Data We Collect from Users: Identity data (full name; date of birth and a government identity document number such as an NRIC or passport, collected where these are needed to verify you or to provide a regulated feature rather than as a condition of opening an account); biometric data (facial recognition templates derived from facial scans); contact data (mobile number, email address); payment data (tokenised payment credentials, national payment scheme identifiers such as DuitNow IDs where applicable in your market, transaction history); device data (device identifiers, operating system, IP address); behavioural data (purchase history, loyalty points, preferences, AI-generated insights).

Data We Collect from Merchants: Business registration information; authorised representative identity data; contact and billing information; POS device data; transaction records and performance metrics.

How We Use Your Data: To provide, operate, and improve AyeFace services; to verify your identity and authenticate transactions; to process payments and manage loyalty programmes; to personalise your experience through AI-driven recommendations; to comply with legal and regulatory obligations; to detect and prevent fraud and unauthorised access; to communicate service updates, promotions, and compliance notices; and to conduct research and analytics to improve our platform.

Data collected directly from you (registration, onboarding); automatically (device and usage data via the AyeFace application and POS terminals); from merchants (transaction and interaction data when you use AyeFace at their premises); and from third parties (payment processors, identity verification partners, and fraud prevention services).

Our website uses only essential and functional storage, such as remembering the currency you have selected. We do not run third-party advertising or social-media tracking pixels on our website, and we do not use it to build advertising profiles.

What we actually store. Our website sets no cookies at all. It stores a single preference in your browser's local storage, which records the currency you have selected so the pricing page shows it again on your next visit. Nothing in that record identifies you, and it is not shared with anyone. We run no analytics cookies and no advertising cookies on our website.

Because our website sets no non-essential cookies, there is nothing to opt out of and no consent banner is shown. You can clear or block storage at any time through your browser settings, though doing so may affect functionality such as remembering your currency. If we introduce analytics or advertising cookies in future, we will ask for your consent before they are set and provide a way to withdraw it. For mobile applications, similar device-level tracking may apply and can be managed through your device operating system settings.

Within the Aye Group: Personal data may be shared among Aye Global Holdings Pte. Ltd. and its subsidiaries for operational, administrative, and service delivery purposes, subject to this Policy.

With Merchants: We share only your store activity (transaction amounts, points earned, rewards redeemed) with the merchant where the transaction occurred. We do not disclose your identity, biometric data, or payment credentials to merchants.

Cross-merchant features: A merchant you have never transacted with holds no profile of you and receives nothing about you. When you pay with AyeFace at a merchant, a customer profile is created with that merchant. Where participating merchants run joint campaigns with one another, we use your activity at one of them to determine the rewards or entitlements available to you at another. We perform that matching ourselves: participating merchants do not receive each other's customer records, they see only that you qualify for the joint campaign they are running, and no merchant receives your biometric data. Taking part is your choice each time: at a participating outlet you decide whether to earn or redeem a joint reward, or simply to pay and take neither. Your activity at a merchant is otherwise used only for that merchant's own programme.

With Service Providers: We engage trusted third-party providers for cloud hosting, payment processing, identity verification, fraud prevention, analytics, and customer support. These providers are bound by data processing agreements and are permitted to use your data only as directed by Aye.

For Legal Compliance: We may disclose personal data where required by applicable law, court order, regulatory authority, or to protect the rights, property, or safety of Aye, its users, or the public.

Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of that transaction, subject to continued protection under equivalent terms.

We do not sell personal data to third parties for their own marketing purposes.

Aye operates across Southeast Asia and may transfer personal data to jurisdictions outside your home country, including Singapore, Malaysia, and other locations where our service providers operate.

Where personal data is transferred across borders, we ensure that appropriate safeguards are in place, such as standard contractual clauses, adequacy decisions, or binding corporate rules, in accordance with applicable data protection laws including the Malaysian Personal Data Protection Act 2010 (PDPA), Singapore PDPA, and GDPR where applicable.

