Biometric Information Privacy Policy
Effective Date: January 24, 2025
INTRODUCTION
This Biometric Information Privacy Policy (the “Policy”) is applicable to users residing in the United States of America.
We care about the security of your personal information and seek to protect you and us against fraud. Where permitted by law, SJD4L and certain of our service providers use ID scanning and facial recognition technology to verify your identity and safeguard personal information as part of our security, compliance, and fraud prevention efforts.
This Data4Living™ Biometric Information Privacy Policy (the “Biometric Policy”) defines the rights you grant SJD4L Enterprises, LLC (“SJD4L”, “we”, “us”, or “our”) regarding your Biometric Information, clearly describes how we collect, retain, use, disclose and protect your Biometric Information, and outlines the tools you have to exercise control over your Biometric Information. This Biometric Policy, together with our Privacy Policy, Terms of Service, and any other agreement between you and SJD4L related to the Service (collectively, the “Agreements”) set forth the terms on which SJD4L provides the Service to you. Capitalized terms are defined below in our Privacy Policy or in our Terms of Service.
Biometric Information
Biometric Information Definition: “Biometric Information” refers to data that depict or describe physical, biological, or behavioral traits, characteristics, or measurements of or relating to an identified or identifiable person’s body. Biometric Information includes, but is not limited to, depictions, images, descriptions, or recordings of an individual’s facial features, iris or retina, finger or handprints, voice, genetics, or characteristic movements or gestures (e.g., gait or typing pattern). Biometric Information also includes data derived from such depictions, images, descriptions, or recordings, to the extent that it would be reasonably possible to identify the person from whose information the data had been derived. By way of example, both a photograph of a person’s face and a facial recognition template, embedding, faceprint, or other data that encode measurements or characteristics of the face depicted in the photograph constitute Biometric Information. There are different definitions for biometric information, or Biometric Information, under different state laws. Within this Biometric Policy we generally adopt the Federal Trade Commission’s (“FTC”) definition. For example, some states’ biometric laws don’t apply to driver’s license photos. While photos of you may not be considered biometric information, biometric information can be made from processing the photo using certain technology.
Information Collected
When you consent to use of your Biometric Information, we (or service providers, such as technology vendors, working on our behalf) collect face scan information—face geometry information and related information—necessary to accomplish the purposes stated in this Biometric Policy, at points of collection, and/or in our Privacy Policy. We do not collect, use, store, or disclose your Biometric Information without your consent.
Purposes
We use your Biometric Information to verify your identity, prevent fraud, comply with anti-money laundering and sanctions screening requirements, and assist with account recovery. Subject to the storage and retention guidelines outlined below, we retain and use your Biometric Information for these purposes during your engagement with us or as otherwise permitted by law.
Our Service also offers Content storage and collection features that may involve storing your Biometric Information. For example, if you upload a photo containing your face, we will store it to provide the requested service. By agreeing to our use of your Biometric Information, you grant us, to the extent permitted by local laws, the right to store and process your Content for artificial intelligence and machine learning purposes, including training and any resulting uses.
Except for Content you upload and the rights granted above, we do not collect, use, or store Biometric Information.
Disclosure of Biometric Information
Unless otherwise required by law, your Biometric Information is accessible only to us and our service providers, which process your data only on our behalf to accomplish the purposes above. We do not share Biometric Information with any other third parties unless required by law. We do not sell, lease, trade or otherwise profit from the Biometric Information. We may disclose your Biometric Information to our authorized service providers or other third parties if:
- You or your authorized representative consent to the disclosure (for example, by providing confirmation to verify identity using a photo of yourself and an ID, or by authorizing a search for a photo or image, such as an x-ray, that you have uploaded);
- the disclosure completes a financial transaction requested or authorized by you or your authorized representative;
- the disclosure is required pursuant to a valid warrant, subpoena, or court order issued by a court of competent jurisdiction; or
- the disclosure is required by law.
Retention and Storage
We will collect, store, transmit, and protect your Biometric Information using a reasonable standard of care that is at least as protective as the way we collect, store, transmit, and protect other confidential and sensitive personal information.
Unless otherwise required by an order from a court of competent jurisdiction or applicable law, we will only retain Biometric Information until: (i) the initial purpose for collecting the Biometric Information has been satisfied, or (ii) for three years following your last interaction with us, whichever occurs first, unless legally required to keep it for a different period.
For any questions regarding our use of Biometric Information or other privacy inquiries, please email us at [email protected].