Biometric Information Privacy Policy

In order to generate its 3D figurines or avatars (“Action Face Products”), Action Face, Inc. (“Action Face”, “we” or “us”) uses software to capture facial geometry from photographs scanned by users to the Action Face App (“App”). Facial geometry is generally considered “Biometric Information” – which is information related to human characteristics. In order to comply with various laws governing Biometric Information, Action Face has implemented the following Biometric Information Privacy Policy: 
  1. Biometric Information Collection. Action Face generates, stores, uses and discloses (as explained below) Biometric Information for the sole purpose of creating and providing users with the Action Face Products that they have ordered.

  2. Consent. Before users upload a scan for customization, they will be prompted to affirmatively consent to this Biometric Information Privacy Policy and to our collection, storage, use and disclosure of Biometric Information. USERS WILL NOT BE ABLE TO UPLOAD ANY IMAGES UNLESS THEY CONSENT TO OUR PRACTICES.

  3. Disclosure. Other than to create the Action Face Products that users wish to purchase, Action Face will not sell, lease, trade, or otherwise profit from the Biometric Information that it collects, nor will it authorize its Service Providers to engage in such activity. Neither Action Face nor its Service Providers will disclose or disseminate Biometric Information for purposes other than to provide the Action Face Products, unless: 

    a. You or your legally authorized representative provides written consent to such disclosure; or
    b. The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

  4. Storage: Once captured, Biometric Information is encrypted and stored by Action Face on its servers, in a secure manner as set forth in our Privacy Policy. Service Providers are contractually required to store Biometric Information using appropriate security measures  

  5. Retention Schedule. Action Face will retain any Biometric Information  captured from the scanner for a period of no more than three (3) years from the date of collection and thereafter shall permanently destroy such Biometric Information from its systems. Service Providers that receive Biometric Information from Action Face are contractually required to permanently destroy it within three (3) years from the date of receipt.