Privacy Policy

1 Introduction

Welcome to MemoFaceAI ("we", "us", "our"). MemoFaceAI is a face-recognition-based attendance tracking application designed for both corporate organizations and educational institutions to manage attendance efficiently and securely.

This Privacy Policy explains what information we collect, how we use it, and the choices you have regarding your data when you use our mobile application ("App"). By using MemoFaceAI, you agree to the collection, use, and handling of your information as described in this policy.

We are committed to protecting the privacy and security of your personal information in compliance with applicable data protection laws and regulations.

2 Information We Collect

a) Personal Information

When your organization registers you on the App, the following personal information may be collected:

• Full name
• Member ID (Employee ID for corporate organizations; Student/Roll Number for educational institutions)
• Email address
• Phone/contact number
• Parent/guardian contact (if applicable)
• Department and section/class assignment
• Role within the organization (e.g., staff, accountant, student)

b) Biometric Data

• Facial images: Multiple photographs of your face captured during the registration process
• Biometric face templates: Compact mathematical representations derived from your facial images, used solely for identity verification during attendance marking. These cannot be reverse-engineered into facial images.
• Liveness detection data: Processed during attendance to verify you are physically present (anti-spoofing)

c) Attendance Records

• Entry and exit timestamps
• Date of attendance
• Associated department and section
• Synchronization status (whether the record has been uploaded to the server)

d) Device Information

• Device identifier (Android ID or iOS identifier)
• Device brand and model name
• Device type

e) Location Data

• GPS coordinates (latitude and longitude) — collected only when geofencing is enabled by your organization and only at the time of marking attendance

f) Authentication Data

• Username and login credentials (encrypted)
• Session tokens for secure authentication
• Tenant/organization identifiers

3 How We Use Your Information

We use the collected information strictly for the following purposes:

4 Biometric Data (Face Recognition)

Our App uses on-device machine learning models to process facial data. We take the handling of biometric data very seriously:

How Face Recognition Works

1. Face Detection: The App uses an on-device model to detect faces in the camera feed. No images are sent to external servers for this step.
2. Face Template Generation: A recognition model running entirely on your device converts facial images into a compact numerical template. This is a mathematical representation — not a photograph — used solely for verifying identity.
3. Liveness Verification: An on-device anti-spoofing model checks that a real, physically present person is in front of the camera, protecting against fraudulent use of photographs or recordings.
4. Identity Matching: The generated template is compared locally on the device against previously registered templates to confirm identity before recording attendance.

5 Location Data & Geofencing

The App includes an optional geofencing feature that may be enabled by your organization. When geofencing is active:

• Your GPS location is accessed only when you attempt to mark attendance.
• Your location is compared against your organization's predefined geofence boundary to determine if you are within the authorized area.
• If you are outside the geofenced area, the App displays a warning and prevents attendance from being marked.
• Location data is processed in real-time and is not stored or transmitted — it is used only for the instant geofence check.

6 App Permissions

The App requests only the permissions necessary for its core functionality:

7 Data Storage & Security

Local Storage (On-Device)

• SQLite Database: Member profiles, biometric face templates, attendance records, department and section data, and attendance policy configurations are stored locally in an encrypted database on your device.
• Shared Preferences: Session tokens, application settings, tenant configuration, and geofence parameters are stored in the device's secure key-value storage.
• Local Files: Face images captured during registration are temporarily stored on the device file system.

Server Storage

• Attendance records, member registration data (including facial images and face templates), and organizational configurations are synchronized with your organization's dedicated MemoFaceAI server.
• All data transmission between the App and server uses authenticated API requests with Bearer token authentication (JWT).

Security Measures

• Token-based authentication (JWT) for all API communications
• Session validation to prevent unauthorized access
• On-device biometric processing — face data is not sent to third-party cloud services
• Automatic session expiration and re-authentication requirements

8 Data Sharing & Third-Party Services

We Do NOT Share Your Data With Third Parties

Your personal information, face data (including facial images and biometric templates), attendance records, and location data are never sold, rented, or shared with any third-party advertisers, data brokers, analytics providers, or external entities. All face data remains strictly confidential and is used solely for the attendance verification purposes described in Section 4.

