Curtains is operated by Billion Flower Moon Studios LLC, a Wyoming limited liability company.
In brief#
- When you sign up, if your iPhone supports it, we ask you to take a face check. It checks that a live person is taking a selfie, and that the same person appears in at least 2 of your profile photos.
- It runs entirely on your phone. The images, and the scans of face geometry worked out from them, never leave your phone, and they're deleted right after each check. Neither is stored, on your phone or on our servers.
- We receive only the results: the outcome, which of your photos matched, and when.
- Before the check runs, you see a notice and tick a consent box. Everyone sees the same box, in every state.
- It's your choice. You can skip it, and if it doesn't match, you can still use Curtains. You can withdraw your consent at any time.
- We never sell, lease or trade biometric data, or profit from it in any other way.
1. What the face check is#
The face check helps keep fake accounts and catfishing off Curtains. It checks two things:
- that a live person is in front of the camera, rather than a photo held up to it, a screen or a recording; and
- that the person taking the selfie appears in at least 2 of your profile photos.
We use the results for nothing else. They never change who sees your profile, or the order in which profiles appear.
The face check doesn't tell us who you are or how old you are. It isn't identity verification. We don't show other members whether you took it or passed it, and there's no badge.
2. How it works#
- You agree first. Before the first check, the app shows a short notice and a consent box (section 5). The check runs only after you tick the box. If your iPhone can't run the check, sign-up carries on without it.
- At sign-up. After you add your profile photos, your phone takes a short live selfie. It checks that a live person is present, then scans the face geometry in the selfie and in each of your profile photos that shows exactly one face, and compares them. To pass, the same person must appear in the selfie and in at least 2 of your photos. Photos with no face, or with more than one face, can stay on your profile, but they're never scanned or compared, and they don't count toward the 2. So other people in group photos aren't scanned.
- After you pass: changing your photos. At least 2 of your photos must always match your selfie. When you add or replace a photo with one face in it, your phone scans it and compares it with your photos that matched, to keep that count. A photo that doesn't match can still go on your profile; it just doesn't count toward the 2. A change, including removing or replacing a photo, that would leave fewer than 2 matching photos can't be made.
- Your phone does all of it. The checks run on your phone, using face-detection tools built into iOS, with no outside model or service. The images and the face-geometry scans are never sent to us.
- Nothing is kept. As soon as a check ends, whether it passes, fails or is cancelled, the app deletes the images and the scans from your phone. It keeps no copy: nothing goes to your photo library, the app's storage, logs, analytics or crash reports.
- We receive the results only. The app sends us the outcome (passed, didn't match, skipped, or not possible on your phone), which of your photos matched, and when. These aren't biometric identifiers or biometric information. They say nothing about what your face looks like, and no one could recognize you or recreate your face from them.
- We may ask you to take it again. If a photo that matched is removed from your profile, for example because it breaks our Community Guidelines, your profile stays as it is, and we may later ask you to take a new face check.
3. What we never receive#
We never receive, store or have access to biometric identifiers or biometric information. That means no images from the selfie; no face geometry, face templates or faceprints; and no fingerprints, voiceprints, or iris or retina scans. We don't collect, capture, buy, receive through trade or otherwise obtain any of them, from you or from anyone else.
Neither our servers nor any provider scans photos for face geometry. Faces in your profile photos are compared only on your phone, during the face check. Our safety tools and ban enforcement work on whole images: a photo hash can spot a copy of the same picture, but can't recognize the person in it.
4. Retention and destruction schedule#
| Data | Where it is | Kept for | How it's destroyed |
|---|---|---|---|
| Selfie images, and the face-geometry scans worked out from them and from your photos during a check | Your phone only | Only while each check runs | Deleted from your phone immediately after each check, whether it passes, fails or is cancelled. Never sent to us. |
| The results: the outcome, which photos matched, and when | Our servers | While your account exists | Deleted with your account, from our live systems within 72 hours of account deletion and out of backups within 30 days (if we took action against the account, 1 year after that decision: Privacy Policy section 8). If you withdraw your consent, we delete them then and keep only a note that you withdrew it. |
| Your consent: that you ticked the box, or withdrew it, and when | Our servers | While your account exists, plus 6 years | Deleted at the end of that period |
The purpose of the images and any face data is met when each check ends, so that's when they're destroyed. The other periods match our Privacy Policy (section 8). If the law requires us to preserve the results or the consent record, for example under a court order, we keep them until that duty ends.
