Thanks for the info. We don't use any private data, only publicly available images. So it won't be a problem, in my opinion.
I will contact my lawyer and double check this.
You might want to look up Clearview AI, who also took publicly available images, performed biometric recognition on them and ended up with a €30.5 million fine: https://blog.barracuda.com/2024/10/23/clearview-ai-fine-gdpr...
The GDPR works on the personally-identifiable vs anonymous distinction. Private vs public doesn't really factor into it, or at least only becomes relevant in the nuances.
Personally identifiable data is just a mouthful, which is why people like to misleadingly shorten it to private data.
Not only the EU, but you will have to check with each of the 50 US states as they all have a patchwork of laws. Illinois was one of the first, but I don't know much about it; I thought I read it was pretty extensive to the point some facial recognition companies specifically exclude it. Texas also has its own version as well, that I know of; again don't know details.