Legal

Privacy Policy

How FacePOS collects, uses, and protects your personal data.

This Privacy Policy (“Privacy Policy”) sets out the ways in which FacePOS Limited (“FacePOS”, “company”, “we”, “us”, “our”) uses and shares personal information (“Personal Data”) we collect when you use our website, mobile application, portals, or any of our systems and services. It also reassures you of the importance we place on keeping your data secure, and the strict guidelines we apply to its use.

Any reference in this notice to “applicable laws” refers to the domestic laws of Ireland and the United Kingdom, including the General Data Protection Regulation (GDPR) and the relevant data protection laws in each jurisdiction.

If you have any questions about how your personal data is processed or if you believe your rights have been violated, please contact privacy@facepos.ie.

Your Data Protection Rights

FacePOS would like to ensure you are fully aware of your data protection rights. You are entitled to:

  • Access– Request copies of your personal data.
  • Rectification– Request correction of inaccurate or incomplete data.
  • Erasure– Request deletion of your data under certain conditions.
  • Restriction of Processing– Request limited processing of your data.
  • Object to Processing– Object to the processing of your personal data.
  • Data Portability– Request the transfer of your data to another organisation or directly to you.

Customers can request that their data be deleted at any time by contacting FacePOS. Upon request, FacePOS will delete all personal data in accordance with data protection laws, unless retention is required by law.

What Data We Collect

FacePOS collects various types of personal data for different reasons, such as to establish identity, contact users, or comply with legal requirements. Data collected may include:

  • Contact details (name, address, phone number, email)
  • Identity data (DOB, PPSN or NI number, nationality)
  • Financial data (bank details, transaction history)
  • Proof of identity (passport, driver's licence)
  • Proof of address (utility bills)
  • Facial biometric data (for facial recognition login and verification)
  • KYC/KYB details including shareholder information, business registration
  • Responses to questionnaires and feedback forms
  • Cookies and website interaction data (IP address, browser info)
  • Sensitive data (only where explicitly provided and necessary)

FacePOS uses facial recognition to verify your identity. The matching itself is performed by Amazon Rekognition, a service of Amazon Web Services, acting solely as our processor on our instructions, and your enrolled reference image is held in Amazon S3. All of this takes place in the European Union (Ireland). We do not sell your biometric data, and we do not share it with anyone else for their own purposes.

How We Collect Your Data

You directly provide FacePOS with most of the data we collect when you:

  • Sign up as a user or business via the FacePOS app
  • Submit onboarding forms or verification documents
  • Use our payment services (send, receive, or request payments)
  • Visit our website or use the app, where cookies collect browsing data

We may also receive personal data from:

  • Public sources (e.g. company registries)
  • Credit agencies and sanctions screeners
  • Partner institutions (e.g. our regulated partner Tink)

How We Use Your Data

FacePOS uses your data to:

  • Verify your identity or business (KYB/KYC)
  • Process and manage payments securely
  • Detect and prevent fraud
  • Comply with regulatory obligations (AML/CTF)
  • Respond to customer inquiries or complaints
  • Improve our product and service offerings
  • Send you updates or marketing (where consented)

Data Storage & Protection

We apply strict technical and organisational safeguards, including:

  • Encryption of sensitive data
  • Access controls and multi-factor authentication
  • Firewalls, anti-virus, and intrusion detection

Facial recognition data is encrypted at rest and is used exclusively for identity verification within the FacePOS platform. It is disclosed to one external party only — Amazon Web Services, which stores the image and performs the match as our processor under contract, within the European Union. We do not sell biometric data, and we disclose it to no one else.

While no method is 100% secure, we take all reasonable steps to protect your data.

Purpose & Legal Basis for Data Collection

We process your data:

  • To perform a contract– e.g., to deliver services you requested
  • To comply with legal obligations– e.g., anti-money laundering laws
  • For our legitimate business interests– unless overridden by your rights
  • With your consent– for certain communications or marketing

Who We Share Data With

We may share your data with:

  • Our regulated Open Banking partner (e.g., Tink)
  • Identity verification providers
  • Professional service providers (e.g., legal, audit, compliance)
  • Regulators, law enforcement, or tax authorities where legally required
  • Third-party vendors for operational support (under contract)
  • Our cloud infrastructure and facial-recognition processor, Amazon Web Services (EU/Ireland)

FacePOS does not sell your data, and does not share biometric or facial recognition data with third parties for their own purposes. The one exception is our cloud processor, Amazon Web Services, which stores your enrolled image and performs the facial match on our instructions.

Transfers Outside the EEA/UK

When data is transferred outside the EEA or UK, we use:

  • Countries with an EU adequacy decision
  • Standard Contractual Clauses (SCCs)
  • Other legally approved safeguards

Data Retention

FacePOS retains data for as long as necessary to fulfil legal or contractual obligations. Typically:

  • Minimum of 5 years from the end of the customer relationship
  • Longer if required for legal, fraud, or compliance reasons

Marketing

FacePOS may use your company name in marketing communications, case studies, or promotional material in an ethical and respectful manner. We will never disclose confidential or personal data without permission. With your consent, we may also send promotional communications. You can withdraw consent or opt out at any time.

Contract Termination

Customers may end their relationship with FacePOS at any time by providing written notice. Businesses may terminate their agreement with FacePOS with one month's notice, with no penalty or exit charge. All outstanding fees owed to FacePOS must be paid in full prior to termination.

Cookies

FacePOS uses cookies to enhance user experience. You can manage cookie settings in your browser or in the app. For more information, see our Cookie Policy.

External Links

Our website may link to external sites. This Privacy Policy applies only to FacePOS platforms. We are not responsible for the content or policies of external websites.

Changes to This Policy

This Privacy Policy is reviewed regularly and updated as needed. Last updated: 27 August 2026.

Contact Us

Email:privacy@facepos.ie
Address:An Chroi Digital Hub, Ballina Road, Tubbercurry, Co. Sligo, Ireland

Data Protection Authority

You have the right to lodge a complaint with your local Data Protection Authority:

Thank you for trusting FacePOS to handle your information responsibly.