EOS Technical Terms
Last Updated: August 25, 2023
The Technical Terms below govern your use of the Services. Capitalized terms used in these Technical Terms but not defined below are defined in the esh OS LTD. (“EOS”) Customer Agreement or other agreement with EOS governing your use of the Services (the “Agreement”). For purposes of these Technical Terms, “Your Content” includes any “Company Content” and any “Customer Content”.
1. General (Applicable to all Services)
1.1. You may not transfer any of the Services or any software (including related documentation) you obtain from EOS or third party licensors in connection with the Services to any third party without specific authorization to do so.
1.2. You must comply with current technical documentation applicable to the Services (including applicable developer guides) posted on the EOS Site.
1.3. You will provide information or other materials related to Your Content (including copies of any client-side applications) as reasonably requested by EOS to verify your compliance with the Agreement. You will reasonably cooperate with EOS to identify the source of any problem with the Services that we reasonably believe may be attributable to Your Content or any end user materials that you control.
1.4. In connection with your use of the Services, you are responsible for maintaining licenses and adhering to the license terms of any software you run. If we reasonably believe any of Your Content violates the law, infringes or misappropriates the rights of any third party, or otherwise violates a material term of the Agreement (including the documentation, the Technical Terms, or the Acceptable Use Policy) (“Prohibited Content”), we will notify you of the Prohibited Content and may request that such content be removed from the Services or access to it be disabled. If you do not remove or disable access to the Prohibited Content within 2 business days of our notice, we shall have the right to remove or disable access to the Prohibited Content or suspend the Services to the extent we are not able to remove or disable access to the Prohibited Content. Notwithstanding the foregoing, we may remove or disable access to any Prohibited Content without prior notice in connection with illegal content, where the content may disrupt or threaten the Services or in accordance with applicable law or any judicial, regulatory or other governmental order or request. To the extent legally permissible, and depending on the circumstances, we will provide you with written notice after we remove Your Content under the circumstances above. We shall have the right, at our discretion, to terminate the accounts which content contain Prohibited Content.
1.5. You will ensure that all information you provide to EOS (e.g., information provided in connection with your registration for the Services) is accurate, complete, and not misleading.
1.6. From time to time, we may apply upgrades, patches, bug fixes, or other maintenance to the Services and EOS Content (“Maintenance”). We agree to use reasonable efforts to provide you with prior notice of any scheduled Maintenance (except for emergency Maintenance), and you agree to use reasonable efforts to comply with any Maintenance requirements that we notify you about.
1.7. When you use a Service provided by EOS, you may be able to use or be required to use one or more other Services (each, an “Associated Service”), and when you use an Associated Service, you are subject to the terms and fees that apply to that Associated Service.
1.8. We may change, discontinue, or reduce support for any third-party identity provider at any time without prior notice.
1.9. If you process the personal data of End Users or other identifiable individuals in your use of a Service, you are responsible for providing legally adequate privacy notices and obtaining necessary consents for the processing of such data. You represent to EOS that you have provided all necessary privacy notices and obtained all necessary consents. You are responsible for processing such data in accordance with applicable law.
1.10. Following closure of your EOS account, we will delete Your Content in accordance with the technical documentation applicable to the Services.
1.11. We may use information about how you use and interact with the Services to improve those Services.
1.12. Information included in resource identifiers, metadata tags, access controls, rules, usage policies, permissions, and similar items related to the management of EOS resources does not constitute Your Content. EOS recommends that you do not include personally identifying, confidential, or sensitive information in these items.
1.13. You must own or have all necessary rights to use any domain name or technical certificate that you use in conjunction with the Services. You are solely responsible for the renewal, security, and proper configuration of any certificates that you provide for use with the Services, including any disclosure of your certificates to third parties.
1.14. You are solely responsible for applying appropriate security measures to your assets and the data transmitted to and from your assets, including using encryption, firewalls, and other network security tools as appropriate, and not allowing unauthorized access to your data.
1.15. You represent and warrant that you own all right, title, and interest in, or have all necessary authority to permit use of, any assets associated with your EOS account, and you agree to provide to EOS, upon request, documentation demonstrating such ownership or authority. EOS is not a party to any agreement you have or may enter into with any other individual or entity accessing or using the Services, any of Your Content, or any assets associated with your account. You are solely responsible for your separate relationship with any such individual or entity.
