Last Updated: March 5, 2026

Marlow Innovations Inc., doing business as AFR Engine (“AFR,” “we,” “our,” or “us”), provides investigative technology tools designed to assist authorized government agencies in generating potential investigative leads using image comparison technology.

AFR Engine operates as a technology service provider that processes images and related information submitted by authorized government agencies and investigative partners.

AFR Engine services are designed for use by authorized law enforcement agencies and public safety partners and are not intended for consumer use. AFR Engine does not provide facial recognition search capabilities directly to the general public.

Images processed by AFR Engine are submitted by authorized users acting within the scope of their agency duties or may originate from lawfully available public records maintained by government entities.

This Privacy Policy describes how AFR Engine processes information when users access our website or when authorized agencies use AFR Engine investigative services.

1. Scope of This Privacy Policy

This Privacy Policy applies to:

  • the AFR Engine website
  • AFR Engine investigative software services
  • authorized users of the AFR platform
  • individuals whose publicly available records or lawfully obtained investigative images may be processed by AFR Engine technology

This Privacy Policy does not apply to:

  • external government databases
  • agency record management systems
  • third-party systems integrated by agencies using AFR Engine

2. Service Provider Role

AFR Engine acts as a technology service provider that processes information on behalf of authorized government agencies. Government agencies using AFR Engine retain responsibility for determining the lawful collection and use of images submitted to the platform in accordance with applicable laws and agency policies.

3. Categories of Information Processed

AFR Engine may process several categories of information depending on how the platform is used.

Identifiers

Examples include:

  • name
  • email address
  • agency affiliation
  • account username
  • IP address
  • device identifiers

These identifiers generally relate to authorized platform users, such as law enforcement personnel.

Investigative Images

Authorized users may upload images for investigative comparison. These images may include:

  • photographs associated with investigations
  • surveillance images
  • booking photographs
  • images derived from public records

Public Records Information

Certain images processed by AFR Engine may originate from publicly available government records, including booking photographs or other lawfully released records. To the extent AFR Engine processes such information, the information may qualify as publicly available information under applicable privacy laws.

System Activity Information

AFR Engine systems may collect operational information such as:

  • browser type
  • system access logs
  • device information
  • timestamps of user activity
  • usage metrics

This information is used to operate and secure the platform.

4. Sources of Information

Information processed by AFR Engine may originate from:

  • Authorized Government Agencies: agencies may submit images or investigative materials for comparison
  • Public Records: certain images may originate from publicly available government records
  • Authorized Platform Users: account registration and platform activity generate operational information
  • Website Visitors: visitors may voluntarily provide contact information when submitting inquiries

5. Biometric Information and Facial Recognition Technology

AFR Engine software uses machine learning technology to compare facial images and generate similarity scores. When images are processed by the AFR Engine system, the software generates mathematical feature representations (“embeddings”) derived from facial characteristics present in an image. These embeddings consist of numerical vectors representing facial features as interpreted by AFR Engine’s proprietary machine learning models.

Embeddings generated by AFR Engine:

  • are not facial images
  • cannot be reverse engineered to recreate a face
  • cannot generate a photograph or likeness of an individual
  • have no meaning outside the AFR Engine comparison system

These templates are used solely for similarity comparison within the AFR Engine system.

Model-Specific Biometric Templates

Biometric templates generated by AFR Engine are model-specific numerical vectors produced by AFR Engine’s proprietary machine learning architecture. Because these templates are derived from AFR Engine’s proprietary model architecture:

  • they cannot be interpreted or used by unrelated facial recognition systems
  • they cannot be transferred for use by other biometric systems
  • they do not function as portable biometric identifiers

As a result, these templates have no practical utility outside the AFR Engine platform. AFR Engine does not provide, license, transfer, or sell biometric templates to third parties.

Non-Reconstructability of Templates

Biometric templates generated by AFR Engine are designed for similarity comparison and cannot be used to reconstruct the original facial image or generate a visual likeness of an individual. These templates function solely as numerical feature vectors used to calculate similarity scores between images.

6. Investigative Use of AFR Engine Technology

AFR Engine technology generates similarity-based search results intended to assist investigative processes. Results produced by AFR Engine represent potential investigative leads only and do not constitute positive identification of any individual.

