Biometric Information Policy

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

This Policy explains how Smiley Pay Limited collects, uses, stores, retains, protects, and destroys biometric information.

1. What We Collect

Facial photographs, live scans, geometry, templates, embeddings, authentication timestamps, success/failure records.

2. Purpose

Identity verification, authentication, fraud prevention, security, improving accuracy. Never for advertising or sale.

3. Consent

Collected only after voluntary enrollment and affirmative consent. Withdrawal available at any time by deleting your account or contacting us.

4. Storage

Facial images and derived templates stored with encryption and access controls. Protected by reasonable safeguards.

5. Retention & Destruction

Retained only as long as needed. Deleted when you close your account, withdraw consent, or information is no longer necessary.

6. Disclosure

Never sold, rented, or traded. Disclosed only to service providers, cloud infrastructure, fraud prevention partners, or when legally required.

7. Contact

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