2. Betas and Previews
2.1. This Section describes the additional terms and conditions under which you may (a) access and use certain features, technologies, and services made available to you by EOS that are not yet generally available, including, but not limited to, any products, services, or features labeled “beta”, “preview”, “pre-release”, or “experimental”, and any related EOS Content (each, a “Beta Service”) or (b) access and use Services and any related EOS Content available in EOS regions that are not generally available, including, but not limited to, any EOS regions identified by EOS as “beta”, “preview”, “pre-release”, or “experimental” (each, a “Beta Region”).
2.2. You must comply with all terms related to any Beta Service or Beta Region as posted on the EOS Site or otherwise made available to you. EOS may add or modify terms, including lowering or raising any usage limits, related to access to or use of any Beta Services or Beta Regions at any time. Service Level Agreements do not apply to Beta Services or Beta Regions.
2.3. You may provide EOS with information relating to your access, use, testing, or evaluation of Beta Services or Beta Regions, including observations or information regarding the performance, features, and functionality of Beta Services or Beta Regions (“Test Observations”). EOS will own and may use and evaluate all Test Observations for its own purposes. You will not use any Test Observations except for your internal evaluation purposes of any Beta Service or Beta Region.
2.4. EOS may suspend or terminate your access to or use of any Beta Service or Beta Region at any time. Your access to and use of each Beta Service and Beta Region will automatically terminate upon the release of a generally available version of the applicable Beta Service or Beta Region or upon notice of termination by EOS. Notwithstanding anything to the contrary in the Agreement, after suspension or termination of your access to or use of any Beta Service or Beta Region for any reason, (a) you will not have any further right to access or use the applicable Beta Service or Beta Region, and (b) Your Content used in the applicable Beta Service or Beta Region may be deleted or inaccessible.
2.5. Test Observations, Suggestions concerning a Beta Service or Beta Region, and any other information about or involving (including the existence of) any Beta Service or Beta Region are considered EOS Confidential Information.
2.6. WITHOUT LIMITING ANY DISCLAIMERS IN THE AGREEMENT OR THE TEHCNICAL TERMS, BETA SERVICES AND BETA REGIONS ARE NOT READY FOR GENERAL COMMERCIAL RELEASE AND MAY CONTAIN BUGS, ERRORS, DEFECTS, OR HARMFUL COMPONENTS. ACCORDINGLY, AND NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THE AGREEMENT OR THESE SERVICES TERMS, EOS IS PROVIDING BETA SERVICES AND BETA REGIONS TO YOU “AS IS.” EOS AND ITS AFFILIATES AND LICENSORS MAKE NO REPRESENTATIONS OR WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE REGARDING BETA SERVICES AND BETA REGIONS, INCLUDING ANY WARRANTY THAT THE BETA SERVICES AND BETA REGIONS WILL BECOME GENERALLY AVAILABLE, BE UNINTERRUPTED, ERROR FREE, OR FREE OF HARMFUL COMPONENTS, OR THAT ANY CONTENT, INCLUDING YOUR CONTENT, WILL BE SECURE OR NOT OTHERWISE LOST OR DAMAGED. EXCEPT TO THE EXTENT PROHIBITED BY LAW, EOS AND ITS AFFILIATES AND LICENSORS DISCLAIM ALL WARRANTIES, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR QUIET ENJOYMENT, AND ANY WARRANTIES ARISING OUT OF ANY COURSE OF DEALING OR USAGE OF TRADE. EOS’S AND ITS AFFILIATES’ AND LICENSORS’ AGGREGATE LIABILITY FOR ANY BETA SERVICES AND BETA REGIONS WILL BE LIMITED TO THE AMOUNT YOU ACTUALLY PAY EOS UNDER THIS AGREEMENT FOR THE BETA SERVICES THAT GAVE RISE TO THE CLAIM DURING THE 12 MONTHS PRECEDING THE CLAIM.
3. User Management (Roles and Permissions)
3.1. We may change user credentials created by you if we determine in our reasonable discretion that a change is necessary for the protection of your EOS account and resources, and we will promptly notify you of any such change.
3.2. We may change, discontinue, or deprecate support for any third-party at any time without prior notice.
4. Financial Management (GL & ALM Tools)
4.1. General Ledger
4.1.1. You are solely responsible for the configuration and setting of the General Ledger according to the regulatory requirements you are bound by.
4.2. Assets and Liabilities Management
4.2.1. You agree that management of Assets, Liabilities and Accounts within the Platform will be done by you solely, and by a trained and professional personnel.