By using AyeFace services, you consent to the transfer of your personal data to our processing locations as described in this Policy. We will always ensure that cross-border transfers are subject to protections at least equivalent to those in your home jurisdiction.

We process personal data on the following legal bases:

Consent: For biometric data collection and processing, including to improve the accuracy and security of Our facial recognition and liveness detection, channel communications, and cross-merchant joint campaigns, where you choose at the point of each transaction whether to earn or redeem a joint reward. If we introduce non-essential cookies in future, they will also rely on consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Contractual Necessity: To provide AyeFace services, process payments, and fulfil our obligations to users and merchants under applicable Terms and Conditions.

Legal Obligation: To comply with applicable laws and regulations, including anti-money laundering (AML), know-your-customer (KYC), and financial reporting requirements.

Legitimate Interests: For fraud prevention, security, service improvement, analytics, and network integrity, where these interests are not overridden by your data protection rights.

For special categories of data (biometric data), we rely on explicit consent and applicable exemptions under data protection law.

We implement industry-standard technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction.

Technical measures include: AES-256 encryption for data at rest; TLS 1.3 encryption for data in transit; biometric template tokenisation: the recognition template is a one-way conversion created on the capturing device and no photograph is held for recognition, and the separate evidence record is encrypted and openable only with dedicated keys under logged, auditable access; multi-factor authentication for platform access; Presentation Attack Detection (PAD) compliant with ISO/IEC 30107; regular penetration testing and vulnerability assessments; and SOC 2-aligned infrastructure controls.

Organisational measures include: role-based access controls (least privilege); mandatory data privacy training for all staff; data processing agreements with all third-party providers; incident response and breach notification procedures; and regular privacy impact assessments for new features.

In the event of a data breach affecting your rights and freedoms, we will notify you and the relevant authorities in accordance with applicable law.

Subject to applicable law, you have the following rights regarding your personal data:

Right of Access: Request a copy of the personal data we hold about you.

Right to Correction: Request correction of inaccurate or incomplete personal data.

Right to Erasure: Request deletion of your personal data where there is no legitimate ground for continued processing.

Right to Restrict Processing: Request that we limit how we process your data in certain circumstances.

Right to Data Portability: Receive your personal data in a structured, machine-readable format where processing is based on consent or contract.

Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.

Rights in Relation to Automated Decisions: Recognising you at a checkout is an automated process: we match your face against your own template to confirm it is you, and apply the rewards, entitlements and payment method you have set up. This is necessary to provide the service you have asked for, and it does not produce legal effects concerning you of the kind that would require additional safeguards. We do not use automated processing alone to decide whether you may hold an account, to assess your creditworthiness, or to profile you for purposes you have not agreed to. Where a match cannot be made, you can always pay by another method, and you may contact us to ask that a person review any decision you believe was made about you in error.

Right to Withdraw Consent: Withdraw consent for biometric data processing or channel communications at any time without penalty.

To exercise your rights, contact us at privacy@aye-ai.org or through the AyeFace User Portal. We will respond within 30 days. Requests may be subject to identity verification. You also have the right to lodge a complaint with your local data protection authority.

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

User account data is retained for the duration of your account and for 7 years after account closure for legal and audit compliance. Recognition templates are deleted within 30 days of account closure or consent withdrawal. Evidence records are retained for 30 days by default. That period is extended only where a dispute or fraud case is raised by you, by a merchant or by an authority, and only for as long as that case remains open; where anti-money-laundering record-keeping obligations apply, the applicable retention is 5 years. Transaction records are retained for 7 years to satisfy financial regulatory requirements, and do not contain photographs. Channel communications data is retained until you withdraw consent or opt out.

Where data is no longer required, we securely delete or anonymise it in accordance with our data retention schedule. Anonymised, aggregated data may be retained indefinitely for research and analytics purposes.

