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Check Twice

Biometric policy

Last updated:

Check Twice uses images of your face to check it’s really you. Comparing faces uses measurements of a face, which is biometric data. We only do it with your consent, given when you tap “Agree and continue” before your first quick photo. FusedFrames Technologies Ltd (“FusedFrames”, “we”), 23 King Street, Suite 191, Cambridge CB1 1AH, United Kingdom, which makes and operates Check Twice, collects and holds it.

What we collect

  • Photos of your face taken by the Check Twice app, or in a browser from a link sent with “Verify them on another phone”.
  • The side of your ID with your photo on it, and the photo on its chip if it has one.
  • The measurements of a face made to compare two photos.

Why

To check you’re a live person, that you match your ID and later that it’s still you when you sign in or someone asks you to verify, and, only if you choose, to show a photo of your face to people on Check Twice as further proof. Nothing else. We never use it to work out anything else about you, such as your mood, health, sex or ethnicity. We never sell, rent or trade it, and never use it for advertising. A summary of our assessment of why using faces is necessary and proportionate is available on request.

If you would rather not

It’s your choice: no law requires it. Check Twice can’t work without it, as checking it’s really you is what it does, so without a quick photo you can’t join or prove it’s you.

Showing your photo

Nobody sees your face photo unless you choose. You can show it to everyone who can see you’re verified (in the app, Account, then Security & privacy, then “Show face photo”), or share it with one person from their page. They see it on your verified card. It is the photo from when you joined, or from your latest Reverify while you show it. Turn it off, or stop sharing it, at any time.

Who else handles it

Amazon Web Services finds faces in these photos and compares them for us, and nothing more. Everyone who handles personal data for Check Twice is on our subprocessors page. We share it with no one else unless you choose to show your photo to someone or the law requires us to.

How long we keep it

  • One photo of your face, from when you join, so we can check it’s you in future: until you delete your account or 3 years after you last use Check Twice, whichever comes first.
  • The photo of your face from signing up, if you choose to verify later: until you finish signing up or 30 days after you chose to, whichever comes first.
  • The photo from your latest Reverify, if you show your photo to anyone: until you stop showing it to everyone, and never longer than the one from when you join.
  • Every other photo of a face, and your ID’s: deleted once the check is done.
  • The measurements made to compare faces: never kept.

How we protect it

Your face photos are encrypted, and only Check Twice’s own systems can open them. We protect them at least as carefully as any other confidential data we hold.

Withdrawing your consent

Delete your account in the app at any time (Account, then Delete account). Your face photos are deleted with it straight away. To stop showing your photo, turn off “Show face photo” or stop sharing it, in Account, then Security & privacy. Questions, or to ask for a copy of what we hold or have it corrected: legal@fusedframes.com. You can also complain to the data protection authority where you live (in New Zealand, the Privacy Commissioner). More about your data and rights is in our Privacy policy.