Date last updated: 26/Aug/2024
​

1. Introduction and GDPR Compliance

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data (General Data Protection Regulation - GDPR), Bouncer Digital S.L. informs users of both the Bouncer mobile app and web app (hereinafter collectively referred to as "the Application") about the processing of personal data that they voluntarily provide during the registration, access, and use of the service.

​

2. Data Collection

​

2.1 Personal Information
To proceed with the registration, access, and subsequent use of the Application, the User must voluntarily provide personal data, including identification, contact information, images, and biometric data, which will be processed by Bouncer Digital S.L.

 

2.2 Facial Data Collection and Use

We collect facial biometric data in the form of 3D Facial Maps solely for the purpose of identity verification as part of our Know Your Customer (KYC) process. This data is used to confirm that the person accessing the account is indeed the authorized user. The data is encrypted during processing and is not retained or stored after the verification is complete. Once the identity verification process is finished, the data is immediately deleted and is not kept or accessed again.

​

3. Purpose of Data Processing

The collection, processing, and management of the data provided by Users are carried out by the Data Controller to ensure the correct operation of the Application, maintain the service relationship with the User, and manage, administer, and improve the service. Bouncer Digital S.L. does not retain any personal data once it has served its purpose.

​

4. Legal Basis

The processing of User data is carried out based on the following legal grounds:

• The User's acceptance of the age verification service provided by the Application, which involves matching biometric and identification data, a service whose terms and conditions will be made available to the User for prior acceptance.

• The User's free, specific, informed, and unequivocal consent, provided by accepting this privacy policy through a clear affirmative action, such as ticking a checkbox provided for this purpose.

• If the User does not provide accurate or complete data to Bouncer Digital S.L., the use of the Application may not be possible.

 

5. Data Retention, Storage, and Security

​

5.1 Data Retention
Bouncer Digital S.L. does not retain personal data beyond the time necessary for the processing purpose. All data is promptly deleted once it is no longer needed for the operation of the Application or when the User requests its deletion.

 

5.2 Storage and Security of Facial Data
Facial data is securely stored in an encrypted database, protected by a combination of RSA asymmetric encryption and randomized AES-256 encryption. The data is not accessible to human operators, as the processing is fully automated. We adhere to industry-standard security practices, including regular encryption key rotation, to protect user data. However, once the identity verification process is complete, this data is not retained.

​

6. Data Recipients and Retention

 

6.1 Facial Data Retention and Deletion
Once the identity verification process is complete, the 3D Facial Map data is deleted. If a user chooses to delete their account, all user-generated data, including the 3D Facial Map, is deleted immediately. This reflects our commitment to user privacy and control over personal information.

 

6.2 Other Recipients and Data Retention
Data will not be shared with any third party outside Bouncer Digital S.L., except as required by law or with the User's prior consent.

 

7. Exercise of Rights

Bouncer Digital S.L. informs Users that they have the rights of access, rectification, limitation, deletion, opposition, and portability of their data, which they can exercise by sending a request to the email: privacy@bouncer.global. Additionally, Users have the right to revoke their consent at any time and to file complaints with the Spanish Data Protection Agency (AEPD).

 

8. Commercial Communications by Electronic Means

In compliance with the LSSI (Law of Services of the Information Society), Bouncer Digital S.L. will not send advertising or promotional communications via email or other equivalent electronic means that have not been previously requested or expressly authorized by the recipients. In the case of users with a pre-existing contractual, legal, or service relationship, the Data Controller is authorized to send commercial communications related to products or services similar to those initially contracted with the customer. If the User wishes to unsubscribe from receiving such communications, they can do so by sending an email to: privacy@bouncer.global.