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Smile Virtual is a virtual try-on and augmented reality platform for e-commerce, enabling customers to see how products like eyewear, makeup, or accessories look on their face using their camera. When camera images are processed to detect facial features, this constitutes biometric data processing under GDPR Article 9. Explicit consent is mandatory before camera access is requested.
Smile Virtual provides augmented reality virtual try-on technology for e-commerce, allowing customers to visualise products on their face using their device camera. It is used for eyewear, makeup, jewelry, and accessories. The camera captures video or images which are processed to detect and overlay products on facial features.
When facial feature analysis is performed to identify facial geometry, proportions, or landmark points, this constitutes biometric data under GDPR Article 4(14), which is special category data under Article 9. This applies regardless of whether images are retained or deleted after processing. Client-side only processing with immediate deletion may reduce risk but does not eliminate the Article 9 classification.
Obtain explicit consent (Art. 9(2)(a)) before activating the camera for try-on. Conduct a mandatory DPIA. Implement client-side processing where possible to avoid transmitting facial images to servers. If server-side processing is required, minimise retention (delete immediately after rendering). Provide clear privacy notice for the try-on feature.
Websites using Smile Virtual (virtual try-on) must obtain user consent under GDPR regulations.
DPIA considerations
A DPIA is mandatory for Smile Virtual implementations that process facial feature data server-side for biometric identification. GDPR Article 35 requires a DPIA for systematic processing of biometric data using new technologies.
Sample consent text
This store uses virtual try-on technology that accesses your camera and processes facial feature data to display products. This is biometric data under GDPR Article 9. Do you explicitly consent to this processing?
Third-party domains contacted
app.smilevirtual.comapi.smilevirtual.comcdn.smilevirtual.comCookies placed
| Name | Type | Duration | Purpose |
|---|---|---|---|
| sv_session | functionality | Session | Maintains the user session for the virtual try on widget and AR rendering state. |
| sv_device_id | functionality | 1 year | Stores a unique device identifier to optimise AR rendering and camera calibration across visits. |
| sv_analytics | analytics | 6 months | Tracks usage metrics of the virtual try on feature including product views and AR interactions. |
| sv_consent | functionality | 1 year | Records user consent for camera access and biometric data processing in the AR experience. |
Smile Virtual (virtual try-on) utiliza cookies para las preferencias de los usuarios — informa a tus visitantes con un banner de consentimiento.
Smile Virtual sets cookies related to the virtual try on experience, including session identifiers, user preference storage, and camera permission states. These cookies maintain the augmented reality session and remember selected products. Additional analytics cookies may be set to track user engagement with the try on feature.
Yes, consent is required before activating Smile Virtual on your website. The service accesses the user's camera, processes facial imagery, and sets non essential cookies. Under GDPR and the ePrivacy Directive, you must obtain explicit consent before enabling the virtual try on feature and processing biometric adjacent data.
The appropriate legal basis is explicit consent under Article 6(1)(a) GDPR. Because Smile Virtual processes facial features through camera access, this may qualify as biometric data under Article 9, requiring explicit consent. Legitimate interest is not sufficient given the sensitivity of facial data processing.
Smile Virtual processes facial data on its servers, which may be located outside the EEA. You should verify the data processing locations with the provider and ensure appropriate safeguards such as Standard Contractual Clauses are in place. Document any international transfers in your privacy policy.
A DPIA is strongly recommended and likely mandatory for Smile Virtual implementations. The service processes facial data at scale, uses innovative technology (augmented reality), and may involve automated decision making. Article 35 GDPR requires a DPIA when processing presents high risks to individuals.
Block the Smile Virtual script until the user gives explicit consent. Present a clear explanation that the feature requires camera access and facial processing. Offer an alternative browsing experience without the try on feature. Implement data minimization by not storing facial data longer than the session requires.
Consider virtual try on solutions that process all data locally in the browser without sending facial imagery to external servers. Some alternatives use 2D overlay techniques that do not require biometric processing. You could also offer static product images or manual size selectors as non invasive alternatives.
Add a dedicated section describing Smile Virtual's cookies, camera access requirements, and facial data processing. Specify the types of data collected, processing purposes, retention periods, and any third party data sharing. Include information about the user's right to use the website without the try on feature.