Biometric Data Policy

Twundle, LLC (“Twundle,” “we,” “us,” “our”) verifies every member's main photo, so the person you match with is the person in the picture. This policy explains what that check collects, what it is used for, and when each part of it is destroyed. It is our public retention and destruction schedule for biometric data, as Illinois' Biometric Information Privacy Act and the biometric laws of Texas, Washington and other places require.

Our Privacy Policy covers everything else we collect.

1. Why We Check Main Photos

A profile shows in Discover only once its main photo is verified, and a new main photo is verified before it replaces the old one. There are two ways to do it, and you choose. Choosing one never changes anything else about your account.

2. A Person Checks It

You take a selfie copying a pose chosen at random, and a person on our team compares it with your main photo by eye.

• No software measures or maps your face, and no face data is made or kept.
• The selfie is stored privately. Only the person checking it sees it, through a private link that stops working within two hours. It never goes on your profile, and other members never see it.
• The selfie is destroyed as soon as they decide. If the check stops before then, because you deleted the photo or your account, it is destroyed within an hour.
• We keep only whether your photo was verified, when, and by whom; or, if it was not, the reason we gave you.

3. The Face Check

We are building a faster way, a face check that answers in seconds. Until it is offered, only the way in section 2 is used, and nothing in this section applies to you. We will tell you before it starts.

3.1 What It Collects

• A live selfie: a few seconds of video from your camera, used to confirm that a real person is there and to compare your face with your main photo.
• A face template: a set of numbers computed from the shape of your face. It is not a photo, and a photo cannot be rebuilt from it.

3.2 What It Is Used For

Only these three things:

1. Checking that the selfie matches your main photo.
2. Stopping one person holding two accounts.
3. Stopping someone whose account we removed as fake or a scam from signing up again.

We never use it to show, rank or match profiles, for advertising, or to identify you to anyone. We never sell, lease or trade it, or profit from it in any other way.

3.3 Who Processes It

The check is run for us by Amazon Rekognition, a service of Amazon Web Services, acting only on our instructions. We offer the face check only on terms under which the service keeps nothing of your selfie once the check ends and uses none of it to train its systems. We do not share face data with anyone else, unless the law requires us to.

3.4 Your Consent

Before the camera opens, we explain what the check collects, why, and for how long, and ask for your yes. We record that you agreed, the version of the words you were shown, and when. If you say no, a person checks your photo instead (section 2).

4. How Long We Keep It, and When It Is Destroyed

• A person-checked selfie: destroyed as soon as the decision is made, or within an hour if the check stops first.
• The face check's selfie and video: destroyed when the check ends, by us and by the service.
• A face template: kept while your account is open. Destroyed when your account is closed, whether you delete it or we do, or 3 years after you last used Twundle, whichever comes first.
• A face template from an account removed as fake or a scam: kept 180 days after the removal, only to stop that person returning, then destroyed.
• Whether your photo was verified, and when: kept while your account is open, and deleted with it.

Each time a selfie or face template is destroyed, we keep a record that it was, and when. The record holds only reference numbers: never a photo or face data.

To have your face template destroyed sooner, without closing your account, ask us through privacy@twundle.com. Your profile stays as it is, and a later check uses whichever way you choose.

5. How We Protect It

Selfies and face templates are encrypted in transit and at rest, and reachable only by the systems that run the check and, for a person-checked selfie, the person deciding it. We protect them at least as carefully as the other confidential information we hold.

6. Changes to This Policy

If we change what we collect, why, or for how long, we update this page first and ask for your consent again before the change applies to you.

7. Contact Us

Twundle, LLC

privacy@twundle.com