Privacy Policy

Validated Pty Limited Operating as the GeoFace App

1. We Respect Your Privacy

(a) Validated Pty Limited respects your right to privacy and is committed to safeguarding the privacy of our customers and software application users. We adhere to the National Privacy Principles established by the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.

(b) “Personal information” is information we hold which is identifiable as being about you.

2. Collection of Personal Information

(a) Validated Pty Limited will, from time to time, receive and store personal information you enter onto our software application GeoFace, provide to us directly or give to us in other forms.

(b) You may provide basic information such as your name (required), phone number (optional), address (optional), and email address (optional) to enable us to send information, provide updates, and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

(c) Additionally, we may also collect any other information you provide while interacting with us. This may include information extracted from photos you provide (e.g., upload), details extracted from documents you provide. Any government identity documents are deleted from our system once a biometric token is created by you and our system, and for verification purposes, we only retain the document number and your name. Your date of birth, address, and similar personal information is not kept in our system.

(d) GeoFace is patented technology that immutably confirms a persons location once that person chooses to activate the single action of the verification and the validation process (being a single point in time, for a person in a location .. it is NOT a tracking device). Our Patent essentially requires a commencing reference to a government issued ID, which confirms that an actual person exists and then facial data embeddings are created from the live person and confirmed against the government issued ID. The photo of the government issued ID is then deleted and only the ID number (ie driver’s licence number) and the person name is retained. We do NOT retain a copy of the government issued ID, nor dates of birth, addresses, expiry dates, and the like. Our App, Privacy Policy, and Terms and Conditions and processes have been reviewed by the ‘best’ IP lawyers in Australia and comply with the Privacy Act 1988 (Commonwealth).

Users have the choice to provide other information such as email address, phone, etc but these are optional for the user and not essential.

(e) GeoFace collects facial images from users through the mobile device’s camera during the verification process. These images are temporarily used to generate unique facial embeddings for identity verification purposes. The unique facial embeddings do not allow any re-creation of someone’s facial features.

(f) The collected facial images are processed in real time to generate facial embeddings, which are mathematical representations of the user’s facial features. These embeddings are used to:

Verify that the correct individual is present at a specific location (our patented technology). Once the embeddings are generated, the original ‘live’ facial image is immediately discarded and is not stored on the device or our backend systems.

3. How We Collect Your Personal Information

(a) Validated Pty Limited collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our software application, and when we provide our services to you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.

4. Use of Your Personal Information

(a) Validated Pty Limited may use personal information collected from you to provide you with information, updates, and our services. We may also make you aware of new and additional products, services, and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.

(b) The application may make third-party social media features available to its users. We cannot ensure the security of any information you choose to make public in a social media feature. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy.

Validated Pty Limited may contact you by a variety of measures including, but not limited to, telephone, email, SMS, or mail, only if you have decided to provide that information to us.

5. Disclosure of Your Personal Information

(a) We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services, required by law, national security, or to police upon their creation of an Incident Number for their investigation.

(b) We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding, or in response to a law enforcement agency request.

(c) We may also use your personal information to protect the copyright, trademarks, legal rights, property, or safety of Validated Pty Limited, its application, website, and customers or third parties.

(d) Information that we collect may from time to time be stored, processed in, or transferred between parties located in countries outside of Australia.

(e) If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

(f) By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

6. Security of Your Personal Information

(a) Validated Pty Limited is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss, and unauthorised access, modification, and disclosure.

(b) The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

(c) The face data or embeddings are never shared with any third parties. All processing is handled securely within the application and backend services. The generated embeddings are stored in our secure backend servers, which are encrypted and comply with industry standards for data protection. Since these embeddings are ‘compiled’ and irreversible, they cannot be reconstructed into the original facial image, and as such, are privacy-preserving. That is, we cannot replicate someone’s face.

(d) The original facial images are not retained at all—they are analysed and immediately discarded after generating the embeddings (within a few seconds). (see Clause 2(c) of our Privacy Policy) ‘Any government identity documents are deleted from our system once a biometric token is created by you and our system, and for verification purposes we only retain the document number and your name. Your date of birth, address and similar personal information is not kept in our system.’;

The facial embeddings generated during the signup process are retained in the system until the user decides to delete them or their account. Point in time or new embeddings generated during location verifications are retained only for the duration required to fulfil the verification purpose, after which they are securely deleted according to our data retention policy.

7. Access to Your Personal Information

(a) You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (th). A small administrative fee may be payable for the provision of information. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant, or misleading, please email us at Wal@GeoFace.com.au for privacy questions).

(b) We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

8. Complaints About Privacy

(a) If you have any complaints about our privacy practices, please feel free to send in details of your complaints to Wal@GeoFace.com.au. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

9. Opt-Out Right

(a) You can stop all collection of information by the application easily by uninstalling the application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at Wal@GeoFace.com.au.

10. Changes to Privacy Policy

(a) Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion, and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

11. Software Application

(a) When You Use Our Application

When you come to our application, we may collect certain information such as mobile unique device ID, the IP address of your mobile device, mobile operating system, the type of mobile internet browsers you use, and information about the way you use the Application. This information is used in an aggregated manner to analyze how people use our site, such that we can improve our service.

(b) Cookies

We may from time to time use cookies on our software application. Cookies are very small files which a website uses to identify you when you come back to the application and to store details about your use of the application. Cookies are not malicious programs that access or damage your computer, tablet, or smartphone. Most devices automatically accept cookies, but you can choose to reject cookies by changing your device settings. However, this may prevent you from taking full advantage of our application.

(c) Automatic Collection

The software application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browsers you use, and information about the way you use the Application.

(d) Third Parties

Our software application may from time to time have links to other applications or websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party applications and websites do not constitute sponsorship or endorsement or approval of these third parties. Please be aware that Validated Pty Limited is not responsible for the privacy practices of other such applications or websites. We encourage our users to be aware, when they leave our application or website, to read the privacy statements of each and every application or website that collects personal identifiable information.

(e) Geo-Location

When you visit the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display a location map with relevant advertisements. We will not share your current location with other users or partners unless that is required by a functionality of the Application you choose to use.

(f) Biometric Information

For certain functions provided via the Application, we may generate biometric tokens from one or more images of your face. We do not permanently store facial images, with these being deleted once biometric purposes are completed, and biometric tokens are generated from facial encoding technologies which do not permit re-creation of facial images.

(g) Images of Documents

For certain functions provided via the Application, we may require that you upload images of documents. We use these images to perform OCR extraction of textual information, and in some cases biometric token generation, and do not permanently store such images.

(h) User-Initiated Sharing of GeoFace Data

You may use the application to generate and share sets of data, which may contain information including your location at a point in time, and potentially aspects of personal information. These are only shared by you at your own request.