FACIAL RECOGNITION DATA CONSENT FORM

(FOR ADVISORS)

To prevent fraud and ensure a fair and competitive environment for all advisors, we ask for your explicit consent to process your facial recognition data for identity verification purposes in connection with your advisor account. Please review this document carefully before deciding whether to consent, as it affects the collection, use, retention, and transfer of your facial recognition data.

1. Data collected

“Facial Recognition Data” means biometric data resulting from specific technical processing of facial images and video streams, used to uniquely identify or verify you. The Facial Recognition Data processed includes the following:

i. Face images and video streams. After you consent to enabling the camera permissions, we will collect face images and video streams for real-time face detection and identity verification. You may be asked to perform simple actions (such as turning your head or nodding) to confirm that you are a real, live person and to prevent impersonation or spoofing attacks.
ii. Facial feature templates and verification results (for example, pass or fail) derived from the above information.

Live video streams or transient facial images captured during verification are processed in real time and are not retained. The data above will be provided by you or collected automatically by our data processor's SDK.

2. Purpose of use

Your Facial Recognition Data is used solely for the following purposes:

i. Confirming that you are a real, live person;
ii. Verifying that the advisor account is used by its registered holder;
iii. Detecting and preventing impersonation, spoofing, and fraud;
iv. Preventing the creation or use of multiple advisor accounts by the same individual;
v. Enforcing account-related restrictions based on prior violations of Platform Rules, where applicable.

Your Facial Recognition Data is not used for public identification or marketing purposes.

3. Data retention period

The facial feature templates will be retained while your advisor account remains active, solely for future identity verification and duplicate detection.

Transient facial images and live video streams captured during real-time verification are processed immediately and not retained. Only the verification result (pass/fail) is stored.

After account termination, we will delete and require the service providers to delete your Facial Recognition Data within one (1) year, unless a longer period is required or permitted by applicable law.

4. International Data Transfers

To perform facial recognition verification, Facial Recognition Data is processed by a third-party facial verification service provider. Accordingly, such data may be transferred across borders outside the advisor’s jurisdiction, as described below:

Facial verification service provider: Alibaba Cloud (Singapore) Private Limited

Location: Singapore

The data is protected through technical measures such as encryption and contractual safeguards to ensure a level of protection equivalent to that required under applicable data protection laws.

5. Your rights, choices and alternative verification
5.1 Providing Facial Recognition Data is voluntary.

You have the right to refuse to provide Facial Recognition Data and have the right to withdraw your consent by submitting a request to [support@scifate.com] at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. You also have rights of access, rectification, erasure, etc. You can read our Privacy Policy for more details.

5.2 If you refuse to consent to Facial Recognition, or if you later withdraw your consent, you can contact us at [support@scifate.com] to request an alternative identity verification method, such as manual review. During this period, new applicants will not be able to register for an advisor account, and existing advisors may face temporary restrictions in certain features of their accounts, until we have completed the alternative identity verification process as requested by you. Alternative verification may require additional time or information.
5.3 If identity verification cannot be completed through either facial recognition or an available alternative method, registration requests for new applicants may be rejected, and existing advisors may have their accounts suspended or, where necessary, terminated, following an individual assessment of the security of the accounts.

If you have any questions regarding this consent or the processing of Facial Recognition Data, please contact us at [support@scifate.com].