LivFace Privacy Policy

1. Who we are

LivFace verifies that a real person is in front of the camera without storing their video or ID images. This Privacy Policy explains what personal data we handle when you visit livface.com, create a LivFace account, or when an app that uses LivFace asks you to complete a liveness check.

LivFace is operated by Sofloom Solutions FZ LLC, a company registered in Expo City Free Zone, Dubai, United Arab Emirates (Business Licence No. 00147) ("Sofloom", "we", "us"). We handle personal data in line with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and other laws that apply to us.

This policy covers:

• livface.com — our marketing website, documentation and live demo

• The LivFace dashboard — where developers sign up, manage API keys and billing

• The LivFace API and SDKs — the liveness, face-matching, ID document and Face ID Database services our customers build into their apps

It does not cover the apps and websites of our customers. Those businesses decide why they verify you and have their own privacy policies.

2. Our role: controller or processor

We play two different roles depending on whose data it is.

When we act as a processor, we handle end-user data only on our customer's documented instructions and for the purpose of providing the service. If you were verified inside someone else's app and want to exercise your rights, please contact that app's operator first. We will help them respond (see Section 11).

3. Information we collect

From customers and website visitors (we are the controller)

• Account data: name, work email, company name, and your password (stored only as a secure hash).

• API credentials: API keys and webhook URLs you create.

• Billing data: plan, invoices and payment status. Card details are entered directly with our payment provider, Stripe; we never see or store full card numbers.

• Support and communications: emails and messages you send us, and transactional emails we send you (sign-up, password reset, billing notices).

• Usage data: API request metadata such as timestamps, endpoints called, response status, verification counts against your plan, and the IP address of the calling client.

• Marketing attribution: campaign (UTM) parameters from the link you used to reach our site, captured in one first-party cookie (see Section 12).

From end users during a verification (we are the processor)

• Camera frames of the user's face, streamed during the liveness challenges. These are analysed in memory and never stored.

• Liveness results: session ID, the challenges issued, pass/fail outcome and liveness score.

• Face embedding: a numerical template (a list of numbers) derived from the face, used for face matching. It cannot be turned back into a photo by ordinary means, but we treat it as biometric data.

• ID document data: when a customer uses ID document verification, the uploaded ID image is never stored. We keep only the document's issue date, expiry date and whether it is valid. We do not store names, ID numbers or other text read from the document.

• Face ID Database templates: on the High-Volume plan, customers can enrol face templates for one-to-many search, along with the identifier the customer assigns to each template.

We do not ask end users for their name, email, phone number or location. A customer may link a LivFace session to its own user records, but that link lives in the customer's systems, not ours.

4. How we handle biometric data

Face data is sensitive personal data under the PDPL, so LivFace is built to keep as little of it as possible.

1. Camera frames stay in memory. The SDK sends a frame roughly every 800 milliseconds while the user completes five randomly chosen challenges (such as blink, smile or turn left). Each frame is analysed in memory and discarded. No video or photo is written to disk or to our database.

2. Only the result is saved. After the session, we store the pass/fail outcome and liveness score.

3. Face embeddings are kept briefly. If face matching is used, the face embedding is stored with the session and automatically erased after the retention period our customer selects: 24 hours (default), 7 days or 30 days. A customer may choose to disable automatic erasure, in which case the embedding is kept until the customer deletes it.

4. ID images are never stored. Only the issue date, expiry date and validity flag are kept, and they are erased on the same schedule as the face embedding.

5. Face ID Database templates persist until deleted. Templates a customer enrols for one-to-many search have no automatic expiry. They stay until the customer deletes them through the API or closes their account.

6. All analysis runs on our own servers. Face landmark detection, face matching and text recognition run inside our infrastructure. We do not send faces or ID documents to any third-party AI or biometric provider.

We do not use end-user biometric data to train or improve our models. Our models are pre-trained and are not updated with faces, embeddings, ID data or results from your verifications. We never sell personal data, and we never use biometric data for advertising or profiling.

5. How we use information and why

We do not use end-user data for any purpose other than delivering the verification our customer requested.

6. Who we share data with

We share personal data only with the service providers below, and only what each needs to do its job. None of them receives camera frames, face embeddings, Face ID Database templates or ID document data.

We may also disclose personal data:

• To comply with the law, such as a valid court order or request from a competent authority. Where allowed, we will tell the affected customer first.

• In a business transfer, such as a merger or sale of assets, to the new owner, who must honour this policy.

• With your instruction or consent.

We will update this list before adding a new provider that handles personal data.

7. Where data is stored and international transfers

All LivFace verification data is processed and stored on servers in Ethiopia, hosted on Ethio Telecom's Telecloud. Billing and email data is also processed by Stripe and Resend, mainly in the United States.

Because Sofloom is based in the UAE, using these locations is an international transfer of personal data under the PDPL. We protect transferred data by:

• using contracts with our providers that require them to keep data confidential and secure and to use it only to serve us;

• keeping biometric and ID-derived data on our own infrastructure, never with third-party providers;

• applying the same security measures (Section 9) wherever the data is.

Customers whose own rules require data to stay in a particular country should contact us before integrating.

8. How long we keep data

When a customer closes their account, we delete its face embeddings and Face ID Database templates within 30 days, except where the law requires us to keep something.

9. How we protect data

Our strongest protection is not keeping data we do not need: no video, no photos and no ID images are stored. On top of that we use:

• encryption in transit (HTTPS/TLS) for the website, dashboard, API and SDK traffic;

• API key authentication, with keys scoped to each customer account;

• strict separation of each customer's data from other customers';

• passwords stored only as salted hashes;

• access to production systems limited to staff who need it;

• automated jobs that erase face embeddings and ID data on schedule.

No system is completely secure. If we become aware of a breach affecting personal data, we will notify affected customers and the relevant authorities as the law requires, without undue delay.

10. Customer responsibilities

Customers who integrate LivFace decide whom to verify and why, so they are responsible for their end users' privacy. Each customer must:

• tell end users, before the camera opens, that a face liveness check will be performed and that LivFace processes it on the customer's behalf;

• obtain the end user's explicit consent, or have another valid legal basis, for processing biometric data under the laws that apply to them;

• choose a retention period for face embeddings that is no longer than needed, and delete Face ID Database templates when they are no longer needed;

• handle end users' requests to access or delete their data, with our help;

• not use LivFace to identify people without their knowledge, or for unlawful surveillance or discrimination.

These duties are set out in more detail in our Terms of Service.

11. Your rights

Under the PDPL you have the right to:

• Know and access what personal data we hold about you and how we use it;

• Receive a copy of your data in a structured, machine-readable format;

• Correct inaccurate or incomplete data;

• Delete your data when it is no longer needed or was processed unlawfully;

• Restrict processing while a complaint or correction is being resolved;

• Object to or stop processing, including for marketing;

• Object to decisions made solely by automated processing that have legal or similarly significant effects on you;

• Withdraw consent at any time, without affecting processing that took place before.

Customers and website visitors: email us at the address in Section 12. We will confirm your identity and respond within 30 days.

End users verified in another company's app: that company controls your data and decides whether you pass a check. Please contact them first. Because we do not store your name or contact details, we usually cannot find your data without the session ID the company holds. If you contact us directly, we will forward your request to the right customer and help them respond.

If you are not satisfied with our response, you may complain to the UAE Data Office.

12. Cookies, children, changes and contact

Cookies. livface.com sets one first-party cookie that records the campaign (UTM) parameters of the link you arrived from, so we know which campaigns work. The dashboard also uses a strictly necessary session cookie to keep you signed in. We do not use third-party analytics, advertising or tracking cookies. You can block or delete cookies in your browser settings; blocking the session cookie will prevent you from signing in.

Children. LivFace accounts are for businesses and developers aged 18 or over. LivFace itself does not set an age limit for end users; customers who verify minors are responsible for meeting the legal requirements that apply, including any parental consent.

Changes to this policy. We may update this policy as our service or the law changes. We will change the "Last updated" date at the top and, for material changes, notify customers by email at least 14 days before they take effect.

Contact us. For privacy questions or requests:

Sofloom Solutions FZ LLC (operator of LivFace) Expo City Free Zone, Dubai, United Arab Emirates Email: contact@sofloom.com