5. Content Center (CMS Tool)
5.1. Applications (End-user Facing Texts)
5.1.1. You are responsible to make sure that all texts, images and other Content you upload to the Platform are compliant with laws and regulations you are bound by.
5.2. Notifications (Customer Facing SMS / Email / Push)
5.2.1. Fees will apply regardless of whether delivery of your notifications is prevented, delayed, or blocked due to reasons outside of EOS control.
5.2.2. You may not charge recipients for receiving notifications by SMS unless you have obtained the recipient’s express consent. You must advise recipients receiving notification by SMS that telecommunications providers may charge the recipient to receive notifications by SMS. You are responsible for ensuring you have all necessary terms in place with push notification service providers, including terms necessary to comply with data protection laws.
5.2.3. EOS may change, discontinue, or deprecate support for a third party push notification platform at any time.
5.2.4. Through your use of Content Center you will not:
5.2.4.1. Transmit any material that contains viruses, Trojan horses, worms, or any other malicious or harmful programs.
5.2.4.2. Materially violate or facilitate the material violation of any local or foreign law, rule, regulation, or order, including laws regarding the transmission of data or software.
5.2.4.3. Transmit material that is sexually explicit, relates to “adult services”, or contains sensitive financial or identifying information (such as social security numbers).
5.2.4.4. Resell, sublicense, or timeshare the Services, or use them on behalf of anonymous or other third parties.
5.2.4.5. Use the Services in hazardous environments (such as operation of nuclear facilities, aircraft navigation, or any other use that may result in foreseeable risk of injury, death, or destruction of property).
5.2.5. We may suspend or terminate your access to, or block or decline to send or receive any notifications, if we determine that our scan of Your Content included notifications reveals abusive or low quality (such as “spam”), notifications bounces back to us or we receive abuse complaints (including complaints from third parties) in connection with your notifications, or the source or email address you have provided us for complaints is not successfully receiving email.
5.2.6. If your notifications are blocked, delayed, or prevented from delivery by reasons outside of our control, your payment obligations continue.
5.2.7. From time to time, telecommunication providers may change or modify their rules, requirements, and policies (collectively “Carrier Policies”). You are responsible for complying with all Carrier Policies that apply to your use of the Service.
5.2.8. Like many email service providers, to increase the security and reliability of email you send, attempt to send, or receive using EOS and the Content Center (“CC Email”), we (or our third-party providers) may store and scan your CC Email and Your Content included in CC Email to protect you and EOS by preventing and blocking “spam” e-mails, viruses and spyware, and other harmful or unwanted items from being sent and received over the .
5.2.9. We may suspend or terminate your access to , or block or decline to send or receive any Email, if we determine that:
· our scan of CC Email or Your Content included in CC Email reveals abusive or low quality email (such as “spam”),
· CC Email bounces back to us or we receive abuse complaints (including complaints from third parties) in connection with your CC Email, or
· the source or return email address you have provided us for “address bounces” or complaints is not successfully receiving email.
5.2.10. If your CC Emails are blocked, delayed, or prevented from delivery by reasons outside of our control, your payment obligations continue.
5.2.11. EOS is not the “sender” as defined in the CAN-SPAM Act or similar applicable law.
5.2.12. CC Email provides a filtering service designed to filter unwanted emails, such as spam, phishing emails, and email infected with viruses. You acknowledge that the technological limitations of the filtering service will likely result in the capture of some legitimate email and the failure to capture some unwanted email, including email infected with viruses.
5.2.13. CC Email may be blocked, delayed, or prevented from being delivered by destination email servers and other reasons outside of our control. Your payment obligations continue regardless of whether delivery of your emails is prevented, delayed, or blocked.
5.2.14. You agree not to use CC Email for sending:
· Bulk emails, such as mass marketing emails
· Unsolicited and unwanted emails
· Phishing emails
5.2.15. You are solely responsible for ensuring any emails you send using CC Email comply with the CAN-SPAM Act and all other applicable law. You agree that EOS is not the “sender” of any emails you send using CC Email as defined in the CAN-SPAM Act and all other applicable laws.
5.2.16. EOS may log and use information such as server hostnames, IP addresses, timestamps, mail queue file identifiers, and spam filtering information for the purpose of troubleshooting or improving CC Email.
