Facial Mapping Notice and Consent Policy

Effective Date: 11 October 2026

1. Introduction

This Facial Mapping Notice and Consent Policy ("Policy") explains how Clocktone Ltd. ("Company", "we", "our" or "us") collects, uses, stores, and protects facial mapping data obtained through the FaceTec software ("FaceTec") when you use our App (the "App"). To the extent there is any inconsistency between this Policy and the above Privacy Policy, this Policy controls with respect to facial mapping data and photos collected through the FaceTec software. This Policy is intended to comply with any federal, state, or local laws that may apply to the facial mapping data. By proceeding to use the FaceTec software, you confirm that you are not doing so from within a jurisdiction where such use is prohibited.

2. Collection of Facial Mapping Data and Photos

In order to use the redeeming feature within the App for the first time, you will need to use your device's camera and software provided by FaceTec that is embedded within the App to scan your face and provide us with facial mapping data that is unique to you, as well as a photo of your face. We use the facial mapping data and photo for the following purposes:

Real person verification: To verify that you are a real person
Fraud prevention: To prevent unauthorized access and fraud. We compare the facial mapping data that you provide with facial mapping data that has been provided by other App users within the last four months to help prevent the same user from creating multiple accounts. We store the facial mapping data that you provide for four months and use your facial mapping data for this purpose as well.
Minor identification: To ensure that users are not underaged minors

3. Storage and Protection of Facial Mapping Data and Photos

Your facial mapping data and photo is stored in our rented server space on the servers of Google Cloud Services provided by Google Cloud EMEA Ltd. (70 Sir John Rogerson's Quay, Dublin 2, Ireland) (please see our general privacy policy in this regard). We implement robust security measures, including encryption and secure storage, to protect your information from unauthorized access, disclosure, or misuse.

Your facial mapping data is stored for up to 4 months and then is securely deleted. Your photo is stored for up to 1 month and then is securely deleted.

Other than as described in this Policy, we do not sell, lease, trade, or otherwise profit from your facial mapping data or photos. The FaceTec software runs within our own environment, and we do not share your facial mapping data or photos with FaceTec. As noted above, the facial mapping data and photos are stored on Google Cloud Services. We may disclose your facial mapping data and photos when required by law, regulation, or legal process, such as a court order or subpoena.

5. Your Rights

Depending on the jurisdiction in which you reside, you may have the following rights regarding your Facial Mapping Data:

Access: Request access to your Facial Mapping Data, and/or information regarding how and why your Facial Mapping Data was collected, and any parties to whom we have disclosed your Facial Mapping Data.
Correction: Request corrections to any inaccurate or incomplete Facial Mapping Data.
Deletion: Request the deletion of your Facial Mapping Data, subject to certain legal exceptions.
Withdrawal of Consent: Withdraw your consent to the collection and use of your Facial Mapping Data, noting that this may affect your ability to use FaceTec.

6. How to Exercise Your Rights

To exercise any of your rights or if you have any questions about this Policy, please contact us at:

Email: privacy@clocktone.io

Address: Karaiskaki 6, City House, 3032 Limassol, Cyprus

Questions?

For any inquiries and additional questions about processing personal data please contact privacy@clocktone.io. Our contact details may also be found above or in the imprint under the App's settings menu.