Privacy Policy

Overview

At NotionTag, we are committed to protecting your personal information with the highest level of integrity. This policy is intended to inform you of our privacy practices in association with the collection and use of your information obtained through our website (www.facetagr.com), services, and applications. This Privacy Policy is incorporated into and subject to the Terms of Service as well as our other security policies.

The following comprises the terms of our policy:

NotionTag Technologies Private Limited. and its aﬃliates (collectively “NotionTag”, “we” and “us”) respect your privacy. This Privacy Policy describes the types of personal information (“Personal Information”) we collect through our facial recognition products and services (“FaceTagr Services”) and about our visitors (“Users”) via our online presence, which include our main website at https://www.facetagr.com, as well as services and websites that we enable Internet users to access, such as the portal (collectively, our “Sites”), Mobile Apps which we deploy to organizations who subscribe to use our services for their employees/contractors/ students etc ( collectively our Licensees ). They may have their own respective privacy policies, in which case the respective Privacy Policies shall supersede this. This Privacy Policy also describes how we use Personal Information, with whom we share it, your rights and choices, and how you can contact us for privacy related messages. We may modify or update this Privacy Policy from time to time, and upon its publication, it shall become effective and your continued use of the Sites or Apps indicates your acceptance. It is your responsibility to check the Privacy Policy regularly for modiﬁcations or updates to ensure your compliance.

1.Personal Information We Collect.

When you visit our Sites or Apps, we collect two types of information from you;

Personal Information, which you actively provide us, and Information automatically collected from your devices.

a)Personal Information that we collect from you. Personal Information is any information that relates to an identiﬁed or identiﬁable individual. The Personal Information that you provide directly to us through our Sites or Apps will be apparent from the context in which you provide the data.

If you are a User, when you appear in an authorized camera feed of a Licensee or conduct transactions through a Licensee’s application, we will receive your biometric data and any associated transaction information. Depending on how the Licensee implements our FaceTagr Services, we may receive this information directly from you, or from the Licensee or third parties. The information that we collect may include biometrics, and other information that is detected or can be derived from an image or other transaction conducted using the FaceTagr Services.

Different use cases and applications of our FaceTagr Services require the collection of different categories of information. The Licensee will determine the information it collects.

b) Information that we collect automatically on our Sites or Apps. Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites or Apps. Our mobile applications may collect and process information about your location, including GPS and other geolocation data, to provide certain features or improve the functionality of the app. This data is used only as necessary to provide the requested service or for analytical purposes to improve our app's performance and user experience.

2.Use of Personal data.

We use Personal Information to facilitate the business relationships we have with our Licensees, to comply with our ﬁnancial regulatory and other legal obligations, and to pursue our legitimate business interests.

Personal data Processing operation and purpose Lawful basis

1. Employee id/ Employee id/ Other unique id is required This is required for completing with contract

Other unique id to map the individual to the identity in the with the Licensee. Consent has to be obtained

licensee’s software. by Licensee to provide this information

2. Photograph Facial data will be used to confirm your This is required for completing contract with

identity for the sole purpose of verifying the Licensee. Consent has to be obtained by

you. Our app collects a close-cropped facial Licensee to provide this information

image to create a feature vector for user

identification and verification.

3. Location data Location data collected through our applications This is required for completing contract with

is processed to enable features that require the Licensee. Consent has to be obtained by

geographical information, such as identifying Licensee to provide this information

the user's vicinity to relevant service points

3.Automatic Collection, Retention and Sharing.

3.1 Automatic Collection

Device and Usage information automatically from our Apps:

We automatically collect and log certain information stored on your device (“Device Data”). For some of our Android apps, we collect Device make, Device Model, Device OS type (Android or iOS), Non persistent Device UUID. Our applications may collect precise or approximate location data based on the permissions you grant. Location data is collected to enable specific app functionalities as per the service offerings.

Information that we collect automatically on our Sites.

Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites, including:

Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services.[1] We use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues. We may also use Cookies to enhance your experience.

3.2 Retention of Personal Data

We are committed to the principle of storage limitation and will retain your personal data for no longer than is necessary to fulfil our processing purposes.

If you are licensing the FaceTagr Software (“Licensee”), we retain your Personal Information as long as we are providing the FaceTagr Services to you.

Following account deletion, revocation of consent or a written deletion request, your personal data will be retained for no longer than 30 days. We may retain Personal Information after we cease providing FaceTagr Services to you, even if you close your account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

We will also anonymize some personal data so it will no longer be associated with Licensee/the employees, contractors, students. In this event we are entitled to retain and use the information freely.

3.3 Sharing with Third Parties

NotionTag does not sell or rent Personal Information to marketers or unaﬃliated third parties. We share your Personal Information with trusted entities, as outlined below.

a) Service providers. We share Personal Information with a limited number of our service providers. We have service providers that provide services, such as website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Information to perform their services. We authorize such service providers to use or disclose the Personal Information only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and conﬁdentiality of Personal Information they process on our behalf. Our service providers are predominantly located in India and the United States of America.

b) Our Licensees and third parties authorized by our Users. We share Personal Information with Users as necessary to maintain a User account and provide the FaceTagr Services. We share data with parties directly authorized by a User to receive Personal Information. The use of Personal Information by an authorized third party is subject to the third party’s Privacy Policy.

c)Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Information with third parties for the purpose of facilitating and completing the transaction.

d) Compliance and harm prevention. We share Personal Information as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of NotionTag, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

4.Aggregating Data.

NotionTag can aggregate your non-personally identiﬁable data. By using the FaceTagr Services, you agree that we can access, aggregate and use non-personally identiﬁable data NotionTag has collected from You. This data will in no way identify you or any other individual.

NotionTag may use this aggregated non-personally identiﬁable data to:

Assist us to better understand how our customers are using the Service,
Provide our customers with further information regarding the uses and beneﬁts of the FaceTagr Service
Provide non identiﬁable reporting on trends relating to the customer’s business
Otherwise to improve the service.

5.Your Rights

In order to exercise your data protection rights, you may contact NotionTag as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Information.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on ﬁle. If we no longer need to process Personal Information about you in order to provide our services, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

If you are a Customer or User of a Licensee, please direct your requests directly to the Licensee.

6.Security

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Information. We maintain organizational, technical and administrative measures designed to protect Personal Information within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Information is only accessible to a limited number of personnel who need access to the information to perform their duties.

7.International Data Transfers

If required, Personal Information may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Information that we maintain about you to recipients in countries other than the country in which the Personal Information was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Information remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

8. Updates To this Privacy Policy and Notiﬁcations.

We may change this Privacy Policy from time to time to reﬂect new services, changes in our Personal Information practices or relevant laws. Any changes are effective when we post the revised Privacy Policy on the FaceTagr Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Information collected by posting them on our website.

9. Contact Information.

If you have any questions or complaints about this Privacy Policy, please send an email to legal@facetagr.com with the subject line “PRIVACY POLICY INQUIRY”.