Interesting. My plaintext reading of the law interpreted "scan of face geometry" as a full 3D mapping (i.e. photographic plus infrared rangefinding), and I stand corrected on the intended reading of the text.
That is an argument which no one has tested in court yet. But it seems unlikely to succeed as the law doesn't specify any requirements on how “biometric identifiers” such as face geometry are collected. And indeed the courts appear disposed to allow the phrase to cover any extraction of face geometry data regardless of the technological means by which it is done.