Biometric Information Privacy Policy

Effective Date: 4 August 2022

1.	Introduction This Biometric Information Privacy Policy (the “Policy”) is applicable to Daon’s customers and those customers’ end-users residing in the United States of America. This Policy supplements our Privacy Policy https://www.daon.com/privacy-policy/. This Policy specifically relates to any Biometric Data that Daon possesses as a result of Daon’s customers’ and their end-users’ use of Daon services. In general, Daon’s customers are responsible for (a) providing its end-users ( “data subjects”) with notice and obtaining consent for Daon’s use of Biometric Data; and (b) developing and complying with their own biometric data retention and destruction policies, as may be required under applicable law.
1.1	Biometric Data Defined As used in this Policy, “Biometric Data” includes both “biometric identifiers” (which means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry) and “biometric information” (which means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual).
1.2	Purpose for Collecting Biometric Data Daon collects, possesses, stores and uses Biometric Data in order to provide its customers with Daon services. This is done in accordance with contracts entered into with its customers which set out the processing instructions from those customers.
1.3	Authorisation To the extent required by applicable law, Daon’s customers will, or in certain circumstances Daon directly will: Inform each data subject, or their authorized representative, in writing of: (i) the specific purpose, circumstances, and manner that Daon may be collecting, processing, storing, or using their Biometric Data, including the length of time of storage, if applicable; and (ii) of the manner in which the data subject may opt out of the collection, processing, storage or usage of their Biometric Data; and Obtain a consent or written release signed by the data subject or their authorized representative authorizing Daon and its service providers to collect, store, and use Biometric Data for the specific reasons set forth in the written consent or release.
1.4	Disclosure Daon will not disclose, disseminate and/or transmit any Biometric Data to any person or entity other than the customer and Daon’s authorized licensors or vendors without/unless: The data subject’s or their authorized representative’s written consent; The disclosed information completes a financial transaction authorised by the data subject or their authorized representative; The disclosure is required by state, federal or municipal law; or The disclosure is required pursuant to a valid warrant or subpoena. Neither Daon nor its vendors will sell, lease or trade any Biometric Data that it receives from its customers or its customers’ end-users as a result of their use of Daon services.
1.5	Retention Schedule Daon will retain Biometric Data until the earlier of the following: Daon becomes aware of the fact that, or receives written notice from its customer that, the initial purpose for obtaining such biometric data has been satisfied; or Within 1 year of Daon’s collection of the Biometric Data, unless further retention is required for use of the specific service and if so then it shall be retained until such service expires or is terminated.