Privacy policy

This Privacy Notice explains how personal data is processed in connection with the GO.CAM Age Verification Solution. It is intended to provide clear and transparent information in accordance with applicable data protection laws, including the EU GDPR, UK GDPR, the UK Online Safety Act (2023), and French Law No. 2020-936.

This notice applies to End Users undergoing age verification via GO.CAM, as well as Business Customers integrating the solution. It does not apply to any data processing carried out independently by the Business Customer on its own platform.
For the purposes of data protection, the Business Customer (Information Society Service) acts as the Data Controller, as it determines the purpose of requiring age verification. GO.CAM acts as a Data Processor, processing data strictly on documented instructions from the Business Customer. However, GO.CAM may act as an independent Data Controller for strictly limited technical or security-related processing where necessary to ensure service integrity, prevent fraud, or comply with legal obligations.
Where GO.CAM acts as an independent Data Controller, the legal bases relied upon under Article 6 UK GDPR are :

• Article 6(1)(f) – Legitimate Interests, for ensuring service security, fraud prevention, business customer account management, supplier and sub-processor management, and certain customer support activities where appropriate.
• Article 6(1)(c) – Legal Obligation, where processing is necessary to comply with applicable legal or regulatory requirements.
• Article 6(1)(a) – Consent, where the End User voluntarily selects a verification method involving processing for which consent is relied upon, including facial biometric comparison where applicable.

GO.CAM has been designed following a privacy-by-design and data minimisation approach. The solution operates primarily through local processing on the End User’s device and does not create user profiles, track individuals, or build any form of behavioural database. GO.CAM does not store or retain identifiable personal data of End Users beyond what is strictly necessary for the operation, security, and compliance of the service.
Depending on the verification method used, certain data may be processed temporarily during the session. This may include a selfie image, an identity document image, partial card information, an email address used for one-time verification, or data read locally from the contactless chip of a compatible electronic identity document when the NFC verification method is used.
When the email-based verification method is used, GO.CAM processes the email address solely for the purpose of sending a one-time verification code. GO.CAM does not store plaintext email addresses. Where technically required, only an irreversible hash may be processed. Plaintext email addresses are neither stored nor logged, whether temporarily or permanently.

When the NFC Contactless Electronic Identity Document verification method is used, the End User is invited to scan the Machine Readable Zone (MRZ) of a compatible electronic passport or identity document and to read its contactless chip using an NFC-capable device. The MRZ information is used locally to establish secure access to the chip. Relevant chip data, including Data Group 1 (DG1) and Data Group 2 (DG2), may then be processed locally for the purposes of determining whether the End User meets the applicable age threshold and performing the document security checks technically supported by the NFC verification method.
All NFC document processing, including access to and reading of the contactless chip, processing of the MRZ and relevant chip data, and the facial similarity comparison between the End User’s live selfie and the facial portrait contained in DG2, is performed locally on the End User’s device. Raw MRZ data, identity document images, chip data, facial images and biometric templates or vectors generated for this verification are not transmitted to or stored on GO.CAM servers or third-party cloud infrastructure. Such data is processed only transiently for the duration of the verification and is deleted from the device’s volatile memory upon completion or termination of the verification session. The current NFC verification method does not validate the document-signing certificate against a CSCA trust list or master list. Accordingly, GO.CAM does not represent the NFC verification result as an official certification of the electronic document’s authenticity, validity or revocation status.
Where the NFC verification method involves a facial similarity comparison between the End User’s live selfie and the facial portrait contained in the electronic identity document, biometric data may be generated and processed locally on the End User’s device solely for the purpose of confirming that the person presenting the document is its legitimate holder. Such biometric processing is performed only as part of the NFC verification method voluntarily selected by the End User. Where the facial comparison constitutes processing of biometric data for the purpose of uniquely identifying or authenticating the End User, GO.CAM relies, where applicable, on the End User’s explicit consent in accordance with Article 9(2)(a) GDPR and UK GDPR. The biometric data and resulting templates or vectors remain under the End User’s control on the device, are not transmitted to GO.CAM or the Business Customer, and are deleted upon completion or termination of the verification session.
Upon successful completion of the NFC verification process, the document data and biometric data used locally are not transmitted to the Business Customer. Only the verification outcome confirming whether the End User meets the applicable age threshold, together with the technical information necessary to validate the verification session, such as a session identifier and timestamp, may be transmitted to the Business Customer. The End User’s name, document number, exact date of birth, MRZ data, facial image and other data extracted from the electronic identity document are not disclosed to the Business Customer.
In addition, GO.CAM may process limited technical and non-identifying data strictly necessary for the operation and security of the service. This may include limited device and browser metadata, verification outcome (such as confirmation that the user is above the required age threshold), and anonymised or pseudonymised technical logs. IP addresses may be processed transiently for security and operational purposes but are not stored or retained by GO.CAM.

GO.CAM may rely on a limited number of third-party service providers strictly for technical support functions. For example, during the Email + Code verification method, a partial hashed representation of an email address may be transmitted using a k-anonymity model to a third-party service (HaveIBeenPwned) to assess exposure to known data breaches. No full email address is transmitted, and no personal data is stored by GO.CAM in this process. Where such services involve transfers outside the European Economic Area, appropriate safeguards such as Standard Contractual Clauses (SCCs) are implemented, and only pseudonymised or hashed data is transmitted.
Personal data is processed solely for the purpose of verifying that the End User meets the applicable age requirement, preventing fraud or circumvention of the system, and ensuring the security and reliability of the service. GO.CAM does not use personal data for marketing, advertising, analytics unrelated to security, or any form of user profiling.

GO.CAM applies strict data minimisation and retention principles. Images and identity documents are not retained and are deleted immediately after processing within the session. For the NFC verification method, MRZ data, data extracted from the contactless chip (including DG1 and DG2), facial images, and any biometric templates or vectors generated for the verification are processed only transiently on the End User’s device and are deleted upon completion or termination of the verification session. Email addresses used for verification are not retained. The age verification result may be stored for a limited period where necessary (typically up to 30 days), and anonymised technical logs may be retained for security and audit purposes for a limited duration (typically up to 12 months). All data retained by GO.CAM is automatically deleted or anonymised in accordance with internal retention policies.
End Users may exercise their data protection rights, including the right of access, rectification, erasure, restriction, or objection, either through the Business Customer or directly by contacting [email protected]. However, due to the privacy-preserving architecture of GO.CAM, in most cases no identifiable personal data is retained by

GO.CAM, and therefore no data can be retrieved or deleted by GO.CAM.

GO.CAM implements appropriate technical and organisational measures to ensure a high level of security, including local-first processing, encrypted communications (TLS), strict access controls, and the absence of any centralised storage of biometric data. For the NFC verification method, GO.CAM uses data formats and secure chip-access mechanisms commonly used by compatible electronic passports and identity documents, including MRZ, DG1, DG2, BAC and PACE where supported by the document and device. The current implementation does not perform CSCA master-list validation and therefore does not independently certify the electronic document’s authenticity, validity, revocation status or compliance with ICAO Doc 9303.
GO.CAM may use a strictly necessary technical cookie (such as "isAgeVerified") to remember the outcome of a verification session and avoid repeated checks. This cookie does not contain personal data and is not used for tracking or advertising purposes.

For any questions or requests related to this Privacy Notice or data protection, GO.CAM can be contacted at [email protected].
Date of last update: September 2026