Biometric & Identity Verification Policy

1. Scope and controller

This Policy supplements the Privacy Policy and applies primarily to creator applicants, approved creators undergoing re-verification, studio representatives, studio-managed performers, co-performers where verification is required, and persons subject to sensitive payout or account-control review.

The controller is [INSERT FULL LEGAL OPERATOR NAME], established in Romania. Privacy contact: [INSERT PRIVACY EMAIL].

2. Who must complete verification

Verification may be required before broadcasting, monetization, paid creator content, creator earnings, payouts, sensitive payout-detail changes or continued creator access.

Viewer identity or age verification, if introduced separately, will be governed by a specific notice describing that processing.

3. Purposes

• Confirm that performers and relevant representatives are adults.
• Confirm identity and document association.
• Confirm that the person completing the check matches the submitted identity document.
• Prevent impersonation, account takeover and unauthorized studio submissions.
• Determine eligibility for broadcasting, monetization and payouts.
• Support consent, fraud, safety and payout investigations.
• Maintain evidence of verification, review and legal acceptance.

Verification data is not used for unrelated advertising or ordinary marketing.

4. Information processed

Identity and document data

Legal name, date of birth, country, account identifiers, stage name, identity-document images, document type, issuing country, expiry information, machine-readable data where applicable, and authenticity or consistency indicators.

Selfie and liveness data

Selfie images, short liveness video or image sequences, challenge-response information, liveness result and replay, mask, screen or spoof indicators.

Facial-comparison and biometric-related data

Facial landmarks or geometry, derived facial representation, document-to-selfie comparison result, similarity score, duplicate-account indicator and technical confidence values where the implemented system generates them.

Review and audit data

Verification timestamp, result, recheck status, admin decision, reason category, consent evidence, accepted policy version, IP address, user-agent, access logs and payout-eligibility status.

5. Identity images and biometric data

An identity-document image, photograph or selfie is personal data. It is not automatically special-category biometric data merely because it contains a face.

Where technical processing extracts or uses physical or behavioural characteristics to uniquely identify or confirm the identity of a person, the resulting information may constitute biometric data under Article 9 GDPR.

Pulscam must document which raw files and derived data are created, who creates them, who stores them, the purpose, access and retention.

6. Internally operated verification workflow

Pulscam’s primary verification process is operated through internally controlled workflow, document-review, liveness, facial-comparison and administrative-review components.

The workflow enforces the required sequence and may:

• identify the documents and declarations required for the applicant type;
• confirm whether every required item has been submitted;
• evaluate document readability, completeness, expiry and supported-document indicators;
• compare names, dates of birth, country information and account details across the submitted records;
• compare the face shown in the selfie or liveness capture with the face shown in the identity document;
• evaluate liveness and anti-spoofing indicators;
• identify missing, inconsistent or mismatched information;
• determine which step must be repeated;
• route only complete applications to mandatory manual review.

The workflow supports verification, completeness, consistency and routing. It does not independently grant final creator approval.

7. Incomplete applications and recheck

An application does not proceed to final administrative review where a document is missing, unreadable, expired or unsupported; information is incomplete; account and document information does not match; selfie or liveness evidence is unsuitable; face comparison or liveness remains unresolved; consent is missing; or another required record is incomplete.

Where reasonably possible, Pulscam returns the applicant to the exact step requiring correction. The applicant may upload a replacement document, repeat selfie or liveness, correct inaccurate data, provide an omitted declaration, submit supporting evidence or explain an inconsistency.

RECHECK REQUIRED is not by itself a finding of fraud or permanent ineligibility.

8. Complete package and mandatory admin review

An application is routed to ADMIN REVIEW PENDING only after the workflow confirms that the required package is complete and ready for human assessment.

The administrator may review identity-document images and metadata, authenticity and consistency indicators, selfie and liveness evidence, comparison results, account data, consent and authorization records, recheck history and relevant mismatch or risk indicators.

The administrator determines whether the document is acceptable, the information is consistent, the applicant matches the document, liveness and age eligibility are established, required consent exists and unresolved risks remain.

The administrator records APPROVED, RECHECK REQUIRED, REJECTED, or SUSPENDED PENDING ADDITIONAL REVIEW.

A workflow-complete result means only that the case is ready for manual review. It is not creator approval.

9. Creator activation gate

Only a final APPROVED decision recorded by an authorized administrator permits creator activation.

Before APPROVED status is recorded, the applicant must not broadcast live, activate monetization, receive tips, conduct private paid interactions, publish paid creator content, accumulate payable creator earnings, access payout functions or receive creator payouts.

Successful document submission, liveness, face comparison or automated workflow completion does not create creator eligibility by itself.

10. Legal bases and consent

Pulscam identifies an Article 6 GDPR basis for each verification operation, which may include steps before contract, contract performance, a legal obligation or legitimate interests in operating an adults-only service safely and lawfully.

