Information about you is private and we will keep it that way
Effective: May 23, 2018
Last updated: September 26th, 2022
A Reminder of What We Do
At Facenote we provide a way to create a Non Fungible Token (ERC 721 standard) that integrates the connection between your encrypted facial biometric profile with your consent for the usage of that profile, thus offering a fully traceable consent method fully controlled by you. This consent information is encrypted with your own private encryption key under your full control. You can opt in and consent to use this Face NFT as second factor authentication method (2FA), receive special loyalty discounts, access to special events or providing a facial signature to prove your identity. Your consent is minted and traceable at all times, thus staying at your full control. At all times you have the possibility of opting out of this service by deleting your account on the app, clicking on the link provided at opt in or by requesting it by email.
Our Reason for Storing Face Data
We securely store your face data to be able to use to validate your identity for the services that you opt in to use (ie: 2FA, or loyalty bonuses). At all times you are able to opt out and your information will be immediately and completely deleted
What is Biometric Data?
GDPR (General Data Protection Regulation) specifically recognizes biometric data as a subset of sensitive personal data deemed a “sensitive category of personal data.” It defines biometric data as, “personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopy (fingerprint) data.
Facenote solution powered by machine-learning software, uses biometric data to validate that your face matches the biometric information included in the NFT.
Information You Provide Us
We collect a variety of information that you provide directly to us. In general, we collect information from you through:
- Registering through our App (Facenote Face NFT)
- Registering through our SDK (Face Token SDK)
The types of data we can collect directly from you include:
- Your email address
- Biometric Data (face features) extracted from your face pictures or selfies under your explicit consent.
- Additional information about preferences that can be included at the registration form like your security pin or preferred art for your NFT.
How We Use The Information We Collect
We use your information for various purposes depending on the types of information we have collected from and about you and the specific services you use, in order to:
- Validate the authenticity of your Face NFT
- Respond to your communications and requests
- Contact you by email regarding our service or security validations
- Engage in analysis, research, and reports regarding use of the Services
- Secure the Services
- Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
- Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
Aggregate/Anonymous Data. We may aggregate and/or anonymize any information collected through the Website so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, statistical analyses of Service usage.
Do We Share or Disclose Your Information
We don’t share your Face Data or any other data we posses from you with third parties.
Data Subject Rights and Your Choices
You may have certain rights with respect to your information as further described in this section.
Your Legal Rights
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us at firstname.lastname@example.org at any time. Your local laws, such as in the European Union, may permit you to request that we:
- provide access to and/or a copy of certain information we hold about you
- prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
- update information which is out of date or incorrect
- delete certain information which we are holding about you
- restrict the way that we process and disclose certain of your information
- transfer your information to a third-party provider of services
- revoke your consent for the processing of your information
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. To the extent that you make such a request, we require certain information to help verify your request and prevent fraudulent information and removal requests. Specifically, we ask that you provide the following pieces of information:
- Email address associated with your Facenote profile;
- Approximate date of User registration;
- Information you want to view and/or request removed;
- Country of residence; and
- A statement under penalty of perjury that all information in your request is truthful and that this is your User Account or that you have the authorization to make the request on behalf of the owner of the User Account.
Depending on the circumstances and the information you request, we may require additional methods of verification in our discretion.
Length of Time Your Face Data is Stored
Your data is stored as long as you keep using the app and connecting services. We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
If you don’t opt in for services for a period longer than 6 months, we’ll delete all your face profile information.
Additionally, you may “opt out” of our service at any time by clicking on the opt-out link received at registration or by requesting it at email@example.com.
Facenote is intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
Facenote stores information about users on servers located in the United States. By using our services, you consent to the storage of your information inside the United States. If you are using the services from outside the United States and the European Union, please know the information you submit will be transferred to and stored in servers in the United States or other countries. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our services, you acknowledge the transfer, storing, and processing of your information in and to the United States.
As described above, Facenote also may subcontract the processing of your data to, or otherwise share your data with, service providers and others in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.
If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
How We Protect Your Information
We consider the confidentiality and security of your information to be of the utmost importance. Facenote takes a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties.
Please accept however, no security measures are perfect or impenetrable, and the Company cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. The Company is not responsible for the circumvention of any privacy settings or security measures contained on the Site by any Users or third parties.
We employ state of the art firewall technology, and all data used by Facenote is fully encrypted at rest and in transit using 256-bit SSL encryption, and continuously backed up in several high security data centres in different locations.
California Privacy Rights
California residents have the right to receive, once a year from Facenote: (a) information identifying any third-party company(ies) to whom we may have disclosed (within the previous calendar year) “personal information” (as defined by California law) for that company’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, submit a request at firstname.lastname@example.org; when you request the information, use the phrase “California Shine the Light Request” to help us appropriately identify your question, and include your mailing address, state of residence and email address so we can provide a response.
Facenote Contact Information
600 N Broad St Ste 5 # 2197
Middletown, DE 19709