a. Right to information:

Data subjects have the right at any time, informally and without justification, to obtain information about the data stored about them. This also applies to their origin and recipients and also to the purpose of storage. Data subjects receive this information free of charge (Art. 15 GDPR). Requests for information about processed personal data should be addressed directly to the above-mentioned public bodies (Foreigners and Passport Office or the Office for Information Technology) or to the Data Protection Unit.

b. Rectification, restriction of processing, erasure, data portability:

In addition, data subjects have further rights, such as the right to rectification of inaccurate data, restriction of processing and erasure of your personal data (Art. 16 GDPR, Art. 17 GDPR, Art. 18 GDPR), as well as data portability (Art. 20 GDPR), provided that the legal requirements for this are met.

For changes to personal data and marital status, transfer, blocking and deletion, see above under "Legal information".

c. Right to object:

Insofar as personal data is processed on the basis of a legal fact such as Art. 6 para. 1 e) GDPR, data subjects can object to the future processing of personal data at any time for reasons arising from the existence of the data subject's particular situation (Art. 21 GDPR). The existence of a special situation is subject to a case-by-case assessment.
If data subjects make use of the above-mentioned rights, the addressed responsible bodies will check whether the legal requirements for this are met.

d. Right to lodge a complaint:

Data subjects have the right to lodge a complaint with the data protection authority. The data protection authority as supervisory authority can be contacted at the following address

Data Protection Authority Principality of Liechtenstein
Kirchstrasse 8
P.O. Box 684
FL-9490 Vaduz
Telephone: +423 236 60 90
E-mail: info.dss@llv.li
Website: www.datenschutzstelle.li

Responsible for the content:

  • Foreigners and Passport Office
  • Office for Information Technology
Link Website: https://www.llv.li/en/eid.li-your-identity-in-digital-life/data-protection-notice