Biometric Data Notice

Last updated: October 16, 2026

This notice explains the place where Luvenue uses automated analysis of faces: what the analysis does, why, who does it, what we keep and for how long, and how we protect it. Luvenue is operated by Mocha Innovations LLC, 169 Madison Ave, STE 11564, New York, NY 10016, USA. This notice goes with our Privacy Policy, which covers everything else.

In short. We use face analysis to keep Luvenue safe and for adults, by spotting photos and video calls that may show someone under 18. We don’t use it to find out who you are, and we don’t keep a faceprint or any measurements of your face. We ask for your agreement before any of it happens.

Why we publish this. Some state laws, including those of Colorado, Illinois and Texas, set rules for “biometric identifiers”, such as a record of someone’s face geometry. In our view the analysis described here doesn’t create biometric identifiers, because nothing it produces can be used to identify anyone. We follow those laws’ rules for it anyway, and this notice is part of how we do that.

1. The face analysis we do

Safety screening of photos and video calls (everyone). Photos you add to your profile, and still images taken from your video at regular intervals during a video call, are checked automatically by Sightengine, a company that does this work for us. Its software looks for things our Community Guidelines don’t allow, such as nudity, weapons, drugs and graphic violence. As part of that check it detects faces in the image and estimates how old they appear, so that we can find images that may show someone under 18. Sightengine sends us back scores, for example how likely it is that an image shows someone under 18. It doesn’t tell us who anyone is.

2. What we don’t do

• We don’t use face analysis to find out who you are, to recognize you in other images, or to match your face to anyone or anything, including your own profile photos.
• We don’t create or keep a faceprint, a face template or measurements of your facial features. What our providers send us are results (scores), not data that describes your face.
• We don’t sell, rent or trade anything covered by this notice, or otherwise profit from it, and we don’t use it for advertising or to train AI models.

3. Who handles it

• Sightengine (operated by Kozelo SAS, in France) analyzes photos and call images for us under a data-processing agreement. It sends us scores and deletes the images right after processing. It doesn’t create or keep face templates, faceprints or other biometric identifiers, and doesn’t identify anyone.
• Google stores photos and call images for us (Google Cloud, in the United States), and Agora captures the still images from video calls for us.
• People on our team who review safety reports and appeals can see images kept as safety evidence, through our internal moderation dashboard. Anyone who helps us with that work does so under a written confidentiality commitment.

We don’t disclose anything covered by this notice to anyone else, unless the law requires us to (for example, a valid warrant or subpoena, or a report of apparent child exploitation to the National Center for Missing & Exploited Children).

4. What we keep, and for how long

What	How long we keep it
Your profile photos	Until you delete the photo or your account
Still images from video calls that our screening doesn’t flag	30 days
A photo or call image that our screening flags, or that is part of a report	365 days, as safety evidence. An image that appears to show someone under 18, without sexual content, is not kept as evidence: we keep the scores, and the image is deleted on its normal schedule. Images we must preserve after reporting apparent child exploitation are kept at least one year after the report, as federal law requires
Scores from safety screening	For an image our screening flags: with our moderation records, for as long as we need them to enforce removals and defend claims (Privacy Policy, Section 7). For any other image: not kept
Face templates, faceprints or measurements of facial features	None are kept, by us or by Sightengine. Sightengine sends us scores, not measurements of your face
Image fingerprints (a short code computed from a whole image, not from a face)	With each profile photo, until the photo is deleted. For the photos of an account we remove, and for an intimate image we remove, as long as we need them to recognize the image if it’s uploaded again (Privacy Policy, Sections 6 and 7)

These periods match Section 7 of our Privacy Policy.

5. Our deletion rules

• We delete the information in Section 4 on that schedule.
• At least once a year, we review what we keep under this notice and whether we still need it, and we delete anything we no longer need within 45 days of deciding that.
• If we ever held a biometric identifier, such as a record of face geometry, we would delete it by the earliest of these dates: when the purpose we collected it for has been met; 24 months after your last interaction with Luvenue; and 45 days after we decide we no longer need it.
• A valid warrant or subpoena, a legal duty to preserve, or a litigation hold can require us to keep something longer. Otherwise, we follow this schedule.

6. Asking for your agreement

• Safety screening. If you sign up in Illinois, Texas, Washington or Colorado, or your profile or phone places you there, the app explains this screening, including face detection and age estimation, and asks whether you agree, before you add your first photo. Everywhere else, the Welcome screen asks for your permission to send photos and video-call stills to these automated safety tools, and this notice describes what they do. Profile photos and video calls on Luvenue are screened, so if you don’t agree, you can’t add profile photos or join calls. You can withdraw your agreement at any time in Settings › Privacy › Your consents.
• We keep a record of each agreement, with the date and the exact text you saw.

7. Keeping it secure, and what happens if something goes wrong

We protect the images and results described here at least as carefully as the most sensitive information we hold: encryption in transit and at rest, restricted storage for safety evidence, and access controls that restrict who at Luvenue can see it. Sightengine’s agreement requires it to tell us without undue delay about a breach affecting our data. If a security incident may have exposed information covered by this notice, we will investigate it, contain it, and notify the people affected, and the authorities, as the law requires.

8. Questions and requests

You can ask us what we hold about you under this notice, or ask us to delete it, by writing to privacy@luvenue.com or to Mocha Innovations LLC, Attn: Privacy, 169 Madison Ave, STE 11564, New York, NY 10016, USA. We answer as Section 9 of our Privacy Policy describes.

9. Changes to this notice

If we change how we use face analysis, we will update this notice before the change takes effect and, where the law requires it, ask for your agreement again.