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Biometric Consent Form

Effective Date: [DATE — TODO: set before launch]

DRAFT — This document contains placeholder fields (effective date, address) and has not been finalized. It is published for review and pilot-planning purposes.

This Biometric Consent Form ("Consent") authorizes Smiley Pay Limited ("Smiley Pay," "Company," "we," "our," or "us") to collect, process, store, use, retain, and delete my biometric information in connection with the Smiley Pay biometric authentication platform.

By selecting "I Agree," enrolling my facial information, or otherwise proceeding with biometric enrollment, I voluntarily provide my informed consent to the practices described below.

1. Collection of Biometric Information

I understand that Smiley Pay may collect and process biometric information, including but not limited to:

I understand that this information is considered biometric information under certain applicable laws.

2. Purpose of Collection

I understand that Smiley Pay collects and processes my biometric information for purposes including:

I understand that biometric authentication is intended to provide a faster and more secure authentication experience.

3. Storage of Biometric Information

I understand that Smiley Pay may securely store my enrolled facial images as well as biometric templates or mathematical representations generated from those images.

I understand that my biometric information will be protected using reasonable administrative, technical, and organizational safeguards designed to prevent unauthorized access, disclosure, alteration, or destruction.

4. Retention and Deletion

I understand that Smiley Pay will retain my biometric information only for as long as reasonably necessary to:

I understand that biometric information may be permanently deleted or anonymized after I delete my account, withdraw my consent, or when the information is no longer reasonably necessary for these purposes, unless retention is required or permitted by applicable law.

5. Disclosure of Biometric Information

I understand that Smiley Pay does not sell, rent, lease, or trade biometric information.

I understand that biometric information may be disclosed only when reasonably necessary to service providers acting on Smiley Pay's behalf, cloud infrastructure providers, fraud prevention partners, or when required by law or valid legal process.

6. Voluntary Consent

I understand that providing biometric information is voluntary.

If I choose not to provide biometric information, or if I later withdraw my consent, I may be unable to use biometric authentication features offered by Smiley Pay.

7. Withdrawal of Consent

I understand that I may withdraw my consent for future biometric processing at any time by deleting my Smiley Pay account or contacting Smiley Pay using the contact information provided below.

Withdrawal of consent may disable my ability to use biometric authentication features.

Withdrawal of consent does not affect processing that occurred before my withdrawal or information that Smiley Pay is required or permitted by law to retain.

8. Acknowledgment

By selecting "I Agree," enrolling my biometric information, or otherwise using Smiley Pay's biometric authentication services, I acknowledge and agree that:

Contact Information

Smiley Pay Limited
Address: [ADDRESS — TODO: set before launch]
Email: privacy@smileylimited.com
Website: smileylimited.com

Questions regarding biometric consent, biometric information practices, or requests to withdraw consent may be directed to the contact information above.