Biometric Consent Form
Effective Date: [DATE — TODO: set before launch]
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:
- Facial photographs
- Live facial images captured during authentication
- Facial geometry measurements
- Facial recognition templates
- Mathematical feature vectors or embeddings derived from facial images
- Authentication records
- Verification logs
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:
- Identity verification
- User authentication
- Payment authorization
- Fraud prevention
- Account security
- Detection of unauthorized account access
- Customer support
- Compliance with legal obligations
- Operation and improvement of the Smiley Pay Service
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:
- Operate the Service
- Authenticate my identity
- Prevent fraud
- Maintain security
- Comply with legal obligations
- Resolve disputes
- Enforce contractual rights
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:
- I have read and understood this Biometric Consent Form.
- I have had the opportunity to review Smiley Pay's Privacy Policy and Biometric Information Policy.
- I voluntarily authorize Smiley Pay Limited to collect, process, store, and use my biometric information as described above.
- I understand that biometric authentication technology is probabilistic and may occasionally produce failed or incorrect authentication results.
- I understand that I may withdraw my consent in accordance with this Consent and applicable law.
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.