Privacy Policy

1. Introduction

FingerPay SA ("FingerPay", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our biometric identity platform and services.

2. Information We Collect

2.1 Biometric Data

We collect fingerprint templates when you enroll in our system. These templates are:

• Encrypted using AES-256 encryption
• Stored exclusively in Swiss data centers
• Never shared with third parties
• Mathematically derived representations, not actual fingerprint images

2.2 Personal Information

We may collect:

• Name and contact information
• Account credentials
• Device information
• Usage data and analytics

2.3 Transaction Data

When using our payment services, we may collect transaction details, amounts, and merchant information.

3. How We Use Your Information

We use the collected information to:

• Provide biometric authentication services
• Process payments and transactions
• Improve our services and user experience
• Comply with legal obligations
• Prevent fraud and ensure security

4. Data Storage and Security

All data is stored in Switzerland and protected by:

• AES-256 encryption at rest and in transit
• ISO 27001 certified data centers
• Swiss Federal Data Protection Act (FADP) compliance
• GDPR compliance for EU data subjects

5. Data Retention

We retain your data for as long as your account is active or as needed to provide services. You may request deletion of your biometric data at any time.

6. Your Rights

Under Swiss and EU law, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Object to data processing
• Data portability
• Withdraw consent

7. Third-Party Services

We may use third-party services for:

• Payment processing (Stripe, Adyen)
• Analytics (anonymized)
• Cloud infrastructure (Swiss providers)

All third-party providers are bound by data processing agreements.

8. International Transfers

Your data is stored in Switzerland. If any transfer outside Switzerland/EU is necessary, we ensure adequate protection through Standard Contractual Clauses or equivalent mechanisms.

9. Children's Privacy

Our services are not intended for individuals under 18. We do not knowingly collect data from children.

10. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of any material changes via email or our platform.

11. Contact Us

For privacy-related inquiries:

Data Protection Officer
FingerPay SA
Rue du Rhône 14
1204 Geneva, Switzerland
privacy@fingerpay.ch

12. Supervisory Authority

You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or your local EU supervisory authority.