Where biometric data is used for unique identification, Pulscam must also confirm the applicable Article 9 GDPR condition: [INSERT CONFIRMED ARTICLE 9 CONDITION].

Where explicit consent is relied upon, it is presented separately, is not preselected, is recorded and explains the controller, purpose, data, provider, retention, transfers, refusal consequences and withdrawal.

11. Withdrawal

Consent may be withdrawn through [INSERT PROCESS OR CONTACT]. Withdrawal does not affect prior lawful processing.

Following withdrawal, Pulscam determines which consent-based processing must stop, which raw or derived biometric data must be deleted, whether non-biometric verification evidence remains under another valid basis, and whether broadcasting, monetization or payout eligibility can continue.

Pulscam will not rely on a generic reference to compliance to retain all verification material indefinitely.

12. Studio-managed performers

The same verification and final-approval requirements apply to studio-managed performers.

Each performer must receive the Privacy Policy and this Policy, complete their own identity and liveness steps, provide their own required consent, communicate directly and confidentially with Pulscam and receive a separate final decision.

A studio must not complete liveness for a performer, substitute another person, upload an unrelated stored image as a live capture, consent in place of the performer, bypass steps, prevent direct contact or activate an unapproved performer.

Studios ordinarily receive only limited operational statuses and do not receive Pulscam biometric templates, raw biometric data or confidential review evidence without a specific lawful need.

13. Third-party providers

Pulscam’s current primary creator-verification workflow is internally controlled. A third-party KYC provider is not required merely because a case reaches manual administrative review.

Pulscam may introduce a provider for a specific identity, fraud, payment, payout or compliance function where operationally or contractually required. Before such processing begins, the applicable notice must identify the function, data disclosed, provider role, processing locations, retention and transfer safeguards.

Payment or payout providers may conduct their own legally required identity, sanctions, fraud or due-diligence checks. Those checks are separate from Pulscam’s creator-approval decision unless expressly stated otherwise.

14. Duplicate-account review

Where duplicate-account review is used, Pulscam must document whether comparison is limited to the same person’s prior records or extends to a wider creator database, what identifier is used, retention, false-positive handling and appeal.

A possible match does not automatically prove unlawful account control and must receive appropriate human review.

15. Storage and security

Verification material is separated from ordinary public profile media where technically possible. Access is restricted by role and necessity to authorized compliance, security, legal and technical personnel and any specifically engaged provider.

Identity documents, liveness captures and biometric-related data must not be exposed through public profiles, public galleries, public object URLs, browser debug output or unsecured administration interfaces.

Production controls must include verified transport security, restricted storage, least privilege, audit logging, access review, backup rules, incident response and secure-deletion procedures.

16. Retention

Before commercial launch, Pulscam must approve separate retention periods for identity-document images, document metadata, raw selfie, raw liveness capture, biometric template or derived facial representation, face-match result, liveness result, provider reference, manual-review result, rejection and recheck records, consent evidence, payout-eligibility status, duplicate-account indicators and access logs.

Raw biometric material and templates must not be kept longer than necessary for the confirmed purpose. Where only a non-biometric verification status remains after raw captures are deleted, that distinction must be recorded.

17. Re-verification

Pulscam may require re-verification where a document expires, account ownership is disputed, payout details materially change, a justified mismatch appears, impersonation is suspected, a studio relationship changes, or a justified fraud, safety, legal or provider requirement exists.

A re-verification request does not by itself establish wrongdoing.

18. Failed verification and appeal

A verification may fail or require recheck because of an unreadable or expired document, unsupported type, poor image quality, liveness failure, unresolved face mismatch, incomplete data, inconsistent account information, technical failure or possible duplicate or fraud indicators.

Where appropriate, Pulscam provides a general reason without disclosing security-sensitive methods.

An applicant may use [INSERT APPEAL CHANNEL] to correct data, replace a document, repeat liveness, explain a legal-name difference, provide supporting evidence, report a technical error or request human reconsideration.

19. Rights and legal holds

Subject to applicable law, individuals may request information, access, correction, deletion, restriction, objection, consent withdrawal and human review of certain significant decisions.

Deletion may be delayed only for specific data required by a valid legal obligation, unresolved payment dispute, safety investigation, legal claim or documented preservation requirement. A legal hold applies only to relevant data and only for the justified period.

20. Prohibited uses, changes and contact

Pulscam does not authorize verification data for sale, unrelated advertising, public facial-recognition searches, identification of viewers from public broadcasts, unrelated monitoring, inference of sexual orientation, ethnicity, health or emotional state, or training a general-purpose facial-recognition system without a separate lawful basis and notice.

Material changes concerning purposes, biometric categories, providers, retention or transfers will be communicated and renewed consent will be requested where legally required.