Consent notice

A face template is biometric data. FaceCard refuses to enroll anyone unless your app says the person accepted a privacy notice (consent_required). The notice is yours: you are the one asking people to scan their face in your app, so the words, the link and the version are your responsibility. FaceCard stores the version, time, IP address and user agent you send, and nothing else about what the person saw.

What a good notice says

Keep it short and plain. Say these things before the camera starts:

1. What you collect. A face template (a list of numbers made from the face), not a photo or video. Say whether your app keeps anything else.
2. Why. To recognize the person when they sign in to your app, and nothing else.
3. How long. Say when it is deleted. FaceCard deletes a template when the account or app is deleted, or 3 years after the last sign in, whichever comes first. If you keep data for less time, say so.
4. How to leave. How a person can withdraw consent or ask for deletion (a settings page, an email address).
5. A link to your full privacy notice, and a checkbox that is not ticked by default.

Also give people another way in. A person who says no, has no camera or does not match should not be locked out. See Email code sign in.

Let the SDK show it

In React, FaceCardEnroll shows a notice like this when you pass consentNotice (SDK 4.3.0 or later), and builds the consent object for you:

<FaceCardEnroll
  email={email}
  name={name}
  consentNotice={{
    policyUrl: 'https://app.example.com/privacy',
    policyVersion: 'your-notice-v1',
    appName: 'Example',
  }}
  onSuccess={({ token }) => onToken(token)}
/>

Details and every option are in React. Without React, or with your own design, show your own notice and pass the result yourself:

await fc.enroll({
  email,
  name,
  consent: { policy_version: 'your-notice-v1', accepted: true },
});

About policy_version

policy_version is a label for the exact notice the person saw. Use your own, such as 'your-notice-v1' or a date you control. Change it every time you change the notice in a way that needs fresh consent, and keep each version's text so you can show what a person agreed to. Do not copy FaceCard's own policy date: that names FaceCard's notice, not yours.

Sample notice page

Adapt this for your app. Replace the text in brackets. It is a sample, not legal advice.

Sign in to [App name] with your face

What we collect. When you set up face sign in, your camera scans your face and turns it into a face template. A face template is a list of numbers. We do not take or keep a photo or video of you. [Add anything else you store, such as your email and name.]

Why. We use the template only to recognize you when you sign in to [App name]. We do not use it for advertising, and we do not sell it. [Say who else handles it: FaceCard, our service provider, stores and compares templates for us.]

How long. We keep it until you delete your account, or until [3 years / the period you choose] after you last sign in, whichever comes first.

Your choices. You do not have to use face sign in. You can sign in with [an email code / another method] instead. You can withdraw consent and delete your template at any time from [Settings > Delete my face data / by emailing privacy@example.com].

More. [Link to your full privacy notice.] Version: your-notice-v1, [date].

[ ] I have read this notice and I agree to a face scan.

[Continue to face scan]

Rules of thumb when you adapt it:

• Do not describe anything your app does not do. If you keep photos, say so.
• Do not pre-tick the box, and do not hide the notice behind a link alone.
• Show it in the language your users read.
• Make it as easy to withdraw as it was to agree.

Not legal advice

Consent rules differ by place. Some jurisdictions have specific biometric privacy laws (for example Illinois BIPA, Texas, Washington, and the EU and UK GDPR for special category data), and they may require written policies, retention schedules or separate releases. This page and the SDK text are a starting point only. Read the rules that apply to your users and ask your own counsel to review your notice.

See also Security and privacy for what FaceCard stores and deletes.