Privacy Policy

Introduction

Verify Twice ("we," "us," or "our") provides anonymous identity verification and community safety services. We comply with UAE PDPL, EU GDPR, and global privacy standards. This Privacy Policy explains how we collect, use, store, share, and retain your personal data, including biometric face data.

Data Collection

We collect the following categories of data:

Account Information: Name (first and last), email address, phone number, date of birth, gender, country, and city.
Photos: Images you voluntarily upload to the app for face detection and matching purposes.
Face Data (Biometric Data): See the dedicated section below for complete details.
Device & Usage Data: Device fingerprint, browser type, platform, screen resolution, timezone, IP address, and usage analytics.
Payment Data: Transaction records (payment processing is handled by third-party providers; we do not store credit card numbers).

Biometric & Face Data

This section provides a complete and detailed explanation of how we collect, use, store, share, and retain face data. Face data is treated as sensitive biometric information and is handled with the highest level of security and privacy protection.

What Face Data We Collect

When you upload a photo, we process it to detect faces within the image. For each detected face, we collect:

Face Bounding Box Coordinates: The pixel coordinates (top, left, width, height) indicating where a face is located within the uploaded photo.
Facial Feature Embedding (Face Vector): A mathematical representation (numerical vector) generated by Amazon Web Services (AWS) Rekognition that encodes the unique geometric characteristics of a face. This is a one-way mathematical hash — the original face cannot be reconstructed from this data.
AWS Face ID: A unique identifier assigned by AWS Rekognition to each indexed face for the purpose of face-to-face similarity searches within our private collection.
Face Thumbnail Reference: A reference URL pointing to a cropped thumbnail of the detected face, used solely for display within the app's user interface.

We do not collect, store, or process: iris scans, retinal patterns, voice prints, fingerprints, DNA, or any biometric data other than facial geometry embeddings derived from user-uploaded photos.

How We Use Face Data

Face data is used exclusively for the following purposes:

Face Detection: Identifying and locating faces within photos you upload, so you can review who appears in your images.
Face Grouping: Grouping detected faces that appear to be the same person across your uploaded photos, helping you organize your images.
Face Matching: When you flag a face as "someone you know," we search our face collection to determine if another user has also uploaded and flagged a photo of the same person. If both users independently recognize the same individual, a mutual match is created — enabling them to connect.
Face Review & Flagging: Allowing you to review detected faces and indicate whether you know the person, which determines whether face matching is performed.
GDPR/Privacy Compliance: Honoring face block requests — when an individual requests their face be excluded from matching, we use the face embedding to identify and permanently prevent matches involving that face.

Face data is never used for: advertising, marketing, profiling, surveillance, law enforcement, identity verification, age estimation, emotion detection, or any purpose other than the face matching service described above.

Third-Party Sharing of Face Data

Face data is shared with the following processors, and no others:

Amazon Web Services (AWS) Rekognition: Your uploaded photos are transmitted to AWS Rekognition solely for the purpose of detecting faces and generating facial feature embeddings (vectors). AWS processes the image data in real-time, returns the results, and does not retain your photos or face data independently. AWS Rekognition is used as a processor under our data processing agreement and is subject to AWS's security and compliance certifications (SOC 1/2/3, ISO 27001, HIPAA eligible).
FaceCheck.ID (optional, Digital Footprint reports only): If you choose to run a Digital Footprint report on a face you have marked as known, the cropped face image may be sent to FaceCheck.ID to search for public appearances of that face on the open web. This is only performed after explicit, in-app consent and only for users aged 18+. FaceCheck.ID states it does not add uploaded photos to its public index and deletes search history within 24 hours. You can disable this step entirely by not purchasing or running a Digital Footprint report.

We do not sell, rent, license, or otherwise disclose face data to any other third party for their own purposes. Face data is not shared with advertisers, data brokers, analytics providers, or any entity other than the processors described above.

