PrivacyPolicy

1. Who we are

Enfacial (“Enfacial”, “we”, “us”) provides face-powered payments software for closed institutional environments. We operate as a data processor for the institutions that deploy Enfacial and as a data controller only for the narrow set of information we directly collect via this website.

2. Information we collect

Through the Enfacial applications

• Facial embedding. A mathematical vector derived from your face on your own device. The raw face image is discarded on-device before anything is uploaded. The embedding cannot be used to reconstruct the original image.
• Identity fields. Name, role at the institution, email or phone, and the linkage to the institution’s own user record (e.g. student ID).
• Transaction metadata. Amount, timestamp, vendor, and device identifier for each payment.
• Device and diagnostic data. Basic operational telemetry needed to keep the service running.

Through this website

• Contact details you submit via the early-access form.
• Standard server logs (IP, user agent, referrer, pages visited).
• Approximate country of the visitor, used to localise the currency shown. This is inferred at runtime and is not stored on our servers.

3. How we use it

• To enrol you at your institution and authenticate payments.
• To show transaction history and limits in the app.
• To detect and prevent fraud, abuse, and spoofing.
• To communicate with institutions about their deployment.
• To comply with applicable laws.

We do not sell personal data. We do not use biometric data to train new models. We do not build behavioural profiles for advertising.

4. How we store it

Embeddings are encrypted at rest (AES-256) and in transit (TLS 1.3), stored in logical per-institution isolation, and are accessible only to the institution’s administrators and the subset of Enfacial engineers with an auditable operational need. Data residency is configurable per deployment to match the institution’s jurisdiction.

5. Consent

Nothing is captured without explicit consent. For users who are minors, consent must be given by a parent or legal guardian through the app before enrolment can proceed. Consent may be withdrawn at any time from within the app.

6. Deleting your data

You can delete your Enfacial face enrolment and associated account data at any time. Visit our Delete your account page for instructions. Deletion removes the embedding and the account from all systems of record within 30 days, except for the minimum transaction metadata required by local law for financial record-keeping.

7. Sharing

• With your institution. The institution sees transaction data and aggregate analytics for users it has enrolled.
• With payment infrastructure. Top-up and payout transactions pass through regulated payment partners so the institution can move funds in and out of its own account.
• With legal authorities. Only where a valid legal request is received, and always narrowly scoped.

8. Your rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or port your personal data, and to object to or restrict certain processing. Write to privacy@enfacial.app and we will respond within the timeframe required by law.

9. Security

We enforce encryption at rest and in transit, logical tenant isolation, idempotent financial ledgers, and full audit logging on biometric data access. No security program is perfect; we disclose material incidents to affected institutions in line with applicable regulations.

10. Changes to this policy

We will update this page when the practices materially change, with the revision date updated at the top.

11. Contact

For any privacy question, write to privacy@enfacial.app.