Last updated April 2024

Introduction

This Facial Scan Policy outlines the procedures governing the treatment of data derived from photos and videos of individuals’ faces, including data that may be interpreted as a scan of facial geometry, and any associated information used for identification purposes by GloRep and its affiliated entities, hereinafter collectively referred to as “GloRep.”

Reasons for GloRep’s use of Biometric Data

You may have encountered this Facial Scan Policy due to direction from a company that owns or operates a website, app or other service you are seeking to access (referred to the “Company’’), which is a client of GloRep. GloRep employs Biometric Data to enhance the identity verification process and ensures secure access to services provided by the Company. By analysing facial features extracted from photos and videos, GloRep aims to authenticate user identities effectively, detect fraudulent activities, and improve overall service quality at the Company’s request within the confines of applicable law.

GloRep collects, processes, and utilises Biometric Data for various purposes, including: Verifying your identity by comparing facial Biometric Data extracted from photos/videos to that extracted from your identity document and/or passport; authenticating your identity and use of the Company’s services by comparing facial Biometric Data from a reference image to new photos/videos; analysing biometric data to detect and prevent fraud, as well as identify signs of coercion or social engineering; and assessing the authenticity of images, videos, and identity documents to detect tampering or the presence of genuine human or physical documents.

In addition to the above-mentioned Biometric Data, GloRep may process other personal data such as personal data extracted from your identity document and/or passport (e.g. name, date of birth etc), as well as information such as IP address and other data about your device for the reasons listed above.

GloRep is committed to employing reasonable standards of care, consistent with industry norms, to safeguard Biometric Data from unauthorised disclosure or misuse.

Retention of Biometric Data

GloRep retains Biometric Data for a specified period, as outlined below:

– Biometric Data is stored for a maximum duration of 365 days from the date of submission of photos or videos containing facial imagery.

– After the specified retention period, Biometric Data is permanently deleted from GloRep’s records, unless otherwise required by law or legal processes.

– Photos/Videos are retained for up to three years before permanent deletion, unless otherwise required by law or legal processes

Disclosure of Biometric Data

GloRep may disclose Biometric Data under the following circumstances:

– In accordance with legal obligations or regulatory requirements.

– Pursuant to a valid court order or subpoena.

– To authorized third-party service providers engaged by GloRep to facilitate identity verification processes.

– With explicit consent from the individual concerned.

GloRep is in no way linked to or responsible for the practices of the Company or Providers. We encourage you to read the Company’s and any Provider’s privacy policies and terms of use.

Consent

By clicking on the ‘’continue’’ button, you acknowledge that you have read, understood, and accepted this GloRep Facial Scan Policy and GloRep’s Terms of Use. You grant consent to GloRep, the Company, and designated Providers to process your Biometric Data and other personal data for the outlined purposes. You release any claims related to your Biometric Data photos/videos, and confirm you are not accessing GloRep’s services in any jurisdiction where the services are not permitted by applicable law.

Withdrawal of Consent

If you have already consented but would now like to withdraw your consent, please contact the Company as described in the Company’s Privacy Policy

Variation

GloRep reserves the right to amend, replace, supplement, or delete this Facial Scan Policy, or any part of it. GloRep may notify users of an Amendment by posting the revised Facial Scan Policy and changing the “Last Updated’’ date at the top of the document. Any changes will take effect immediately upon posting the revisions to the GloRep website. These amendments will apply immediately to all current and future uses.

Conclusion

This Facial Scan Policy underscores GloRep’s commitment to safeguarding the privacy and security of individuals’ Biometric Data. By implementing stringent retention and disclosure protocols, the Company ensures compliance with applicable laws and regulations while prioritizing user trust and data protection.

It is important to read this Facial Scan Policy alongside GloRep’s Terms of Use and Privacy Policy, which provide more detailed information regarding GloRep’s services and the utilisation of personal data, including sensitive personal data. In the event of any inconsistency between this Facial Scan Policy and other documents or policies issued by GloRep, the terms outlined herein shall take precedence.