On-Device Processing Libraries

The following libraries are used entirely on-device and do not transmit any data externally:

• On-Device ML Runtime: Runs face detection, recognition, and liveness detection models locally on your device. No biometric data is sent to any third-party server.
• Location Services Library: Accesses the device GPS solely for geofence verification. Location data is processed locally and not transmitted to any third party.

9 Background Processing

The App uses background processing mechanisms (such as Android's WorkManager and iOS Background Tasks) to perform periodic background operations:

• Attendance Sync: When the device has an internet connection, unsynced attendance records stored locally are automatically uploaded to your organization's server at regular intervals.
• Member Data Sync: Member registration data is fetched from the server to keep the local database up to date.
• Boot Persistence: After a device reboot, sync tasks are automatically rescheduled to ensure no attendance data is lost.

Background processing does not access your camera, microphone, or location. It only transfers previously recorded attendance data to the server.

10 Notifications

The App uses local notifications only (not push notifications from external servers) to inform you about:

• Pending attendance records that have not yet been synced to the server
• Background sync task status (success or failure)

No marketing, promotional, or third-party notifications are ever sent through the App.

11 Data Retention

• Face Data: Facial images and biometric face templates are securely retained on our servers while the member's profile is active or deactivated by the organization. All associated face data is permanently deleted from our servers only upon explicit request or when the organization permanently deletes the user's account.
• On-Device Data: Attendance records and member data are retained on the device until successfully synchronized with the server.
• Server Data: Your organization controls the retention period for attendance records and member data stored on the MemoFaceAI server. The server securely stores this data even if an account is temporarily deactivated, until a deletion request is made.
• Account Deactivation: When a member is deactivated by the administrator, access to the App is revoked and all local biometric data on their device is purged. However, their data on the server remains securely stored until graduation, termination, or an explicit deletion request is submitted.
• Session Data: Authentication tokens expire automatically and are cleared upon logout.

12 Data Deletion Policy

We are committed to honoring your right to have your personal data — including sensitive biometric data — deleted upon request.

What Data Can Be Deleted

• Facial images and biometric face templates
• Personal information (name, member ID, contact details, department/class assignments)
• Attendance records, subject to your organization's legal retention obligations
• Device identifiers associated with your account
• All active session tokens and authentication records

How to Request Data Deletion

To request deletion, email us at loveneesh@metaguard.in with the subject line "Data Deletion Request". Please include your full name, Member ID, and organization name.

Processing Timeframe

• On-device data: Deleted immediately upon member deactivation or app uninstallation.
• Server-side data: Processed within 30 days of a verified request.
• Biometric data: Deletion is prioritized and completed within 15 business days.

13 Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Correction: Request correction of inaccurate or incomplete personal data.
• Right to Deletion: Request deletion of your personal data, including biometric data, subject to your organization's policies and legal obligations.
• Right to Restrict Processing: Request that we limit the processing of your personal data under certain circumstances.
• Right to Withdraw Consent: Withdraw your consent for data processing at any time.
• Right to Data Portability: Request your data in a structured, machine-readable format where technically feasible.

14 Children's Privacy

MemoFaceAI is designed for use in corporate organizations and educational institutions. While the App may be used by students in institutional settings, it is the responsibility of the institution to obtain appropriate parental or guardian consent for members under the age of 13 (or the applicable minimum age in your jurisdiction) before registering them in the App. We do not knowingly collect personal or biometric data from minors without proper organizational authorization.

15 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes:

• The "Last Updated" date at the top of this policy will be revised.
• We may notify your organization's administrator of significant changes.
• Continued use of the App after changes are posted constitutes acceptance of the updated policy.

We encourage you to review this policy periodically.

16 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact us:

• App Name: MemoFaceAI
• Email: loveneesh@metaguard.in

If you have concerns about how your data is being handled by your organization through MemoFaceAI, please first contact your organization's administrator or data protection officer.