The notice discloses that when an identity document is flagged for verification or a facial image is used multiple times in a short period, a hashed version of the facial image may be stored for up to 96 hours to detect repeated use of the same image with different documents, with temporary service access blocks possible during that period, all blocks subject to human operator review.
This analysis describes what Checkout.com's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a secondary automated biometric processing mechanism, distinct from the primary identity verification function, that may impose a temporary service access block on individuals whose facial image triggers the fraud detection heuristic, with human review stated as the backstop for all such blocks.
Interpretive note: Whether a hashed facial image constitutes a biometric identifier under BIPA or analogous state laws is subject to judicial interpretation and is not resolved on the face of the document.
The updated policy establishes formal complaint procedures for UK and Australia users, requiring Checkout to acknowledge complaints within 30 days and respond without undue delay. For UK users specifically, the policy clarifies that complaints must first be raised with Checkout before escalating to the Information Commissioner's Office. The policy also discloses that transaction information collection now includes country data alongside currency and amount. For Australia users, the policy clarifies that identity verification is a legal requirement and cannot be provided anonymously or pseudonymously. Users in these jurisdictions can submit data protection complaints through Checkout's designated process and escalate to their respective regulatory authorities if dissatisfied with Checkout's response.
View change record →Under these terms, a hashed version of a consumer's facial image may be stored for up to 96 hours if flagged during identity verification, and a temporary block on service access may be applied during that period. The agreement states that all such blocks are reviewed by human operators and do not result in permanent classification or denial of service.
Cross-platform context
See how other platforms handle 96-Hour Temporary Image-Hash Block for Fraud Prevention and similar clauses.
Compare across platforms →"In addition, in limited cases where your identity document is flagged for further verification, we may process a hashed version of your facial image, for the sole purpose of preventing repeated use of the same facial image with different documents. This data is used for fraud prevention, stored for no more than 96 hours, and does not result in permanent classification, profiling or denial of service. In addition, in the event that a facial image is used multiple times in a short period of time, a temporary block (up to 96 hours) may be applied to a hash of the image. This is to allow us to protect our systems against potential fraud and alert affected Merchants. This does not result in any permanent decision or classification, and all blocks are reviewed and handled by human operators.Excerpt from Checkout.com's Privacy
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This provision establishes a secondary automated biometric processing mechanism, distinct from the primary identity verification function, that may impose a temporary service access block on individuals whose facial image triggers the fraud detection heuristic, with human review stated as the backstop for all such blocks.
Under these terms, a hashed version of a consumer's facial image may be stored for up to 96 hours if flagged during identity verification, and a temporary block on service access may be applied during that period. The agreement states that all such blocks are reviewed by human operators and do not result in permanent classification or denial of service.
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