Biometric Data Policy & Written Release

Facial-recognition embeddings — a numerical representation of your facial geometry (“face fingerprint”) derived from the selfies you upload, computed using AuraFace and stored as a reference “centroid.” This is a “biometric identifier”/“biometric information” under 740 ILCS 14/10 and analogous state laws.

We collect, store, and use your biometric data only to: (a) keep your AI-generated photos consistent with your real face (“drift test” similarity checking); and (b) verify that all your uploads depict the same single person — you — to enforce our own-likeness-only rule and block impersonation. We do not use it for surveillance, advertising, or any other purpose.

We retain your biometric data only as long as needed for the purposes above and destroy it when the initial purpose is satisfied or within three years of your last interaction with us, whichever comes first (BIPA §15(a)). Raw uploads and their photo-level embeddings are destroyed within 30 days of upload; your reference embedding is destroyed with your trained model at 90 days (the model deletion is verified against the third-party provider and logged); and everything is destroyed sooner upon your deletion request or withdrawal of consent. A de-identified record of your consent (with all biometric data removed) is retained for three years solely as legal proof of compliance.

Your biometric data is disclosed only to the vendors who process it on our behalf to run the Service — principally fal.ai (training/generation), AWS Rekognition (safety screening), and Supabase (storage) — under contracts requiring confidentiality and equivalent protection. We will not disclose, redisclose, or disseminate your biometric data except: with your consent; to complete a transaction you request; as required by law; or under a valid warrant/subpoena (BIPA §15(d)).

We do not and will not sell, lease, trade, or otherwise profit from your biometric data (BIPA §15(c)).

We store, transmit, and protect your biometric data using the reasonable standard of care in our industry, in a manner at least as protective as we use for our other confidential information (BIPA §15(e)).

By checking the consent box and/or signing below, you provide your informed written release to collect and process your biometric data as described. You may withdraw consent at any time — in your account settings (Settings → Privacy), where deleting your photos or your account withdraws consent, or by emailing [email protected] — and we will stop future biometric processing and destroy your biometric data under this schedule.

Illinois: This serves as our public policy and your written release under BIPA. Texas (CUBI): You consent to capture and use of your biometric identifiers for commercial purposes; we destroy them within a reasonable time and no later than the BIPA schedule (CUBI is enforced by the Texas AG only, up to $25,000 per violation). Washington: Consent under RCW 19.375; where face data is “consumer health data,” this also serves as MHMDA consent. Colorado (HB 24-1130): This is our public biometric policy; you consent before processing and we do not sell your biometric data.

Electronic acceptance (checking the box, click-to-accept, or e-signature) constitutes a valid written release; BIPA was amended (SB 2979, eff. Aug. 2, 2024) to confirm that a “written release” may be obtained by electronic signature.