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Facial Scan and Biometric Information Policy

Facial Scan and Biometric Information Policy

Last Updated: August 2022

This Facial Scan and Biometric Information Policy (“Policy”) describes how Trulioo Information Services Inc. and its affiliates (“Trulioo”) use facial scan data extracted from photos of users.

The company that provides the service or operates the website or application that you are using or wish to gain access to (“Company”) uses Trulioo technology to verify your identity via a photo capture of your identity document and a photograph of you.

Please note: if you wish to exercise legal rights you may have with respect to your personal information (e.g., access, deletion), please contact Company. Trulioo does not store information in a manner that would allow us to respond to these types of requests. Trulioo will permanently destroy your facial scan when requested to do so by Company or up to one year after your last interaction with Trulioo, whichever comes first, unless further retention is required by law.

To provide these services for Company, Trulioo will extract a facial scan from your identity document and a facial scan from your photograph and compare these scans (or scans you previously enrolled) to verify or authenticate your identity. Trulioo may also use your facial scans and other data to detect and prevent fraud or to develop and improve our products and services. The facial scans generated and used by Trulioo may be considered “biometric information” or “biometric identifiers” under applicable law.

The images and facial scan data are collected, used, and stored by Trulioo and its service providers who are contractually committed to confidentiality and protection of your data. Any service providers used by Trulioo will process your data solely to provide the services necessary for your use of Company’s products and services. Trulioo does not share your facial scan data with Company. Based on the results of its comparison, Trulioo may advise Company whether your identity was verified or authenticated or whether any indicators of fraud were detected. Trulioo does not sell, trade, or lease your facial scan data. Trulioo stores facial scans and photographs of you and your identity documents in encrypted format.

Trulioo is not responsible for Company’s practices. We encourage you to review Company’s privacy policies and terms to understand how Company uses data about you, including facial scan data.

Except as otherwise noted, this Policy governs in the event of any inconsistencies between any Trulioo privacy policy, terms of service, or any other documentation provided by Trulioo.