FaceCards Privacy Policy

Last updated: 16 September 2026 This Privacy Policy explains how FaceCards collects, uses, stores and shares personal data across the website, account system, controller clients, calibration, device management, purchases, support and security systems. This policy reflects the FaceCards service and technical design reviewed as at 16 September 2026. If the production deployment, SDK versions, app-store configuration or third-party providers materially change, we will update this policy as appropriate. 1. Who we are and controller details FaceCards is operated by: ONECORTEX LTD Company number: 17374603 Registered in: England and Wales Registered office: 128 City Road, London, EC1V 2NX, United Kingdom General support, privacy, legal, intellectual-property and safety contact: facecardssupport@gmail.com “FaceCards”, “we”, “us” and “our” mean ONECORTEX LTD and the FaceCards service. “You” and “your” mean the individual accessing or using FaceCards. For the personal data described in this policy, ONECORTEX LTD is generally the controller unless a third-party service independently determines its own purposes and means of processing. 2. Who this policy applies to This policy applies to visitors, account holders, trial users, purchasers and users of released FaceCards web, extension, desktop and mobile controller surfaces. FaceCards is intended only for people aged 18 or over. People under 18 must not create an account, start a trial, purchase FaceCards or use the controller service. See the Age Eligibility and Under-18 Privacy Notice for how we handle under-18 access or data that reaches us despite this restriction. 3. Account and authentication data Depending on how you sign in and use FaceCards, we may process: • name or account display name; • email address and email-verification status; • internal account identifiers, role and account status; • password hash for password-based accounts; • OAuth account identifiers and tokens where an optional supported login provider is enabled; • account creation, update and activity timestamps; • session-security version and authentication/session information; and • security-token records for verification, reset or deletion workflows. We do not intentionally store your password in readable form. Password-based authentication uses a one-way password hash. 4. Camera video and local vision processing FaceCards needs camera access for camera-based gesture recognition. The intended processing path is camera → local vision/tracking → transient gesture signal → configured action. Raw camera frames are analysed on the device. FaceCards is designed not to upload or store raw camera video, face photographs, eye images, screenshots, continuous facial-landmark history or biometric identity templates in the FaceCards backend. The live tracking process may temporarily hold camera frames, landmarks and feature values in device memory for the time needed to recognise gestures. Stopping tracking should end the live camera/tracking session, subject to ordinary operating-system shutdown behaviour. 5. Derived calibration data synchronised to your account FaceCards currently supports account-synchronised derived calibration profiles. These are not raw images, but they are linked to your account and may be personal data. A saved calibration may include: • camera key, label and facing mode; • device identifier and device name associated with the calibration; • neutral eye/head measurements such as eye-axis and head yaw/pitch/roll baseline values; • noise measurements for those signals; • gesture thresholds, axis direction multipliers and sensitivity values; • per-gesture measured values, confidence, noise floor and signal-to-noise information; • tracking-quality and sample-count information; • which calibration steps were completed or skipped; and • calibration quality, completion, last-use and update timestamps. FaceCards uses this information to recognise your configured gestures more reliably and to allow a saved calibration to be reused where appropriate. The data is not intended to identify who you are and is not used by FaceCards for facial-recognition authentication or identity matching. FaceCards currently keeps up to 50 account calibration profiles per user through the controller API; older excess profiles are removed as new profiles are saved. You can rename or delete saved calibration profiles, and account-owned calibration profiles are deleted with the account subject to lawful backup/retention handling. 6. Control profiles, mappings and preferences We may store configuration data you save to your account, including tracking mode, sensitivity, hold/cooldown settings, control-set names, target labels or identifiers, gesture bindings, keyboard or action configuration, layout type, normalised screen-region coordinates and whether a profile should auto-switch. A mapped label or target identifier can reveal which app or website you use. Do not put secrets, passwords, confidential content or sensitive personal information into profile names or labels. FaceCards does not need to upload the contents of your flashcards, decks, study questions or answers merely to execute these mappings. 7. Device, pairing and controller data To enforce device limits and securely connect controller clients, we may process device and pairing information including: • a generated installation identifier or cryptographic hash; • device public identifier; • device name and platform; • optional device/fingerprint hash; • application or extension version; • first-seen, last-seen, active and revocation timestamps; • short-lived pairing records and controller-credential identifiers; and • security information needed to authenticate controller requests. Removing a device revokes its active controller relationship. A previously revoked installation may later be paired to another account without carrying the former account’s device record into the new account. 