AVENIQUE BIOMETRIC INFORMATION POLICY

Effective Date: September 21, 2026

This policy is publicly available and linked from the Privacy Policy and the in-app verification screen. It describes how we collect, use, store, and destroy biometric data used for identity verification and ban enforcement.

1. PURPOSE AND SCOPE

BafaTech Studio ("we," "us," or "our") operates the Avenique service. To protect our community from impersonation, catfishing, and fraudulent accounts, we require every member to complete a selfie verification with liveness detection. This process involves the collection and processing of biometric identifiers and biometric information ("Biometric Data") as those terms are defined under applicable law, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Nigeria Data Protection Act 2023 (which classifies biometric data as sensitive personal data).

This policy applies to all users worldwide. Where a jurisdiction imposes stricter requirements, the stricter requirement governs.

2. WHAT WE COLLECT

A live selfie image (with liveness-detection signals) captured during verification.
A mathematical representation (facial geometry template / embedding) derived from that selfie and from your profile photos, used to compare the two.
Where an account is permanently banned for a serious violation, a one-way, irreversible ban signal derived from the facial geometry template (the "Face-Derived Ban Signal"), used solely as described in Section 3.
Verification outcome metadata (pass/fail, timestamp, retry count).

We do not collect fingerprints, voiceprints, iris scans, or any other biometric identifier.

3. PURPOSE LIMITATION

Biometric Data is collected and processed solely to:

Verify that the person creating or operating the account matches the profile photos (anti-catfishing / anti-impersonation).
Detect and prevent verified-account compromise or rental (re-verification triggered by risk signals).
Enforce permanent bans. If your account is permanently banned for a serious violation of the Terms of Use, Community Guidelines, or Child Safety & CSAM Enforcement Policy, we may retain a Face-Derived Ban Signal and compare new verification attempts against it, solely to prevent banned individuals from returning to the platform. The Face-Derived Ban Signal cannot be reversed to reconstruct your face or the original template.

Biometric Data is never used for advertising, profiling for matching, training of matching algorithms, or any purpose beyond the three purposes above. We do not sell, lease, trade, or otherwise profit from Biometric Data. We do not disclose Biometric Data to third parties except: (a) to our verification vendor acting as a processor under a Data Processing Agreement listed in our Subprocessor List; (b) where required by valid legal process; or (c) with your further explicit consent.

Vendor restrictions:

We contractually require all biometric subprocessors to strictly adhere to these purpose limitations. Our subprocessors are legally prohibited from utilizing your Biometric Data, facial templates, or liveness signals to train, optimize, or improve their own proprietary machine learning models, artificial intelligence, or facial recognition systems. Your data is processed solely on a transient basis to execute the verification transaction for Avenique.

4. CONSENT

Before capturing any Biometric Data, the app presents a dedicated consent screen that:

Discloses that Biometric Data is being collected, each specific purpose listed in Section 3 (including ban enforcement), and the applicable retention periods;
Links to this policy in full;
Requires an affirmative, unambiguous action (checkbox plus button, not pre-checked, not bundled with general Terms acceptance).

The consent record (user ID, policy version, timestamp) is stored and is exportable in response to a data subject access request. Capture does not proceed until consent is recorded. This consent screen constitutes the written release required under BIPA and the explicit consent required under the NDPA 2023 and GDPR Article 9(2)(a).

Withdrawal: You may withdraw consent at any time via Settings → Verification. Withdrawal triggers destruction per Section 5 and removes Discover visibility, because Avenique is a verified-member directory. Withdrawal of consent does not require destruction of a Face-Derived Ban Signal already created in connection with a permanent ban, to the extent retention is permitted by applicable law for fraud prevention and platform safety; where applicable law does not permit such retention after withdrawal, the signal is destroyed.

5. RETENTION AND DESTRUCTION SCHEDULE

Vendor raw capture: The live selfie processed by our verification vendor is retained by that vendor only as long as its Data Processing Agreement allows (typically within seventy-two (72) hours of a verification decision). We do not store raw government-ID images on Avenique servers.
Enrollment reference image: We retain one liveness reference image in dedicated private storage while your account is active and your biometric consent remains in effect. That image is used solely to compare later profile photos you upload to the same person (anti-impersonation / gallery Face Match). It is not used to match you to other people, for advertising, or to train matching algorithms. We destroy it when you withdraw consent, when a replacement reference is confirmed after re-verification, or when we erase your account, subject to legal-hold and child-safety exceptions.
Facial geometry template / embedding: Retained while your account is active and biometric consent remains in effect, solely for uniqueness checks, photo-selfie binding, and (where applicable) ban-evasion comparison. It is destroyed on consent withdrawal or account erasure except as converted to a Face-Derived Ban Signal.
Templates retained for pending risk review: Until review closes, maximum 90 days, unless an enrollment reference or embedding is still required under the bullets above.
Face-Derived Ban Signal (permanent bans only): While the ban remains in effect, and in all cases no later than three (3) years after the ban is imposed, unless a longer period is required by an active legal hold or applicable law.
Verification outcome metadata (non-biometric): Life of account, subject to banned-user retention in the Privacy Policy.
Consent records: Life of account plus 3 years.

In all cases, Biometric Data other than the Face-Derived Ban Signal is destroyed no later than the earlier of (a) satisfaction of the verification purpose per the schedule above, (b) three years after your last interaction with the Service, or (c) your withdrawal of consent or account deletion (subject to the purge window in the Privacy Policy and the legal-hold exceptions in the Child Safety & CSAM Enforcement Policy). The enrollment reference is not treated as “purpose satisfied” merely because the initial liveness decision is complete; its purpose includes later gallery photo comparison for the life of the consented account.

6. STORAGE AND SECURITY

Biometric Data is stored encrypted at rest and in transit, in dedicated storage with access restricted to verification services. Access events are logged. Biometric Data is protected using a standard of care at least equal to that applied to other sensitive information we hold.

7. JURISDICTION-SPECIFIC PROVISIONS

Illinois (BIPA): Sections 4 and 5 constitute our written policy, retention schedule, and release mechanism. All Biometric Data, including any Face-Derived Ban Signal, is destroyed no later than the statutory outer limit.
Texas (CUBI): Notice and consent; destruction within the statutory period following purpose satisfaction.
Nigeria (NDPA 2023): Biometric Data is sensitive personal data; our lawful basis is your explicit consent; cross-border transfer of Nigerian users' Biometric Data occurs only under NDPA Part IX safeguards as described in the Privacy Policy.
EEA/UK (GDPR Art. 9): Explicit consent is the Article 9(2)(a) basis.

8. CHANGES

Material changes to this policy require fresh consent from affected users before continued biometric processing. Use the contact form at the bottom of this page for DPO or data-rights questions (choose Data Protection Officer or Data rights or deletion request).