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Face Verification Privacy Notice

Effective: June 2026 Applies to: Face verification during onboarding Match Marvel Private Limited
This notice supplements our main Privacy Policy and Terms of Service. It applies only to users who complete face verification.

1 What This Notice Covers

This notice explains specifically how SoulVi collects, uses, and deletes your biometric data during the one-time face verification process. It supplements our main Privacy Policy.

Face data is special-category / sensitive personal data under:

We process it only with your explicit, informed consent, which you give on the consent screen before the process begins.

2 What We Collect

During verification we collect exactly two things:

DataDescription
Liveness video frames A short sequence of frames captured by your front camera while you complete the challenge (blink twice, turn head left, turn head right)
Profile photos The photos you already uploaded to your SoulVi profile — these are compared against the liveness frame

We do NOT collect:

  • Fingerprints, voiceprints, or any other biometric modality
  • Continuous facial tracking after onboarding
  • Any data from your phone's gallery or other apps

3 How We Use It

The liveness frame is used for exactly one purpose: confirming that the person in your profile photos is the same person completing onboarding.

The process:

  1. Your device runs an on-device liveness check (detecting real eye blinks and head movement) to confirm a live person is present
  2. A single JPEG frame is extracted at the moment the challenge completes
  3. That frame is transmitted over TLS to our secure server
  4. Our face-matching system (running on our own servers — no third-party facial recognition API is used) compares the frame against your profile photos
  5. A similarity score is computed. If the score meets our threshold, your account is marked Verified
  6. The frame is permanently deleted from memory immediately after the comparison
Zero Retention

The liveness frame is never written to disk, never stored in a database, and never uploaded to cloud storage.

Your profile photos already reside on our servers as part of your account. They are used for the comparison and continue to be stored as your profile pictures.

4 Legal Basis

JurisdictionLegal Basis
IndiaExplicit consent — DPDP Act 2023, Section 9(1); SPDI Rules 2011, Rule 5
EU / UKExplicit consent — GDPR Art. 6(1)(a) + Art. 9(2)(a)
OtherExplicit consent as required by applicable law

You provide this consent on the dedicated consent screen before the camera is activated. You can withdraw it at any time (see Section 7).

5 Who Processes Your Data

RolePartyLocation
ControllerSoulVi (Match Marvel Private Limited)India
Face-matching processorSoulVi's own server infrastructure (DigitalOcean)India / regional data centre
Third-party facial recognitionNone — we do not use any external facial recognition provider

We do NOT share your biometric data with:

  • Advertisers or data brokers
  • Social media platforms
  • Any third-party facial recognition provider (AWS, Google, Azure, etc.)
  • Other SoulVi users

6 Retention

DataRetention Period
Liveness frame Zero — deleted immediately after comparison, never persisted
Face similarity score Stored in your verification record for our safety audit log — deleted when you delete your account
Verification status (verified / unverified) Stored as part of your profile — deleted when you delete your account
Profile photos Retained until you delete them or delete your account

7 Your Rights

8 Security

The liveness frame is:

Our server infrastructure undergoes regular security reviews. Access to verification systems is restricted to authorised engineers only.

9 Children

SoulVi is strictly for users aged 18 and above. We do not knowingly collect biometric data from anyone under 18. If you believe a minor has completed verification, contact us immediately at puja.koli@matchmarvel.com.

10 Changes to This Notice

If we make material changes to how we process biometric data, we will:

  1. Show an updated consent screen before the next verification
  2. Send an in-app notification and email (if provided)
  3. Require fresh consent if the legal basis or purpose changes

11 Contact

Grievance Officer / Privacy Contact

Name: Puja Koli

Match Marvel Private Limited

Email: puja.koli@matchmarvel.com

Mobile: 9226827265

Response time: within 72 hours · Resolution within 30 days