8. Trial and access data If a trial is enabled, we may process account creation time, trial start/end or expiry information, trial sessions and other limited records needed to decide whether free access remains available. The current access logic calculates the calendar trial from account creation time, so verification time may count within the trial. 9. Purchase, entitlement and billing data For purchases and entitlement management, we may process provider, transaction and checkout identifiers, product identifiers, payment status, amount, currency, purchase/refund timestamps, limited tax/country information, billing-customer identifiers and entitlement status. Payment-card credentials may be collected directly by Stripe, Apple, Google or another payment provider shown at checkout. FaceCards does not need to store your complete card number when the provider handles it. We may derive or send a stable pseudonymous account token to Apple or Google to help bind an in-app purchase to the correct FaceCards account without exposing the ordinary account ID unnecessarily. 10. Support communications If you contact support, we may process your account identifier, category, subject, message and technical context such as domain, platform, app version, browser or screen resolution where you provide or the support flow includes it. Do not send passwords, raw camera recordings, unnecessary identity documents or sensitive third-party information in support messages. 11. Security, fraud prevention and audit information We process information needed to protect accounts, purchases and infrastructure. This can include login success/failure events, rate-limit events, session revocations, audit actions, timestamps, user-agent information and network information. Some application security records use cryptographic hashes of identifiers such as IP addresses or user agents rather than storing those values in readable form. Hosting, network, email, payment and security providers may still process raw IP addresses as part of providing an internet service. 12. Legal acceptance records When you accept a published legal document, we may keep the document/version identifier, account identifier, acceptance timestamp and hashed security indicators derived from IP address and user-agent information. This helps us demonstrate which version was accepted and investigate abuse or disputes. 13. Aggregate product analytics FaceCards maintains a deliberately limited server-side aggregate usage model. Current aggregate fields include date, platform, app version, session totals, active time, gesture-trigger totals and device-start totals. The aggregate analytics table does not contain a user foreign key and is not intended to record what an identifiable person studied, which app content they viewed, or which specific gesture an individual performed. 14. Cookies and local device storage FaceCards uses cookies, browser storage, app storage and secure local storage for authentication, controller pairing, installation identity, calibration, mappings and other requested functions. Details are in the Cookie, Browser and Device Storage Notice. FaceCards does not currently intentionally use advertising pixels or behavioural advertising trackers. If we introduce non-essential tracking later, we will update our notices and obtain consent where required before activating it. 15. MediaPipe and computer-vision software FaceCards uses Google MediaPipe Tasks and associated model/runtime assets for computer-vision processing. Google’s current MediaPipe Tasks Privacy Notice states that input data such as images and video is processed on-device and is not sent to Google servers. FaceCards also does not intentionally upload raw camera images to the FaceCards backend. Google’s current MediaPipe Tasks information states that the APIs send performance and utilisation metrics to Google for purposes such as measuring performance and usage, debugging, maintenance and improvement. Google also describes usage data that can include SDK usage/session information, inference and hardware-level performance metrics, application and general input-media metadata, and system-environment information. FaceCards does not intentionally configure MediaPipe to transmit raw camera frames, study content or saved FaceCards calibration profiles to Google. Google states that developers are responsible for obtaining informed consent to Google’s processing of MediaPipe metrics where applicable law requires it; camera permission alone should not be treated as consent to unrelated third-party metrics processing. 16. Other recipients and service providers Where enabled or used, personal data may be processed by categories of provider including hosting/database providers, transactional email providers, payment processors, app stores, authentication providers, software-distribution/update infrastructure, customer-support infrastructure and professional advisers. Current production configuration may use services such as Vercel, Neon, Resend, Stripe, Apple and Google for the functions described above. This includes Google’s processing of MediaPipe performance/utilisation metrics described in section 15. A provider may act as our processor or as an independent controller for parts of its service, such as its own payment, store or SDK-metrics processing. We may also disclose information where required by law, to protect legal rights, to investigate fraud or security incidents, or in connection with a genuine corporate transaction subject to appropriate safeguards. 