FaceTec ZoOm® SDK Privacy Policy

Last Updated - May 25, 2018

  1. To continually innovate and improve our software, FaceTec may collect user data and usage statistics from the ZoOm Login App, ZoOm Liveness App, and any app using the ZoOm Software Development Kit (SDK) only with the non-production version.
    When the SDK uses a production token - for commercial purposes and no longer for development purposes - no images or biometric data ever leave the end-user’s device. With a production token, any data that is transferred to the server via FaceTec’s secure API is anonymized, including an associated IP address and device UUID (unique hardware identifier).
  2. We will not disclose end user data to any third party without explicit approval from the user. This includes disclosures that will enable us to fulfill our business and product and service obligations, further allowing us to manage our business operations.
  3. The anonymous data collected is only used to operate our business, provide our products and services, improve existing products and services, develop new products and services, and to improve and personalize experiences interacting with the software. FaceTec will have the right to use and disclose usage data and anonymized user data for FaceTec’s legitimate business purposes; provided, however, that FaceTec will not use or disclose usage data or anonymized user data in a manner that would enable a third party to reasonably determine that such usage data or anonymized user data originated from our customers’ use of the services or any individual end user’s use of an integrated application.
  4. In production, as we do not provide our service and software directly to end users, our customers are solely responsible for providing all notices, and obtaining all consents, as required by applicable law in connection with the collection, use and disclosure of end user data. FaceTec may use end user data collected via the ZoOm SDK by our customers to provide the services to them.
  5. We may disclose what little personally identifiable information we do collect if required by law, such as to comply with a court ordered subpoena, or similar legal process when we believe disclosure is necessary to protect our rights, investigate fraud, or respond to a government request.
  6. EU GDPR Compliance (For EU residents)
    6.1 How We Collect, Use and Store Your Data
    In order to create the biometric data we use to successfully process your enrollment and login sessions in our ZoOm app and in developer versions (not production), we gather the following things:
    • Your IP (Internet Protocol) address, which is a set of numbers that identifies the location of a piece of hardware connected to a network, including the internet. An IP address allows a device to communicate with other devices over an IP-based network like the internet. By itself, it cannot provide the identity of the user. It’s important to us because it tells us where in the world our software is being used, which helps us better prepare the product for distribution and daily use.
    • Specific phone and software version information, all collected to make sure our software is 100% compatible and working correctly.
      OS version, including:
      • ZoOm version
      • Package name
      • Device ID
      • Phone model
      • Time stamp
    • Enrollment and authentication session information collected will include the above information as well as the following information, which is never shared or used for any other purpose except to positively identify you and help make the product more accurate:
      • Face images: Our system uses this data to understand the exceptionally wide variety of face structures from people all around the world
      • Session length: This helps us to understand the frequency and duration of use as it relates to the services level of daily usability
      • Email address provided: In the event we have questions about how you intend to use our service or what issues you might have had with it, we will use your email address only to contact you directly with questions and to send you only our own product updates if you desire
    6.2 How we Share Data We Collect From You
    We do not share any of the data we collect with any other organization as a rule. The exceptions will only be when there is a lawful request related to an unlawful act, such as a breach or theft of data.
    6.3 Your Access and Options to Manage Your Data
    You have control over your information. You may do the following at your discretion:
    • Request your data be erased ("The right to be forgotten")
    • Request a copy of what data is captured
    • Withdraw your consent at any time
    • Lodge a complaint with the authoritative body in your region
    At the same time, we provide the following information about us:
    • Our identity and contact information:
    • The following purposes of and legal basis for processing your data:
      • We have been given explicit consent to the processing of your personal data for the specific purpose of authenticating you as the correct user, and that your are alive when you enroll of log in
      • Processing your data is necessary to protect your vital interests. Our process makes it certain that no other person gains access to your confidential information
      • Processing your data is a necessary part of the service the company we provide user authentication services for
    • The location in which we process the data:
      • The specific data we collect is processed in the United States
    • Who the recipients of the data are:
      • We do not send the data we collect and process for our authentication process to any other organization or individual.
    • The period for which the data is stored:
      • We store your collected data for a time period that meets the needs of our business partners, and only for the purposes of a) our own ability to perform our service for those partners, and b) as reference for continued product integrity and improvement.
  7. Our privacy policy may be updated at any time to reflect changes in our practices or the laws governing them. Please review this document periodically for the latest updates.

Please contact us directly for more information at support@zoomlogin.com.