Compliance

Compliance as product, not paperwork

Facial data is sensitive personal information and every step of handling it carries statutory requirements. Here is how those requirements live inside the product.

Applicable law

Civil Code, Articles 1018–1023

Portrait rights. No one may make, use or publish another's likeness without consent; forging it by technical means is equally an infringement.

Personal Information Protection Law

Facial data is sensitive personal information requiring separate consent, a prior impact assessment and protection of individual rights.

Measures for the Security Management of Facial Recognition Technology

In force from 1 June 2025. Sets processing rules, storage and transmission limits, security measures and filing duties.

Data Security Law

Data classification and grading, security management systems, risk monitoring and incident response.

Measures for Labelling AI-Generated Synthetic Content

In force from 1 September 2025. The labelling duty rests with the content generator; we supply the guidance.

Our technical and organisational measures

  • Original images are envelope-encrypted, one key per image, master key held in a key management service
  • ID numbers are stored only as an HMAC plus ciphertext — never plaintext, never a bare hash
  • Facial data has exactly one access path, which enforces a licensing basis and logs every read
  • Liveness data from identity verification is deleted immediately; only the result and reference number are kept
  • Every delivery embeds a unique watermark behind a time-limited link with a capped number of copies
  • The withdrawal control is within three taps — no retention prompts, no reason required, no conditions

What we do and do not do

We do

  • Hold facial assets that performers upload voluntarily
  • Broker licences and deliver watermarked reference material
  • Issue licence certificates and chain-of-consent reports

We do not

  • Provide any generation or face-swap service
  • Disclose original images, feature vectors or ID documents to third parties
  • Train any model on facial data
  • Serve anyone under 18

Published documents

  • Privacy Policy
  • Facial Data Processing Rules
  • Exercising Your Rights
  • Protection of Minors

The platform is at MVP stage, opening to an initial 10,000 performers and a first cohort of studios. Some external services (identity verification, e-signature, trusted timestamping) run in a limited mode until integration completes; the interface says so plainly wherever that is the case.

Data protection officer

If you have a question, request or complaint about how we handle personal information, contact us below. We answer within 15 working days.

Data protection officer
dpo@face.yidaocaiwu.com
Contact: /en/contact