17. Our purposes and lawful bases Depending on the processing, we rely on one or more lawful bases under UK data-protection law: • Contract: to create and operate your account, provide the controller, save your requested settings/calibrations, enforce the device cap, deliver a trial or paid entitlement, provide downloads/updates and respond to service requests; • Legal obligation: for tax, accounting, consumer, regulatory and lawful disclosure duties; • Legitimate interests: to secure FaceCards, prevent fraud and abuse, maintain limited audit records, diagnose failures, understand aggregate product reliability and protect our legal rights, where those interests are not overridden by your rights; • Consent: where a particular optional processing activity, device permission, marketing technology or similar activity legally requires consent. Device camera/accessibility permission is also controlled through the relevant operating system or app flow. We do not rely on derived calibration data for biometric identification. If FaceCards ever changes purpose to identify or authenticate people from biometric characteristics, that would require a new legal assessment and updated privacy information before such use. 18. Age restriction and under-18 data FaceCards is an adult-only service. We do not knowingly offer FaceCards accounts, trials or purchases to people under 18. If we become aware that an account belongs to or is being used by a person under 18, we may restrict the account and take appropriate steps to delete or otherwise handle the associated personal data, subject to lawful security, fraud-prevention, accounting, dispute and legal-retention needs. See the Age Eligibility and Under-18 Privacy Notice. 19. International processing Some service providers or app-store/payment systems may process information outside the United Kingdom. Where UK data-protection law requires a transfer safeguard, we will use an applicable mechanism such as UK adequacy regulations, the UK International Data Transfer Agreement/Addendum or another lawful safeguard, as appropriate to the provider and transfer. You may contact us at facecardssupport@gmail.com for information about the safeguard relied on for a relevant transfer and, where applicable, how to obtain a copy of it. 20. Retention We keep personal data only for as long as reasonably necessary for the purposes described, taking account of account status, feature operation, security, legal claims, tax/accounting obligations and statutory requirements. • Account settings, control profiles, active devices and saved calibration profiles: generally while the account remains active, unless you delete a particular item earlier; • Expired pairing/security tokens: removed or expired according to their short operational purpose; • Purchase and accounting records: may be retained after account deletion, commonly for periods needed for tax, accounting, fraud prevention and legal claims; records may be detached from the user account where appropriate; • Legal acceptance and essential audit records: may be retained for the period reasonably needed to establish compliance, security history or legal rights; • Support records: retained for the time needed to resolve the matter and any reasonable follow-up, dispute or legal period; • Aggregate analytics without a user identifier: may be retained longer because it is designed not to identify an individual. Backups can persist for a limited period after live deletion before routine rotation. We do not keep identifiable personal data indefinitely merely because it might be useful later. 21. Security FaceCards uses technical and organisational measures intended to protect personal data, including hashed passwords, token hashing for sensitive links, restricted controller credentials, server-side session invalidation, rate limiting, access controls, audit logging and encryption or secure storage for selected credentials. No service can guarantee absolute security. You should use a strong unique password, keep your device secure and remove devices you no longer control. 22. Your data-protection rights Depending on the circumstances and lawful basis, you may have rights to be informed, access your personal data, correct inaccurate data, erase data, restrict processing, receive portable data and object to certain processing. You may also withdraw consent where processing is based on consent. Your right to object Where we rely on legitimate interests (or another basis to which the statutory right applies), you may object to that processing by contacting facecardssupport@gmail.com. We will assess the objection under applicable data-protection law and stop the processing where the law requires us to do so. Some rights are not absolute. We may need to keep limited information where required by law or where a lawful exemption applies. 23. Automated decision-making FaceCards uses automated logic to recognise gestures, apply user-defined mappings, enforce access/device rules and detect some security or rate-limit conditions. We do not currently use solely automated processing to make decisions about you that are intended to produce legal or similarly significant effects in the UK GDPR sense. 24. Account deletion and device-level data Account deletion removes account-owned records through the service’s deletion workflow, subject to lawful retention described above. Purchase records may remain detached from the user account where required. Deleting your FaceCards account does not necessarily erase local data from every device, browser profile or extension. You may also need to uninstall the app/extension or clear local storage on the relevant device. 25. Complaints Privacy questions or complaints may be sent to facecardssupport@gmail.com. You also have the right to complain to the UK Information Commissioner’s Office (ICO) if you believe your data-protection rights have been infringed. We encourage you to contact us first so we can investigate. 26. Changes and contact We may update this Privacy Policy when FaceCards, our providers or applicable law changes. Material changes will be communicated appropriately. Privacy contact: facecardssupport@gmail.com