5.3. Documents
5.3.1. You are solely responsible for ensuring any documents you send to Customers comply with legal and regulatory requirements applicable to you.
6. Products Factory (BPM Tool)
6.1. You are solely responsible for setup and definition of flows you create within the Product Factory and for ensuring anything you present to End-Users comply with legal and regulatory requirements applicable to you.
6.2. Features within the Product Factory may be dependent on information provided by 3rd parties, some of which are governmental and other organizations. We cannot guarantee the accuracy or availability of such features.
6.3. You are solely responsible for testing products that you create using the Product Factory in staging environment, and to make sure they are satisfactory to you, before presenting it to End-Users.
6.4. Automated Testing
6.4.1. For any test run on EOS (each, a “Test”), you represent and warrant that you have an active and valid license agreement with the tested device and tested software owner (including Microsoft, Apple, Google, IOS App Store and Android Play Store) at the time any such Test is run. You understand that you are responsible to for all actions you undertake in connection with each Test.
6.4.2. You agree not to and not to attempt to:
(i) perform any network discovery inside EOS or otherwise in connection with the test;
(ii) generate any internet traffic from within EOS, unless approved by us; internet traffic should be limited to devices only;
(iii) root, unlock, or jailbreak any tested device;
(iv) install persistent software on devices or with connection to EOS; or
(v) change settings on tested devices, or call or access third-party servers in a manner that would interfere with any Services.
6.4.3. You acknowledge and agree that we may disclose application packages, test packages (pre- compiled), test script source code, application extension files, or auxiliary data files to third parties solely for purposes of conducting automated security verification.
6.5. Staging Environments
6.5.1. Any new feature is tested before being deployed to staging environments. You will report to EOS regarding any issue you will find in staging environments, prior to deploying it to production environment.
7. Ticketing Tool
7.1. You are solely responsible for setting up and defining tickets you wish to use.
8. Customer Center (End-User Information & Actions)
8.1. Information presented within the ‘customer center’ module, is information which was received by you, by end-user, or by 3rd party.
9. Rules Management (Defining Risk Management)
9.1. You are solely responsible for setting up and defining rules you wish to use.
10. Analytics (BI Dashboard)
10.1. EOS Analytics may use Your Content that you select as a data source for EOS Analytics to make personalized recommendations to you, such as suggested visualizations based on your query history and suggested insights.
10.2. EOS Analytics Machine Learning Services. “EOS Analytics ML Services” means EOS Analytics. “EOS Analytics ML Content” means Your Content that is processed by an EOS Analytics ML Service. The following terms apply to your use of EOS Analytics ML Services:
(a) You agree and instruct that: (i) we may use and store EOS Analytics ML Content to maintain and provide EOS Analytics ML Services (including development and improvement of EOS Analytics ML Services and their underlying technologies); (ii) we may use and store EOS Analytics ML Content that is not personal data to develop and improve EOS and affiliate machine-learning and artificial intelligence technologies; and (iii) solely in connection with the development and improvement described in clauses (i) and (ii), we may store your EOS Analytics ML Content in EOS regions outside the EOS regions where you are using EOS Analytics ML Services.
(b) You are responsible for providing legally adequate privacy notices to End Users of your products or services that use EOS Analytics ML Services and obtaining any necessary consent from such End Users for the processing of EOS Analytics ML Content and the storage, use, and transfer of EOS Analytics ML Content as described under this Section. You represent to us that you have provided all necessary privacy notices and obtained all necessary consents. You are responsible for notifying us in the event that any EOS Analytics ML Content stored by EOS Analytics ML Services must be deleted under applicable law.
(c) You will not, and will not allow any third-party to, use EOS Analytics ML Services to, directly or indirectly, develop or improve a similar or competing product or service.
11. Reports
11.1. You are solely responsible for defining reports you wish the system to present. We do not guarantee we will support every requested report.
12. ITOC
12.1. Network Operation Center
12.1.1. EOS operates a Network Operation Center (NOC). NOC log files can be obtained by you through the software.
12.1.2. EOS collects and stores certain information for the Services you are monitoring, including CPU utilization, data transfer, disk usage and activity (collectively, “EOS Metric Data”). EOS Metric Data may be used by EOS to maintain and provide the Services (including development and improvement of the Services).
12.2. Security Operation Center
12.2.1. EOS operates a Security Operation Center (SOC). SOC log files can be obtained by you through the software.
12.2.2. Our SOC will make best efforts to monitor, identify, investigate, and respond to security threats, and in case needed will recover lost data and will operate in order to maintain business continuity.