Reverse Face Search (Digital Footprint Reports)

Digital Footprint reports combine reverse image search, optional open-web face search, public web search, and AI synthesis. The open-web face search is:

Only available for faces you have explicitly marked as known in the app.
Only run after you accept two separate consent checks (processing and third-party permission).
Not available in the iOS native app while App Store review is pending.
Framed as a signal, not a verified identity: results show similar faces on public pages with source links.

Where Face Data Is Stored

Face data is stored in the following locations:

Facial Embeddings & Metadata: Stored in our secured database hosted on cloud infrastructure with encryption at rest (AES-256) and in transit (TLS 1.2+). Access is controlled via row-level security policies ensuring users can only access their own data.
AWS Rekognition Face Collection: Face embeddings are indexed in a private AWS Rekognition Collection for similarity search purposes. This collection is private to our application and is not shared with or accessible to any other AWS customer or service.
Uploaded Photos: Stored in encrypted Amazon S3 buckets with server-side encryption (SSE-S3). Photos are accessible only via time-limited signed URLs generated on demand.

All storage infrastructure is located in AWS regions compliant with applicable data protection regulations. Face data is never stored on the user's device beyond temporary cache for display purposes.

How Long Face Data Is Retained

Face data is retained according to the following schedule:

Active Account: Face embeddings, face metadata, and uploaded photos are retained for as long as your account remains active and you have not deleted the associated photo or face.
Photo Deletion: When you delete a photo, all face data derived from that photo (embeddings, bounding boxes, thumbnails, AWS Face IDs) is permanently deleted from our database and removed from the AWS Rekognition Collection within 24 hours.
Account Deletion: When you delete your account or submit a data deletion request, all face data, photos, embeddings, and associated metadata are permanently deleted from all systems (database, AWS Rekognition Collection, and S3 storage) within 30 days.
Face Block Requests: When an individual requests their face be blocked (GDPR right to object), the minimal face embedding required to enforce the block is retained in our blocklist to prevent future matches. No photo or personally identifiable information is retained — only the mathematical embedding necessary for exclusion.
Logs: API usage logs related to face processing (which do not contain face embeddings or photos) are retained for up to 12 months for security and debugging purposes, then permanently deleted.

Consent for Face Data

We collect and process face data only with your explicit, informed consent. By uploading a photo to Verify Twice, you expressly consent to the detection of faces within that photo and the generation of facial feature embeddings for the matching purposes described in this policy. You may withdraw consent at any time by deleting your photos or your account, which will result in the permanent deletion of all associated face data. Consent is obtained on a per-action basis — no face data is collected until you actively upload a photo.

Photo Ownership & Third-Party Consent

By uploading a photo, you represent and warrant that you either own the photo or have obtained the consent of all identifiable individuals depicted in the photo for its upload and processing, including the generation of facial feature embeddings. You are solely responsible for ensuring that your use of the app does not violate the privacy rights of any third party. If an individual depicted in a photo objects to their face being processed, they may submit a face block request through our data deletion request page or by contacting us at support@verifytwice.com, and we will permanently exclude their face from all matching.

Deep Search Reports & Match Data

This section explains exactly what is stored — and what is not — when you run a Deep Search (digital footprint) report or when a face match is created.

Deep Search Reports

What is stored: The structured report results (summary sections, links to public sources, and a risk indicator) are stored in our database, linked to your account and the specific face you searched. Reports are private to you — no other user can ever see your reports or know that you ran one.
Search details you enter: Any name, username, or city you type is sent to our search providers solely to run the check and may appear within the stored report results.
No new biometric data: Deep Search does not create any new face embeddings or biometric records. The optional reverse face search sends the existing cropped face image to FaceCheck.ID only after your explicit, per-search consent; FaceCheck.ID states it does not add uploaded images to its public index and deletes search history within 24 hours.
Report expiry: Each report automatically expires 30 days after it is generated and is never reused after that point.
Deletion: Stored reports are permanently deleted when you delete the face or photo they relate to, and within 30 days of account deletion, alongside all other account data.
The person searched is not notified: Running a report does not contact, match with, or reveal anything to the person in the photo.

