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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 the customers’ clients residing in the United States of America. This Policy supplements our Privacy Policy . Daon has instituted this Policy as it specifically relates to any Biometric Data that Daon possesses as a result of Daon’s customers’ and their clients’ use of the Services. In general, Daon’s customers are responsible for (a) providing its clients (as a data subject) 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 accordance with Daon’s customer contracts pursuant to Daon’s customers instructions.
1.3 Authorisation
To the extent required by applicable law, Daon’s customers will or, in certain circumstances Daon directly will:

  1. Inform each data subject or their authorized representative in writing that Daon may be processing collecting, processing, storing, or using Biometric Data, including by: (i) informing each data subject or their authorized representative in writing of the specific purpose, circumstances and manner of such collection, processing, storage or usage, including the length of time of storage, if applicable; and (ii) informing each data subject or their authorized representative in writing of the manner in which the data subject may opt out of the collection, processing, storage or usage of their Biometric Data; and
  2. 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 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:

  1. The data subject’s or their or their authorized representative’s written consent;
  2. The disclosed information completes a financial transaction authorised by the data subject or their authorized representative;
  3. Disclosure is required by state, federal or municipal law; or
  4. 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’ clients as a result of their use of Daon Services.

1.5 Retention Schedule
Daon will only 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.