5. Your consent#
Before the first check, the app tells you:
- that the check scans the face geometry in your selfie and in your profile photos, on your phone, to compare them;
- that, once you've passed, the same scan and comparison run on your phone whenever you add or replace a profile photo;
- that the images and the scans stay on your phone and are deleted immediately after each check;
- that we receive only the results, and keep them while your account exists; and
- what the check is for.
The notice links to this policy. You tick a box to agree, and the check runs only after you do. Ticking the box is your written release, signed electronically. We show the same notice and box to everyone, in every state, and keep a record of your consent (section 4).
It's your choice. If you don't agree, the check doesn't run, and you can still use Curtains. The same goes if the check doesn't match. We record that you skipped it or didn't match (section 2), and nothing else changes for you.
Withdrawing. You can withdraw your consent at any time in the app (Settings → Legal & privacy → Face check) or by writing to privacy@curtainsdating.com. We then delete your face-check results and keep only a note that you withdrew it. You can keep using Curtains and change your photos as usual.
6. No sale, and no disclosure#
- We don't sell, lease, trade or otherwise profit from biometric identifiers or biometric information.
- We don't disclose them to anyone, except as the law requires. Because we never receive any, there's nothing for us to disclose.
- The results we receive aren't biometric data, but we treat them as sensitive (Privacy Policy section 2.2). We don't sell them or use them for advertising, and we disclose them only as section 6 of our Privacy Policy describes, for example when the law requires it.
7. Security#
Nothing biometric reaches our systems. On your phone, the check runs inside the Curtains app, and iOS keeps each app's data apart from other apps. We protect the results like other member data, with encryption in transit and at rest and restricted, logged access (Privacy Policy section 14).
8. Changes to this policy#
If we ever planned to receive or store biometric data ourselves, we would first publish an updated policy with a new retention schedule, tell you at least 30 days ahead, and get your written release before collecting anything. For any other change, we update the "Last updated" month and year at the top, and tell you in the app or by email at least 30 days before a material change takes effect. Earlier versions are archived; email privacy@curtainsdating.com for a copy.
9. State notices#
Illinois. The Biometric Information Privacy Act (740 ILCS 14) requires a publicly available retention schedule and guidelines for destroying biometric identifiers and biometric information, and a written release before they're collected. We don't collect either: the face check runs on your phone, and nothing biometric is sent to us. Section 4 is our retention schedule and destruction guidelines: data on your phone is destroyed immediately after each check, when its purpose has been met, long before the Act's outer limit (3 years after your last interaction with us). The consent box (section 5) is a written release, signed electronically, and we ask everyone for it. We don't sell, lease, trade or otherwise profit from biometric data, and we disclose none.
Texas. Texas law (Business and Commerce Code §503.001) allows a biometric identifier to be captured for a commercial purpose only after notice and consent, bars selling it, and requires destroying it within a reasonable time. You get notice and give consent before the check (section 5). We never receive a biometric identifier, so we have none to sell or disclose, and the data on your phone is destroyed immediately after each check.
Washington. Washington's biometric identifier law (RCW 19.375) requires notice and consent before a biometric identifier is enrolled in a database for a commercial purpose. We don't enroll biometric identifiers in any database: nothing from the check leaves your phone. We still give the same notice and ask for the same consent as everywhere else. Washington's My Health My Data Act also treats biometric data as consumer health data. Our Consumer Health Data Privacy Policy explains how we handle the face check under that law.
10. Contact us#
- privacy@curtainsdating.com: questions about this policy, or withdrawing your consent
- support@curtainsdating.com: app help and appeals
Billion Flower Moon Studios LLC, 2106 House Ave, Cheyenne, WY 82001, USA · Phone: +1 (307) 317-0275
Section 16 of our Privacy Policy lists all our contact addresses.
Related policies: Privacy Policy · Consumer Health Data Privacy Policy
