Identity & Face Verification Addendum

This addendum supplements the Verification Policy and Privacy Policy and governs face and identity verification only. It is deliberately narrow and conservative because facial data is treated as sensitive/biometric data in several jurisdictions.

Important product distinction. The Poses camera feature processes on-device (ML Kit) and stores no facial data on our servers. This addendum is about the separate, opt-in identity/face verification flow, which does capture and store a face image for review.

1. Purpose limitation

Any face image or identity evidence you submit is used solely to verify that a genuine, identifiable person (or authorised business representative) is behind a verification request — i.e. identity assurance. It is not used for advertising, content ranking, facial recognition across the platform, surveillance, training models, or any other purpose.

2. Consent

Face/identity verification is optional and opt-in. Before capture, we obtain your explicit consent and explain what is collected, why, how long it is kept, and how to withdraw. Where local law treats facial data as special/biometric data (e.g. GDPR Art. 9, US state biometric laws such as Illinois BIPA and Texas/Washington equivalents, DPDPA rules, APPI), we apply the stricter local requirement.

3. What we collect

• A face image/capture and any derived face_verification_result.
• Identity or business evidence (e.g. government ID, business registration), stored as private R2 object references.

4. Storage, access, and audit

• Stored privately (owner + authorised admin only); never public.
• Every admin view is logged (admin_audit_logs) through an audited proxy; no evidence token or URL is exposed to clients.
• Encrypted in transit and at rest per the Security section of the Privacy Policy.

5. Retention and deletion (data-minimising)

We keep face/identity data only as long as needed to complete and record the verification, and delete it within 30 days of the verification decision (approval, rejection, or withdrawal), except during an open appeal or a legal hold. On withdrawal of consent or account deletion we delete face/identity evidence on the same 30-day basis, except where a legal hold applies. See the Retention Policy.

6. Your rights

You may withdraw consent, request access, and request deletion of face/identity data by contacting fuy.aphelion@gmail.com. Withdrawal stops future processing and may end or reset your verification status.

7. No sole reliance / no guarantee

A completed face/identity verification supports, but does not conclusively prove, identity, and does not create any warranty by Aphelion about the user.