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Last updated: 24 AUGUST 2021

Facial Scan Policy And Release

Where the laws of Illinois, Texas, Washington or New York apply, the terms of this Facial Scan Policy and Release describe how Onfido Inc and its affiliate companies (“Onfido”) treat facial scan data extracted from photos and videos. Notwithstanding anything that could be construed to the contrary in Onfido’s Privacy Policy, Terms of Service, or any other document, where the laws of Illinois, Texas, Washington or New York apply and there is any inconsistency or ambiguity between the terms of this Facial Scan Policy and Release and any other document, these terms shall prevail.

Onfido, acting as a service provider to the company that owns or operates the website or app that you are using or is providing the services you wish to access (“Company”):

  • compares facial scan data extracted from your photo in your identity document that you provide to us to the facial scan data extracted from the selfie photo or video that you upload, in order to help verify your identity (“Verification”), 

  • compares facial scan data from the image you upload when you first enroll to the facial scan data provided when you authenticate yourself as an authorised user of the Company’s services (“Authentication”),

  • may also use your information, including your facial scan data, to detect and prevent fraud, to determine whether Onfido has previously verified a user’s identity on behalf of the Company, and to improve and develop our services. However, if you upload a photo or video from within Illinois or New York, Onfido will not use any facial scan data derived therefrom for the purpose of improving and developing our services. 

The images of you obtained from selfies, videos or identity documents and facial scan data are collected, used and stored directly by Onfido on behalf of Company as Company’s service provider through Company’s website or app that you currently are using.

Onfido securely stores all selfies, videos, photos of identity documents, and facial scan data in an encrypted format. Onfido’s third-party vendors may have access to the facial scan data to store the data, to maintain backup copies, and to service the systems on which such data is stored. Consistent with our directions from the Company, Onfido will permanently destroy your facial scan data when directed to do so by the Company, or within one year of your last interaction with Onfido, whichever occurs first, unless otherwise required by law or legal process to retain the data. In the event that you do not complete the verification or authentication process, Onfido will not extract or process your facial scan data or attempt to verify or authenticate your identity. Onfido will retain a record of the partially completed process and any media you uploaded in accordance with the instructions of the Company through which you are accessing Onfido’s services. Onfido uses the reasonable standards of care within its industry to store, transmit, and protect from disclosure your facial scan data, in a manner that is the same as or more protective than the manner in which it stores, transmits, and protects other confidential and sensitive information. Onfido will not sell, lease, trade, or, other than to provide the verification and authentication services to Company described in this policy, otherwise benefit from facial scan data. Other than as set forth herein, Onfido will not disclose, redisclose, or otherwise disseminate facial scan data unless doing so: A. Completes a Company transaction requested and authorized by you or your legally authorized representative; B. Is required by state or federal law, or municipal ordinance; C. Is required pursuant to a warrant or subpoena issued by a court of competent jurisdiction; or D. Is expressly consented to by you.

By clicking on the “Accept” button or otherwise proceeding to use the services Onfido provides on behalf of Company, you agree that you have read, understand, and voluntarily consent to Onfido’s Facial Scan Policy and Release, Onfido’s Terms of Service, and Onfido’s Privacy Policy, and that you release any claims related to your facial scan data.

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Company Registration Number: 07479524.