12.3. Banking Operations Center
12.3.1. EOS operates a Banking Operation Center (BOC).
12.3.2. You are solely responsible for setup and definitions of the BOC flows and usage.
12.4. Bankers Support, Training and Certification Center
12.4.1. “EOS Bankers Support” means the support programs that EOS provides in connection with the Services, and includes account representative and other sessions and materials. EOS Bankers Support is a “Service” for purposes of the Agreement.
12.4.2. “EOS Training” means the training programs that EOS provides in connection with the Services, and includes instructor-led and self-paced digital classes and other training sessions and materials. EOS Training is a “Service” for purposes of the Agreement.
12.4.3. “EOS Certification” means the program through which EOS makes available professional certifications and other credentials in connection with the Services. The EOS Certification Program is a “Service” for purposes of the Agreement.
12.4.4. Any guidance provided through EOS Bankers Support, Training and Certification Services is provided for your convenience, does not constitute legal or compliance advice, and is not subject to any legal professional privilege. You are responsible for making your own assessment of whether your use of EOS Bankers Support, Training and Certification Services meets applicable legal and regulatory requirements, including by engaging with a legal professional if necessary.
13. Developer Tools
13.1. API / SDK Documentation
13.1.1. We will make best efforts to maintain the software usage documentation up to date. You acknowledge there may be discrepancies in documentation, and you are the sole responsible for making sure you use our API/SDK in a way which is satisfactory to you in staging environments.
13.2. Changelog
13.2.1. The Services are evolving over time. We are making efforts to disclose within the Changelog all major changes we make to the Services from time to time. You acknowledge and agree that we may not disclose all the changes made and may delay disclosure of some changes if they don’t materially affect you.
13.3. Open Banking
13.3.1. We do not guarantee that we will support every open banking protocol.
13.4. Developer Support Level
13.4.1.1.A business-continuity solution by a trusty, in-case of permanent failure by EOS, as described in the EOS SLA.
13.4.1.2.A prior Notice to you if EOS decides to discontinue a Service, as described in EOS Customer Agreement.
13.4.1.3.Access to a technical account manager.
14. Extensions
14.1. Extension development by Customer will be done according to the Extension Development Guidelines as published on EOS Website.
15. Development Acceleration (Acceleration of specific requirements)
15.1. “EOS Development Acceleration Services” are advisory and consulting services that EOS provides under a statement of work (“SOW”) to help you use the other Services. EOS Development Acceleration Services are “Services” for purposes of the Agreement.
15.2. EOS or any of its affiliates may enter into a SOW or an addendum to the Agreement with you to provide EOS Development Acceleration Services. For the purposes of each SOW or addendum, the term “EOS” in the SOW, the addendum and the Agreement refers to the EOS entity that executes the SOW or addendum, and no other EOS entity has any obligations under that SOW or addendum. Each SOW or addendum (together with the Agreement) is intended by the parties as the final, complete, and exclusive terms of their agreement and supersedes all prior agreements and understandings (whether oral or written) between the parties with respect to the subject matter of that SOW or addendum.
15.3. EOS will invoice you monthly for the EOS Development Acceleration Services. Payments for EOS Development Acceleration Services are not refundable.
15.4. EOS does not provide legal or compliance advice. You are responsible for making your own assessment of whether your use of the Services meets applicable legal and regulatory requirements.
15.5. Other than Third Party Content, Content that EOS provides as part of the EOS Development Acceleration Services is EOS Content. You are solely responsible for testing, deploying, maintaining and supporting Content provided or recommended by EOS.
15.6. EOS may develop Content consisting of either (a) documents and diagrams (“Documents”) or (b) software (in source or object code form), sample code, or scripts (“Software”) as part of the EOS Development Acceleration Services (such Documents and Software, “Developed Content”). Subject to any non- Disclosure agreement in effect between you and EOS, EOS is not precluded from developing, using, or selling products or services that are identical to, similar to or related to the Developed Content. Any Developed Content provided to you by EOS as part of the EOS Development Acceleration Services under a SOW is fully owned by EOS.
15.7. Any materials or information that you own or license from a third party and provide to EOS for the purposes of the EOS Development Acceleration Services are Your Content. If you choose to provide access to Your Content to EOS, then you will ensure that you have adequate rights and permissions to do so.
