Biometric Information Privacy Policy & Consent

1. Purpose of Collection

To ensure the security of our platform and prevent identity fraud, Flashpass IDV (“we,” “us,” or “our”) uses facial recognition technology to verify the identity of drivers. When you upload a photo of your Commercial Driver's License (CDL) and a “selfie” photograph, our system uses Artificial Intelligence to compare the facial geometry in both images.

2. Definition of Biometric Data

As used in this policy, Biometric Data includes “biometric identifiers” and “biometric information” as defined by applicable law (e.g., 740 ILCS 14/1 et seq., Tex. Bus. & Com. Code § 503.001). This includes record of your facial geometry, faceprints, or other unique biological patterns derived from your uploaded images.

3. Disclosure and Use

We do not sell, lease, or trade your Biometric Data. Your data is used solely for:

• Verifying your identity against your government-issued ID.
• Complying with legal obligations or valid law enforcement requests.

Your Biometric Data may be processed by our third-party identity verification provider, Google, who is contractually required to protect your data with the same or higher level of care as described here.

4. Storage and Retention

We protect your Biometric Data using industry-standard encryption and security controls. We will retain your Biometric Data only until the earliest of the following occurs:

• The initial purpose for collecting the data (identity verification) has been satisfied.
• You request the deletion of your data (subject to legal/regulatory requirements).
• 45 days from your last interaction with our application.

Once the retention period expires, we use secure deletion methods to permanently destroy the data so it cannot be recovered.

5. Your Rights

Depending on your residency (e.g., Illinois, California, Texas), you may have the right to:

• Access the specific pieces of biometric information we have collected.
• Request deletion of your biometric data.
• Opt-out of automated decision-making. If you opt-out, your application will be flagged for manual human review, which may delay processing.