Biometric Privacy Notice

Effective November 22, 2021

Updated February 12, 2026

This Biometric Privacy Notice explains how Vouched Identity, Inc. (“Vouched“, “we“, “us“, “our“) collects, uses, shares, retains, and destroys your Biometric Data.

Please note that this Biometric Privacy Notice applies only to individuals located in the United States. For more information about how we collect, use, and share your personal information generally, please review our End User Privacy Statement.

Definition of Biometric Data

When we refer to “Biometric Data,” we mean specifically:

• “Biometric identifiers,” which are data generated by measurements of your biological characteristics, such as a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include (i) writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color; or (ii) information captured from you in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).
• “Biometric information” which is information based on a biometric identifier used to identify you.

Vouched Collection and Use of Biometric data

Vouched provides identity verification and fraud prevention services on behalf of our customers. In order to provide these services, Vouched may collect images of you (e.g., a selfie you provide) and/or images of your identification documents using Vouched systems and technologies.

Vouched software tools detect, verify and analyze Biometric Data included in images of you to provide identity verification and fraud detection. Vouched software uses Biometric Data solely for the purpose of identity verification and fraud prevention.

Vouched Disclosure of Biometric Data and Customer Obligations

Vouched may use third-party vendors to provide its services.

Vouched customers will have access to Biometric Data collected on their behalf. Vouched customers must comply with applicable law governing any collection, storage, use, disclosure, or transmission of Biometric Data processed by them or on their behalf, including Biometric Data captured by Vouched in the course of providing our services to the customer. Vouched customers may have their own policies that apply to their collection and use of your Biometric Data. Vouched has agreements with its customers requiring the customers to: (i) follow the retention schedule below with respect to Biometric Data captured by Vouched, (ii) only use Biometric Data, or permit Biometric Data to be used by their customers, for identity verification purposes consistent with this Biometric Privacy Notice, and (iii) keep Biometric Data confidential and secure.

Data Retention

If you are an Illinois or Texas resident: Vouched will retain your Biometric Data only until the first of the following occurs: (i) the initial purpose for collecting or obtaining your Biometric Data has been satisfied; or (ii) within 3 years of your last interaction with us. Vouched may delete Biometric Data earlier at the direction of a Vouched customer or if otherwise required by law. Except for as required for healthcare providers and in compliance with HIPAA, we permanently erase your Biometric Data at the end of the retention period described above such that it cannot be recovered or reconstructed.

If you are not an Illinois or Texas resident: We will retain your Biometric Data consistent with applicable laws and regulations and our third-party customer agreements.

Data Storage

Vouched shall use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which Vouched transmits and protects from disclosure other confidential and sensitive information of Vouched and its employees.

Your Release and Consent

As part of our identity verification and fraud prevention services, you will be asked to either check a box or click to continue button agreeing to this Biometric Privacy Notice and consenting to our collection, storage, use, and disclosure of your Biometric Data.