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BIPA Notice - Biometric Information Privacy Act Notice

Effective Date: September 3, 2024

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Introduction

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This Biometric Privacy Policy ("Policy") explains how Justplay GmbH ("Company," "we,""our" or "us") collects, uses, stores, and protects biometric data obtained through the FaceTec software ("FaceTec") when you use our JustPlay App (the “JustPlayApp”), particularly in accordance with the Illinois Biometric Information Privacy Act (BIPA) of 2008, 740 ILCS14. (740 ILCS 14/1) (“BIPA“).

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What is Biometric Information?

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​Biometric Information is any information, however generated, stored or shared, that is basedon an individual’s biometric identifier, and used to identify that individual.

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In case of the JustPlayApp, only face geometry by utilizing facial recognition technology isused as a biometric identifier through facial recognition technology.

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We require you undergo a facial recognition scan before we are able to pay out collected coins.

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Collection of Biometric Information​

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We collect and process the following Biometric Information through the camera of yourmobile or handheld during your verification within our payout process:

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  • Facial images and geometric data points to create a unique biometric template.

 

Prior to using your Biometric Information for the first time, we will require you to consent tothis Policy.

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Purpose of Collection

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We collect and use biometric data solely for the following purposes:

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  • Real person verification: To authenticate and verify that you are a real person

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  • Fraud prevention: To prevent unauthorized access and fraud

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  • Minor identification: To ensure that users are not underaged minors

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  • User experience: To improve and customize user interactions

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Storage and Protection of Biometric Data

 

Your Biometric Information will solely be stored in our rented server space on the servers of Google Cloud EMEA Ltd. (please see our general privacy policy in this regard). We implement robust security measures, including encryption and secure storage, to protect your biometric information from unauthorized access, disclosure, or misuse.

 

Biometric data is stored 4 months to fulfil the purposes outlined in this Policy or as required by law.After this period, the data is securely deleted.

 

Sharing of Biometric Data

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In general, we do not disclose or share your Biometric Information with any third party, but do so only under the following circumstances:

 

  • Service Providers: With Google Cloud EMEA Ltd. for storage on their servers.

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  • Legal Requirements: When required by law, regulation, or legal process, such as acourt order or subpoena.

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Your Rights

 

You have the following rights regarding your biometric data:

 

  • Access: Request access to your biometric data.

 

  • Correction: Request corrections to any inaccurate or incomplete biometric data.

 

  • Deletion: Request the deletion of your biometric data, subject to certain legal exceptions.

 

  • Withdrawal of Consent: Withdraw your consent to the collection and use of you rbiometric data, noting that this may affect your ability to use FaceTec.

 

How to Exercise Your Rights

 

To exercise any of your rights or if you have any questions about this Policy, please contactus at:

 

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  • Address: Justplay GmbH Monbijoupl. 5, 10178 Berlin

 

Changes to This Policy

 

We may update this Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the new Policy on our website or through other communication channels. Your continued use of FaceTec after such changes constitutes your acceptance of the revised Policy.

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