Any investigative determination must be made independently by authorized investigators using additional evidence and investigative methods.

Human Review Requirement

AFR Engine technology does not make automated determinations regarding an individual’s identity. Investigative results generated by AFR Engine require human review and evaluation by authorized personnel.

No Consumer Enrollment

AFR Engine does not provide mechanisms for members of the public to enroll themselves or others into a biometric database. Biometric templates are generated only when images are submitted by authorized investigative users or processed from lawfully available public records.

7. Illinois Biometric Information Privacy Act (BIPA)

The Illinois Biometric Information Privacy Act (“BIPA”) regulates the collection and use of biometric identifiers in certain circumstances. AFR Engine services are provided exclusively to authorized government agencies and approved public safety partners and are not offered to the general public.

AFR Engine does not intentionally collect biometric identifiers directly from consumers or members of the public, including residents of Illinois. To the extent AFR Engine processes images derived from publicly available records or lawfully obtained investigative materials, such processing occurs solely to assist authorized government agencies with investigative lead generation.

AFR Engine does not sell, lease, trade, or otherwise profit from biometric identifiers.

8. Purpose of Processing

AFR Engine processes information for the following purposes:

  • assisting investigative lead generation
  • operating and maintaining the platform
  • preventing fraud or misuse
  • supporting authorized users
  • complying with legal obligations

9. Sharing of Information

AFR Engine does not sell personal information.

AFR Engine does not share personal information for cross-context behavioral advertising.

Information may be shared only in limited circumstances:

Authorized Agencies

Investigative results are returned to the authorized agency conducting the search.

Service Providers

AFR Engine may use trusted service providers for infrastructure and security operations. These providers process information only to support AFR Engine services.

Legal Requirements

Information may be disclosed when required by law or lawful government request.

10. Data Retention

AFR Engine retains information only as long as reasonably necessary for operational, legal, and investigative purposes. Retention periods may vary depending on the type of information. When information is no longer required, AFR Engine may delete, anonymize, or render such data inaccessible.

11. Security Safeguards

AFR Engine implements administrative, technical, and physical safeguards designed to protect information from unauthorized access or misuse. These safeguards may include:

  • encrypted communications
  • access controls
  • system monitoring
  • audit logging
  • network security protections

12. Technology Limitations

Facial recognition technology is a tool intended to assist investigative workflows and should not be relied upon as the sole basis for determining identity. Similarity scores generated by AFR Engine may be affected by factors such as image quality, lighting conditions, camera angle, occlusions, aging or changes in appearance, and image resolution.

Because of these limitations, AFR Engine results should be considered investigative leads only and must be evaluated using additional investigative methods and evidence.

13. California Privacy Rights (CCPA / CPRA)

California residents may have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

  • the right to request disclosure of personal information collected
  • the right to request deletion of personal information
  • the right to request correction of inaccurate personal information
  • the right to opt out of the sale of personal information
  • the right to limit use of sensitive personal information

Certain rights may be subject to statutory exemptions, including where information is processed as publicly available government records, for law enforcement investigative purposes, or pursuant to legal obligations.

Submitting California Privacy Requests

California residents may submit requests to know, delete, or correct information by emailing privacy@afrengine.com. Please include your name, contact information, and a description of your request. We may need to verify your identity or confirm applicable exemptions before responding.

Do Not Sell or Share My Personal Information

AFR Engine does not sell personal information and does not share personal information for cross-context behavioral advertising. Accordingly, AFR Engine does not offer an opt-out mechanism for sale or sharing because those activities do not occur. If you have questions about this statement, contact us at privacy@afrengine.com.

Limiting the Use of Sensitive Personal Information

AFR Engine processes sensitive personal information (which may include biometric identifiers derived from facial images) solely to provide investigative technology services to authorized government agencies and for security, audit, and legal compliance purposes. AFR Engine does not use sensitive personal information for advertising or consumer profiling. If you would like to submit a request related to sensitive personal information, contact privacy@afrengine.com.

14. Children’s Privacy

AFR Engine services are intended for authorized government personnel and are not directed to children. We do not knowingly collect personal information from children under 13.

15. Changes to This Policy

AFR Engine may update this Privacy Policy periodically. Updates will be reflected by the “Last Updated” date.

16. Contact Information

Questions regarding this Privacy Policy may be directed to: