Biometric Data Notice

What biometric data we collect

• Facial images captured during identity verification (KYC) and during the "liveness" check (proof that you are a real, present person).
• Derived facial features, used to compare your face against the reference photo.

Why

• To confirm you are the enrolled person (anti-fraud).
• To keep participation and the learning-time records required by your employer trustworthy.

Legal basis

Explicit consent under Art. 9(2)(a) GDPR. Processing does not start without your agreement, given separately from the other terms.

Who processes the data

Face verification is performed by Amazon Web Services (Rekognition) in an EU region, and document verification by Didit, both acting as processors under our instructions. Images are stored securely (encrypted).

How long we keep it

• Frames captured during the liveness check are deleted automatically at most 90 days after capture.
• The reference photo is kept only while you remain enrolled and active; it is deleted when your membership is deactivated or your account is removed.
• Liveness scores and review records are kept as evidence that the check took place, but the pointer to the image is cleared when the image goes.

Withdrawing consent

You can withdraw consent at any time by writing to contact@fonetix.ro. Note that, without biometric verification, you will not be able to access features that require a verified identity; your employer may require an alternative method.

No other uses

We do not use your biometric data for other purposes (e.g. surveillance, advertising) and we do not sell it.