FaceLock

FaceLock Terms of Use

Last Updated: July 3, 2026

These Terms of Use ("Terms") govern your access to and use of the FaceLock Creator Application (the "Creator App"), the FaceLock Reader application (the "Reader App"), the FaceLock Authenticator mobile application for elevated multi-factor authentication (the "Authenticator App"), associated APIs, services, websites (including facelock.id), and any related tools provided by FaceLock (collectively, the "Services"). The Services are operated by FaceLock, located at 1800 City Farm Dr, Bldg 1B, Baton Rouge, LA 70806, United States ("FaceLock", "we", "us", or "our").

By accessing, registering for, or using the Services, you agree to be bound by these Terms. If you are entering into these Terms on behalf of an organization (an "Issuing Authority"), you represent that you have the authority to bind that organization, and "you" refers to both you and the organization.

IMPORTANT: These Terms include important limitations on liability, dispute resolution provisions, and requirements regarding biometric-enabled credential issuance. Please read them carefully.

Critical Terms Regarding Face Data (Authenticator App): The FaceLock Authenticator processes Face Data (face geometry, depth, and liveness information) solely to provide elevated multi-factor authentication functionality. We do not use Face Data for advertising, marketing, profiling, or any other purpose. Facial biometrics are used exclusively to deliver the authentication service you or your organization have requested. Full details, including compliance with Apple's Developer Program License Agreement §3.3.52, are in the FaceLock Authenticator Privacy Policy.

1. Acceptance of Terms; Modifications

You must be at least 18 years old (or the age of majority in your jurisdiction) to use the Services. By using the Services, you agree to these Terms and our Privacy Policy (available at facelock.id/privacy). We may modify these Terms at any time. We will provide notice of material changes via the App, email, or website. Continued use after changes constitutes acceptance.

2. Description of Services

FaceLock provides a platform enabling Issuing Authorities to create biometrically bound credentials. Using FaceTec's 3D liveness detection and UR Code technology, the App facilitates the generation of digitally sealed, PKI-signed QR codes (UR Codes) that cryptographically bind a non-reversible representation of an end-user's face biometrics to credential data. These credentials — whether digital or printed — can be verified offline using the free FaceLock Reader app by comparing a live face scan to the sealed biometric reference.

Key privacy-preserving design:

  • FaceLock does not receive, store, or process raw biometric data, selfies, or reconstructible biometric templates.
  • All biometric processing occurs locally in the Issuing Authority's controlled environment via the FaceTec SDK.
  • FaceLock acts as a limited processor facilitating credential issuance infrastructure; Issuing Authorities remain data controllers for end-user personal data and biometrics.

3. FaceLock Authenticator for Elevated MFA

The FaceLock Authenticator App provides elevated multi-factor authentication ("MFA") for organizations using the FaceLock platform and integrated identity providers (such as Microsoft Entra ID). By enrolling a device and using the Authenticator App, you agree to the following additional terms:

Description of Authenticator Services:

  • The Authenticator App allows registered devices to receive push notifications for sign-in approval, perform on-device FaceTec 3D Liveness checks, and report verification results securely to FaceLock servers.
  • Supported challenge types include enrollment (one-time device and biometric binding), sign-in verification (elevated MFA for identity provider sign-in), and ad-hoc verification (administrator-initiated liveness challenges with a stated business purpose).
  • Biometric data (facemaps) is captured on your device via the FaceTec Device SDK and transmitted to FaceLock's secure servers for matching against your enrolled template.

Eligibility and Enrollment:

  • You must be at least 18 years old (or the age of majority in your jurisdiction) and authorized by your organization to enroll a device.
  • Enrollment requires a valid enrollment code from your administrator and completion of the FaceTec liveness process.
  • You are responsible for maintaining the security of your enrolled device.

Biometric Data (Authenticator):

  • Biometric information (Face Data) is collected and processed solely for identity verification and liveness detection during MFA challenges. It is never used for advertising, marketing, or unrelated purposes.
  • Facemaps are processed only within FaceLock's systems using FaceTec's licensed technology. FaceTec, Inc. receives only limited anonymized usage and billing data required for licensing — not facemaps or raw captures from Authenticator production flows.
  • You may unenroll your device at any time via the App's Settings, which revokes the device on our servers and deletes associated facemaps.