Child mode: under 13. A child under 13 may be enrolled only through child mode, which requires verifiable parental consent and a parent or guardian who holds their own AyeFace account linked to the child's. Verifiable means We confirm the parent or guardian's identity before enrolment completes: their own AyeFace account must have been verified against a government-issued identity document, matched against their own facial capture, before they can link a child's account. This is a one-time step per parent, covering every child subsequently linked to that account.

Teen mode: 13 to 17. From age 13, a young person may enrol through teen mode, which requires a parent or guardian to hold their own AyeFace account and link the teen's account to it.

Adult: 18 and over. From age 18, a person enrols independently, in their own right, with no parent or guardian link required.

Moving between modes. An account moves automatically from child mode to teen mode at 13, and from teen mode to adult at 18. Each transition requires a new facial capture: the recognition template held for the earlier mode is deleted and replaced, because a young person's face changes enough over these years that the earlier template would not reliably match. Moving to adult mode also ends the parent or guardian's link to the account.

Payment methods. A child or teen account may link a payment method, such as a debit card or e-wallet, only where that instrument has itself been lawfully issued to the young person by their own bank or payment provider. Eligibility for that instrument is determined by the issuing bank or provider, not by AyeFace. AyeFace's own requirement, at every age under 18, is the parent or guardian link.

We do not use a minor's data for personalisation, marketing, or general AI model improvement. Data from a child or teen account is used only to operate the account and process transactions. We do not use it to build advertising profiles or audiences, personalise marketing, or improve any AI model, except for the narrow, opt-in purpose described below. Evidence records for child and teen accounts follow the same retention schedule as all accounts: 30 days by default, extended only while a raised case remains open, and 5 years where anti-money-laundering obligations apply.

Improving liveness and security protection for young users. With the linked parent or guardian's separate, verifiable consent, given specifically for this purpose and distinct from and in addition to the consent required to enrol, We may use a minor's biometric data, in anonymised form, solely to improve the accuracy of Our liveness and spoof-detection technology, so as to better protect young users from impersonation. This consent is off by default, is never bundled with enrolment, and the parent or guardian may withdraw it at any time without affecting the minor's account or requiring re-enrolment. It is never used for personalisation, marketing, or any other purpose.

If we discover an account outside this framework. Where an account belongs to someone under 13 without verifiable parental consent, or aged 13 to 17 without a parent or guardian linked, We will suspend it, delete the associated biometric template and any raw enrolment data without undue delay, and delete or anonymise the remaining personal data on the same basis as any other closed account.

For parents and guardians. You manage a child's or teen's account through your own AyeFace account. If you believe a young person has enrolled without a parent or guardian properly linked, contact us at privacy@aye-ai.org. We will verify your request, remove the account and confirm the deletion to you, at no charge.

Age assurance. The assurance we apply is proportionate to what an account can do. Where an account is used for membership and loyalty only, age rests on the account holder's own declaration. Where a payment method is linked, the account holder must be eligible to hold that instrument, and its issuer's own age and identity checks apply in addition. Where a subsidy or verified-profile feature is used, a government identity document or national identity credential is required. Where a government identity document or national identity credential is presented, whether for verification, a subsidy or a verified-profile feature, the date of birth it carries takes precedence over the declaration, and We will move the account to the correct mode. For child mode, and for the liveness-improvement consent described above regardless of age band, We additionally verify the parent or guardian's identity before proceeding.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

Data Protection Officer
Aye Global Holdings Pte. Ltd.
Email: privacy@aye-ai.org
For complaints or concerns: complaints@aye-ai.org

We are committed to resolving data privacy concerns promptly. If you are not satisfied with our response, you may escalate to the relevant data protection authority in your jurisdiction.

This Privacy Policy is effective as of 23 August 2026. We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Material changes will be communicated to you via in-app notification, email, or prominent notice on our website at least 30 days before taking effect, matching the notice period in Our Terms. Where a change materially affects how we process personal data, this Policy governs. Your continued use of AyeFace services after the effective date of any update constitutes acceptance of the revised Policy.

We encourage you to review this Policy periodically. The "Last Updated" date at the top of this page indicates when the Policy was most recently revised.