Face Match Records

When a match is stored: A match record is created only when two users have each independently uploaded and flagged the same person as someone they know. The record links the two accounts and the matched face — it contains no names or messages by itself.
Anonymous by design: Matched users see only a first initial, city, and gender — never full names, contact details, or the other user's photos outside the matched face context.
Automatic deletion: If either user un-flags the face, or deletes the photo or face it came from, the match — and the chat attached to it — is deleted automatically. Matches do not outlive the face data they are based on.
Account deletion: All match records and chats involving your account are permanently deleted within 30 days of account deletion.

Legal Basis

Our legal basis for processing your data includes:

EU GDPR: Explicit consent (Article 9(2)(a)) for biometric/face data processing; contractual necessity (Article 6(1)(b)) for account management; legitimate interest (Article 6(1)(f)) for security and fraud prevention.
UAE PDPL: Consent, contractual necessity, and legal obligations as applicable.

Use of Data

Data is used to provide services, improve accuracy, maintain security, and comply with laws. For face-specific data usage, see the "Biometric & Face Data" section above. We never sell your data.

Storage & Security

We use encrypted storage (AES-256 at rest, TLS 1.2+ in transit) in compliant cloud regions, strict row-level access controls, regular security audits, and zero-trust architecture. All database access is enforced through row-level security policies ensuring users can only access their own data.

Retention & Deletion

Images, face embeddings, and associated metadata are retained until you delete the photo, delete your account, or submit a data deletion request. Upon deletion, all data including face embeddings and photos are permanently removed from all systems within 30 days. Logs are kept for up to 12 months. You can request deletion of your data at any time by visiting our data deletion request page.

If your face appears in someone else's photo

Users may only upload photos they own and where every identifiable person has given them permission, and they must confirm this before uploading. If your face has been uploaded by someone else, you can have it removed at any time — you do not need a Verify Twice account.

Submit a request on our data deletion request page and we will remove the face data and block it from any future matching.
Facial geometry derived from a photo is deleted within 24 hours of processing in any case; removal requests additionally delete the stored photo and add the face to our permanent blocklist.
You can also email support@verifytwice.com.

Your Rights

All users have GDPR-level rights regardless of location, including:

Right of Access: Request a copy of your personal data including face data.
Right to Erasure: Request deletion of all your data including face embeddings and photos.
Right to Withdraw Consent: Withdraw consent for face data processing at any time by deleting your photos or account.
Right to Object: Object to processing of your face data (e.g., request your face be blocked from matching).
Right to Rectification: Request correction of inaccurate personal data.
Right to Data Portability: Receive your data in a structured, commonly used format.

Contact support@verifytwice.com to exercise your rights.

Data Sharing

We share data only with the following categories of service providers, under strict data processing agreements:

AWS (Amazon Web Services): Cloud hosting, photo storage (S3), and face recognition processing (Rekognition). AWS processes data as a sub-processor and does not retain your data independently.
Payment Processors (RevenueCat, Apple, Google): Transaction processing only. They do not receive face data.
Email Service Provider (Resend): Transactional email delivery. They do not receive face data.
Legal Authorities: Only when required by law, court order, or legal process.

We do not sell, rent, or share face data with advertisers, data brokers, or any other third parties.

International Transfers

Data may be transferred to AWS regions outside your country of residence for processing and storage. Such transfers are protected by Standard Contractual Clauses (SCCs), adequacy decisions, and UAE PDPL safeguards as applicable.

Children's Privacy

Verify Twice is not intended for users under 16 (17+ on Apple App Store). No data is knowingly collected from children. If we become aware that a child has provided us with personal data, we will take steps to delete that data immediately.

Policy Updates

Significant changes will be communicated via the app and/or email. Continued use of the app after updates constitutes acceptance of the revised policy.

Contact Us

If you have any questions about this Privacy Policy, our face data practices, or wish to exercise your data rights, please or email us at contactus@verifytwice.com.

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