Face detection != face recognition. They don't really spell out if face detection without recognition is kosher, but face ID by advertisers is explicitly verboten.

I should have included more of the quote: "Exceptions. The prohibition in this Chapter does not apply to use of Face Recognition Technologies:..."

I'm not seeing your claimed explicit ban on advertising. Could you quote it please?

It doesn't call out advertisers directly but it does call out the Minority Report style ad serving.

IANAL but sec. A: defines FRT as "comparing the facial features of a probe image with the features of images contained in an image repository (one-to-many search)."

"Private Entity shall not use Face Recognition Technologies in Places of Public Accommodation"

"John Anderton, you could use a Guinness right now!" style targeted advertising requires matching features of the face (eyes) to a repository to get the name.

https://youtu.be/uiDMlFycNrw

Right, but if that was part of a social media app (say a hypothetical "Instagram display advertising" product) then it is explicitly included in the language: "Exceptions. The prohibition in this Chapter does not apply to use of Face Recognition Technologies:... In automatic face detection services in social media applications."

While I understand the difference between detection and recognition I think an exception naming both recognition and detection is likely to be viewed by a court as permissive.

Otherwise what does that exception mean? I'm not aware of any detection functionality in any social media application that isn't tied to recognition.