Digital Identity LLC ("SelfiePay", "the Company", "we", "us") is a provider of facial payment services. We respect users' privacy and ensure the processing of personal data in compliance with the requirements of the General Data Protection Regulation (GDPR).
This Privacy Policy explains how we collect, use, store, and protect personal data, including biometric data, when using the SelfiePay mobile application.
1Legal Basis for Data Processing
The Company processes personal data only where an appropriate legal basis exists, including:
- The user's explicit and informed consent
- The necessity to provide services (performance of a contract)
- Compliance with legal obligations imposed by applicable law
2Categories of Data Processed
2.1 Ordinary Personal Data
- First name, last name
- Phone number and/or email address
2.2 Biometric Data (Facial Recognition)
SelfiePay processes biometric data, specifically a facial biometric template, for the purposes of identity verification and payment authorization.
Important clarifications:
- The Company does not store facial photographs or video recordings for identification purposes
- Facial data is converted into an encrypted biometric template
- Biometric data is used solely to verify the user's identity during the payment process
Biometric data is processed only on the basis of the user's prior, explicit consent.
2.3 Payment and Transaction Data
- Transaction identifier
- Payment date, time, and status
Note: SelfiePay does not store full payment card details (PAN, CVV). Payment processing is carried out by licensed and authorized payment service providers.
2.4 Location Data (During Facial Payment)
During the facial payment process, SelfiePay processes location data, specifically the user's location at the moment the payment is initiated.
Purposes of location data processing include:
- Additional verification of transaction security
- Fraud prevention (e.g., identification of unusual or suspicious transactions)
- Verification that the payment is performed at an authorized partner location
Important limitations:
- Location data is processed only at the time of payment
- Location data is not used for continuous tracking
- Location data is not used for advertising, marketing, or profiling purposes
- Users may disable location access at any time through their device settings
2.5 Device and Security Data
- Device identifiers necessary for fraud prevention
- Security logs related to authentication attempts
Such data is used solely to ensure system security and to prevent unauthorized access.
3Camera Usage
The SelfiePay application requires access to the device camera:
- To capture facial data during biometric enrollment and authentication
- Camera access is activated only through user interaction and solely for biometric identification purposes
Camera data is not used for advertising, marketing, or profiling.
4Purposes of Data Processing
The Company processes personal data exclusively for the following purposes:
- Digital identity verification
- Biometric payment authorization
- Fraud prevention and system security
- Customer and technical support
- Compliance with legal obligations
5Data Sharing
SelfiePay does not sell personal data.
Personal data may be shared only with:
- Licensed payment service providers
- Technology partners acting as data processors on behalf of the Company
- Authorized public authorities where required by law
Biometric data is never used for marketing or advertising purposes.
6Data Retention Periods
- Biometric data is retained only for as long as the user maintains an active account
- Location data is retained only for the period necessary to ensure payment security
- Transaction data is retained for the duration required by applicable law
Upon account deletion, biometric data is permanently deleted.
7User Rights and Account Deletion
7.1 Account Deletion
Users may request deletion of their account and associated data at any time:
- By using the "Delete Account" function within the application
- By submitting a written request to support@selfiepay.app
Following account deletion, personal data will be deleted within 10 business days, unless retention is required by law.
7.2 User Rights
Users have the right to:
- Obtain information about their personal data
- Request correction or updating of personal data
- Withdraw consent for data processing
- Request deletion of personal data
Withdrawal of consent may result in the limitation of biometric payment functionality.
8Data Security
The Company implements high-standard technical and organizational security measures, including:
- Encryption of biometric templates
- Strict access controls
- Continuous security monitoring
9Children's Data
The SelfiePay application is not intended for individuals under the age of 16, and the Company does not knowingly process personal data of children.
10Contact Information
For any matters related to personal data protection and privacy, you may contact:
Digital Identity LLC
📧Email:support@selfiepay.app
🌐Website:https://selfiepay.ge