15.8. EOS and its affiliates will handle any personal data relating to your personnel (“Personnel”) that is provided to EOS or its affiliates in connection with a SOW in accordance with the handling practices described in the EOS Privacy Notice. You will make the EOS Privacy Notice available to any Personnel whose personal data you provide to EOS or its affiliates.
15.9. Any guidance provided through EOS Development Acceleration Services is provided for your convenience, does not constitute legal or compliance advice, and is not subject to any legal professional privilege. You are responsible for making your own assessment of whether your use of EOS Development Acceleration Services meets applicable legal and regulatory requirements, including by engaging with a legal professional if necessary.
15.10.You will not, and will not allow any third-party to, use EOS Development Acceleration Services to, directly or indirectly, develop or improve a similar or competing product or service.
16. EOS Machine Learning and Artificial Intelligence Services
16.1. “AI Services” means, collectively, EOS Analytics, EOS Financial Management, EOS Products Factory, EOS Tasks Management, EOS ITOC. “AI Content” means Your Content that is processed by an AI Service.
16.2. You and your Users are responsible for all decisions made, advice given, actions taken, and failures to take action based on your use of AI Services. AI Services may use machine learning models that generate predictions based on patterns in data. Output generated by a machine learning model is probabilistic and should be evaluated for accuracy as appropriate for your use case, including by employing human review of such output.
16.3. You agree and instruct that for EOS Analytics, EOS Financial Management, EOS Products Factory, EOS Tasks Management, EOS ITOC: (a) we may use and store AI Content that is processed by each of the foregoing AI Services to maintain and provide the applicable AI Service (including development and improvement of such AI Service and its underlying technologies); (b) we may use and store AI Content that is not personal data to develop and improve EOS and affiliate machine-learning and artificial-intelligence technologies; and (c) solely in connection with the development and improvement described in clauses (a) and (b), we may store such AI Content in a EOS region outside of the EOS region where you are using such AI Service.
16.4. You are responsible for providing legally adequate privacy notices to Users of your products or services that use any AI Service and obtaining any necessary consent from such Users for the processing of AI Content and the storage, use, and transfer of AI Content as described under this Section, including providing any required notices and obtaining any required verifiable consent under law and obtaining any required consent of individuals appearing in any images or videos processed by an AI Service. You represent to us that you have provided all necessary privacy notices and obtained all necessary consents. You are responsible for notifying us in the event that any AI Content stored by an AI Service must be deleted under applicable law. If you use EOS in connection with websites, programs or other applications that are directed or targeted, in whole or in part, to children under age 18 and subject to COPPA or similar laws you must provide all required notices and obtain all required verifiable parental consent.
16.5. You will not, and will not allow any third-party to, use the AI Services to, directly or indirectly, develop or improve a similar or competing product or service.
16.6. Regulatory Use of EOS Products Factory. EOS Products Factory’s face comparison feature uses machine learning to detect similarities between faces in different images and generate predictions of the likelihood the same person appears in both images; it does not provide definitive identifications of any person. Given the nature of machine learning systems, the following terms apply when Financially Regulated Entities use EOS Products Factory’s face comparison feature in connection with regulatory requirements. “Financially Regulated Entities” means an entity whose responsibilities include identifying fraudulent or criminal activity, investigation, apprehension, or reporting.
16.6.1. If EOS Products Factory is used to assist in identifying a person, and actions will be taken based on the identification that could impact that person’s civil liberties or equivalent human rights, the decision to take action must be made by an appropriately trained person based on their independent examination of the identification evidence.
16.6.2. Financially Regulated Entities that use EOS Products Factory to assist personnel in making decisions that could impact civil liberties or equivalent human rights must ensure such personnel receive appropriate training on responsible use of facial recognition systems, including how to properly operate the system and interpret its results.
16.6.3. EOS Products Factory may not be used for sustained surveillance of a specific person without following an independent review process that is designed to protect civil liberties or equivalent human rights (such as obtaining a court order, warrant, or other authorization), unless the use is to address exigent circumstances involving a threat or serious harm to a person.
16.6.4. Financially Regulated Entities that use EOS Products Factory for criminal investigations must provide a public disclosure describing their use of facial recognition systems. The method and content of the disclosure is at the reasonable discretion of the entity, but should be easily accessible to the public (such as a posting on a website), describe how the facial recognition system is used, and summarize safeguards in place to prevent violations of civil liberties or equivalent human rights.