Acceptable Use (Authenticator):

  • Do not enroll devices for unauthorized users or share enrollment credentials.
  • Do not attempt to reverse engineer, decompile, or tamper with the FaceTec SDK or the Authenticator App.
  • Do not use the Authenticator App for any illegal purpose.

Your use of the Authenticator App is also governed by the FaceLock Authenticator Privacy Policy.

4. Account Registration and Security

To use the Creator App, you must create an account. You agree to provide accurate information and maintain the security of your credentials. You are responsible for all activities under your account. Notify us immediately of any unauthorized use.

5. Your Obligations as an Issuing Authority

As an Issuing Authority, you agree to:

  • Comply with all applicable laws, including data protection laws (GDPR, CCPA/CPRA, BIPA, etc.), when processing end-user personal data and biometrics.
  • Obtain all necessary consents, notices, and authorizations from credential holders before capturing or binding biometrics.
  • Ensure accurate, lawful issuance of credentials and maintain chain-of-custody records.
  • Not use the Services for illegal purposes, fraud, or to issue credentials without proper authority.
  • Implement appropriate security measures in your environment to protect biometric processing.
  • Promptly revoke or deactivate credentials when required (e.g., upon termination of relationship).

You are solely responsible for the accuracy of credential metadata and the legality of issuance.

6. Prohibited Conduct

You may not:

  • Reverse engineer, decompile, or attempt to derive the biometric binding or cryptographic processes.
  • Use the Services to create credentials for unlawful purposes.
  • Transmit malware, interfere with the Services, or attempt unauthorized access.
  • Misrepresent your identity or authority.
  • Circumvent any technical limitations.

7. Intellectual Property

The Services, including software, UR Code technology integration, designs, and trademarks ("FaceLock Marks"), are owned by FaceLock or our licensors. We grant you a limited, non-exclusive, non-transferable license to use the Services solely for creating and managing biometrically bound credentials during your active subscription.

You retain ownership of your credential metadata, but grant us a license to process it as necessary to provide the Services.

8. Biometric Data and End-User Privacy

FaceLock does not collect, store, or have access to raw biometric data or templates. Biometric processing is handled exclusively by the FaceTec SDK in your environment. The resulting credential contains only a one-way, cryptographically secured reference.

You (the Issuing Authority) are the data controller for end-user data. You must provide your own privacy notices and obtain consents required for biometric processing. FaceLock disclaims any liability for your compliance failures.

9. Payments and Subscription

Access to the Creator App may require a paid subscription. Fees, billing, and terms are specified in your order or subscription agreement. All fees are non-refundable except as expressly stated.

10. Termination

We may suspend or terminate your access for violation of these Terms, non-payment, or legal requirements. Upon termination, your right to use the Services ceases immediately. Sections concerning liability, IP, and governing law survive termination.

11. Disclaimers and Limitation of Liability

THE SERVICES ARE PROVIDED "AS IS" WITHOUT WARRANTIES OF ANY KIND. WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING ACCURACY, RELIABILITY, NON-INFRINGEMENT, OR FITNESS FOR A PARTICULAR PURPOSE.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, FACELOCK SHALL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE DAMAGES, EVEN IF ADVISED OF THE POSSIBILITY. OUR TOTAL LIABILITY SHALL NOT EXCEED THE AMOUNT PAID BY YOU IN THE 12 MONTHS PRECEDING THE CLAIM.

You acknowledge the inherent risks in biometric systems (e.g., false positives/negatives, spoofing attempts) and agree that FaceLock is not liable for verification outcomes.

12. Indemnification

You agree to indemnify, defend, and hold harmless FaceLock, its affiliates, and personnel from claims arising from your use of the Services, your issuance of credentials, your violation of laws, or your breach of these Terms.

13. Governing Law and Dispute Resolution

These Terms are governed by the laws of the State of Louisiana, United States, without regard to conflict of laws principles. Any disputes shall be resolved exclusively in the state or federal courts located in Baton Rouge, Louisiana.

14. Miscellaneous

  • Entire Agreement: These Terms (plus any subscription agreement) constitute the entire agreement.
  • Severability: Invalid provisions shall be reformed to the extent necessary.
  • Force Majeure: We are not liable for delays due to events beyond our control.
  • Assignment: We may assign these Terms; you may not without our consent.

15. Contact Us

Questions about these Terms? Contact us at:

FaceLock
1800 City Farm Dr, Bldg 1B
Baton Rouge, LA 70806
United States
Email: legal@facelock.id