Pepr Dates — Biometric Data and Consumer Health Data Notice
Pepr Dates is operated by Sparks Media Group LLC, doing business as Pepr Dates (“Pepr,” “we,” “us”). This notice covers photo verification, the optional feature that lets you earn the “Photo verified” mark on your profile. It explains what we collect, why, how long we keep it, who processes it, and the rights you have.
This notice is our written policy for biometric data, including for the purposes of the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, Washington’s biometric identifier law, and Colorado’s biometric data law. It is also our Consumer Health Data Privacy Policy under the Washington My Health My Data Act and Nevada’s consumer health data law (§8), because those laws treat biometric data as consumer health data.
It supplements our Privacy Policy. Where the two differ on photo verification, this notice applies.
1. Photo verification is optional
You never have to verify your photos to use Pepr. Not verifying does not limit your account, your matches, or what you can do. If you do not start a verification, we collect nothing described in this notice.
2. What we collect
When you choose to verify your photos:
- A live video selfie. Your browser streams a few seconds of video from your camera directly to our verification provider (§4), which checks that a real, live person is in front of the camera. Pepr never receives or stores the video.
- One still frame from that selfie. The provider returns a single image from the video, and we store it.
- Your main profile photo. This is a photo you have already uploaded. We send a copy to the provider so it can be compared with the selfie.
- The results. The provider returns a liveness confidence score and a similarity score between the selfie and your main photo. We store both, along with the outcome, the time of the attempt, and which profile photo was compared.
To compare the two faces, the provider measures the geometry of the face in each image. That measurement is a biometric identifier. It is made at the moment of the check and is not returned to us. We never receive, store, or keep a face template, face vector, or faceprint. The still frame we store is an ordinary photograph. We treat it, and the scores derived from it, as biometric data under this notice.
3. Why we collect it
We use this data for one purpose: to confirm that the person in your main profile photo is the person holding the account, and to display the “Photo verified” mark when they match.
- If the scores clear our bar, your photos are verified automatically.
- If they are borderline, a member of our safety staff looks at the still frame next to your main photo and decides. A person, not a machine, makes every decision that is not a clear pass.
- If the check clearly fails (for example, no live person or no face was detected), you see that result and can try again.
- If you later remove the photo that was compared, the mark lapses. Our staff can also remove the mark if they find it was given in error.
We do not use your biometric data to identify you to anyone, to search for you, to match you with other members, for advertising, or to train any model. Other members see only the “Photo verified” mark. They never see your selfie, your scores, or the outcome of a failed attempt.
We ask for your consent first. Before a verification starts, the app shows a short summary of this notice with a link to it, and asks you to agree. Nothing is collected until you do. We record the time and the version of this notice you agreed to.
4. Who processes it
We do not sell, lease, trade, or otherwise profit from your biometric data, and we never will. We disclose it only to the service providers below, which process it on our instructions and for no purpose of their own:
| Provider | What it does | What it processes |
|---|---|---|
| Amazon Web Services (Amazon Rekognition), United States | Runs the liveness check and the face comparison | The video stream, your main profile photo, the still frame |
| Google Cloud (Firebase), United States | Stores the still frame and the results | The still frame, the scores and the outcome |
We have instructed AWS not to store or use verification content to improve its own services.
Apart from these providers, we disclose biometric data only:
- if you ask us to, or consent to it; or
- when required by a valid warrant, subpoena, or other legal process, or to comply with a law that requires it.
5. How long we keep it, and how it is destroyed
This is our retention schedule:
| Data | Destroyed |
|---|---|
| The live video | Never received or stored by Pepr |
| The face geometry measured for the comparison | Never returned to Pepr. The provider uses it only to produce the scores |
| The still frame | Automatically, 30 days after the attempt is decided (passed, approved, rejected, failed, or expired). An attempt still waiting for review is destroyed no later than 90 days after it was taken, whether or not it has been decided |
| The scores, outcome and attempt record | When your account is deleted |
| Everything above | Immediately when you delete your account, and within 45 days of a request to withdraw consent or delete it (§6) |
In every case, we destroy biometric data once the purpose it was collected for has been met. That is always sooner than three years after your last interaction with Pepr. Destruction is permanent deletion from our storage. Encrypted backups may keep a copy for up to 90 days, after which it is overwritten. We do not restore it from backups for any other use.
The scores and attempt record cannot be used to recognise or identify you. We keep them while your account exists so we can show your verification status and review how the mark was earned if someone questions it.
6. Your choices and rights
- Withdraw your consent. You can withdraw consent at any time by emailing hello@peprdates.com from the address on your account. We will remove the “Photo verified” mark and destroy your still frames within 45 days. Withdrawing consent does not affect your account in any other way.
- Access and confirm. You can ask us to confirm whether we hold biometric data about you, and for a copy of it.
- Delete. Deleting your account destroys all of it. You can also ask us to delete only your verification data.
- Know who received it. You can ask for the list of every provider and third party that has received your biometric data. The list is §4, and we will tell you if it has changed.
We verify each request so that no one can act on your account in your name. We respond within 45 days, and we will tell you if we need up to 45 more days and why. We never charge you, and we never treat you differently for using these rights.
Appeals. If we decline a request, we will explain why. You can appeal by replying to that email with “Appeal” in the subject. We will respond to an appeal within 45 days. If we deny it, we will tell you how to contact your state Attorney General.
7. Security
We protect biometric data with at least the same care we use for the most sensitive personal information we hold. The still frame is stored encrypted. Member-facing apps cannot read it, and only our servers and authorised safety staff, who need it to review an attempt, can access it. Access by staff is limited to the review screens. The video stream and the comparison travel only over encrypted connections.
8. Consumer health data: Washington and Nevada
For residents of Washington and Nevada, this section is our Consumer Health Data Privacy Policy. The only consumer health data Pepr collects is the biometric data described in this notice.
- Categories we collect: biometric data, meaning the still frame, the scores derived from the selfie and your main photo, and the live video, which is streamed to our provider and never stored by us.
- Sources: you, through your device’s camera, and the main photo on your profile.
- Purpose and use: to verify your photos and display the “Photo verified” mark (§3), and nothing else.
- Sharing: we share consumer health data only with the processors in §4. We do not sell it.
- Consent: we collect it only after you agree in the app (§3).
- Your rights: to confirm whether we collect or share your consumer health data, to get the list of processors and third parties that have received it, to withdraw consent, and to have it deleted (§6). Deletion also reaches our processors, and our backups as described in §5.
- How to exercise them: email hello@peprdates.com. Appeals work as described in §6.
9. Changes to this notice
If we change this notice in a way that affects how we use biometric data, we will post the new version with a new version date. We will also ask for your consent again before your next verification, and we will not use data already collected for any new purpose without your consent.
10. Contact
Sparks Media Group LLC, DBA Pepr Dates
32 N Gould St
Sheridan, WY 82801, USA
Email: hello@peprdates.com