Consent for ID.me to Collect Biometric Data | ID.me

CONSENT FOR ID.ME TO COLLECT BIOMETRIC INFORMATION AND SENSITIVE PERSONAL INFORMATION

In the event of any discrepancy between a non-English version of this document and the English version of this document, the English version shall prevail in all respects.

BIOMETRIC INFORMATION PRIVACY STATEMENT

ID.me will not sell, rent, or trade your Biometric Information. Your Biometric Information will only be used by ID.me for identity proofing in accordance with the guidelines published by the National Institute for Standards and Technology and as required for the prevention of fraud and identity theft.

Notice and Consent

This Notice and Consent for the collection of Biometric Information and Sensitive Personal Information ('Consent') describes how ID.me collects and processes certain categories of Personal Information in connection with the Services provided by ID.me ('Services'). By providing your consent you acknowledge and agree that you have been provided with, have reviewed, and agree to be bound by the ID.me Terms of Service and the ID.me Privacy Policy, and for ID.me's collection, processing, and retention of your Biometric Information in association with use of our Services.

Please carefully review the details below prior to consenting to our collection and use of your information. Please note that once consent is provided for the collection and processing of your information as part of your identity proofing, it may not be revoked until the transaction for which consent was given is completed.

1. What are Personal Information and Sensitive Personal Information

In order to verify your identity, ID.me must collect your Personal Information, including certain Sensitive Personal Information. The specific categories of Personal Information or Sensitive Personal Information that may be collected through your use of ID.me Services may vary, however some examples of Personal Information collected include name, address, and date of birth. Some examples of Sensitive Personal Information that may be collected include different types of personal identification numbers, including social security, driver's license, passport, or state ID card numbers as well as your geolocation information at the time of identity proofing. ID.me will never sell, rent, or trade any of this information. For more information about the information collected by ID.me, as well as additional details about how this information may be processed, please see our Privacy Policy.

2. What is Biometric Information?

Biometric Information is a form of Personal Information related to biometric characteristics which may be used to identify you. Common examples include fingerprints, voiceprints, scans of a hand, facial geometry recognition, and iris or retina recognition. As used in this policy, Biometric Information includes any 'biometric identifiers' or 'biometric information' as defined under applicable law.

3. What Biometric Information Do We Collect?

The Biometric Information we collect will vary depending on the specific type of Services you request. When you sign up for an applicable ID.me Service we may collect the following Biometric Information which is used for identity proofing and preventing the creation of fraudulent wallets:

Facial Biometrics: Our Service may require you to upload an image of your government issued or other identification document(s) as well as your photographic image or 'selfie' photograph. We use these images to create or derive facial geometry or faceprint for identity proofing, to prevent the creation of multiple wallets, and for the detection and prevention of fraud.
Fingerprint Information: You may be required to submit fingerprints, including fingerprint or hand scanning, which we use for identity proofing and for the detection and prevention of fraud.

4. How Do We Use Your Biometric Information?

ID.me may use your Biometric Information to verify your identity and to assist in detecting and preventing fraud. We may use your Biometric Information to compare your facial geometry derived from the image on your identity document to your facial geometry derived from the photograph or video image that you provide to help verify your identity. We may also use your derived Biometric Information to detect and prevent fraud and identity theft by comparing your Biometric Information against other Biometric Information on the ID.me platform. The following are the permitted uses for Biometric Information you consent to when using ID.me Services:

your identity and/or age will be used when you are creating a wallet or using our Services;
authentication for your use of your wallet and the Services for a transaction;
improvement of the accuracy, inclusivity, and fairness of our biometric verification systems;
prevention of fraudulent uses of ID.me's Services or the creation of multiple wallets, including to detect and prevent identity theft; and
compliance with legal obligations or comply with a request from law enforcement or government entities where not prohibited by law.

5. Do We Share or Disclose Your Biometric Information?

ID.me will only share your Biometric Information with our partners in the following circumstances:

As required with other third parties where permitted by law to enforce our Terms of Service, to comply with legal obligations, or to cooperate with law enforcement agencies concerning conduct or activity that we reasonably believe may violate federal, state, or local law when required by a subpoena, warrant, or other court ordered legal action, and to prevent harm, loss or injury to others.
To third party service providers that perform functions on our behalf. These service providers are limited to using the Biometric Information to assist in our provision of Services, and must maintain any Biometric Information we share in a secure fashion.

6. Do We Sell Your Biometric Information?

ID.me will not sell, rent, or trade your Biometric Information. Your Biometric Information will only be used by ID.me to verify your identity in accordance with the guidelines published by the National Institute for Standards and Technology and as required for the prevention of fraud. In fulfilling our Services to you, ID.me will transfer your Biometric Information to our third party partners only when required by a subpoena, warrant, or other court ordered legal action.

7. How Long Does ID.me Retain My Biometric Information?

For purposes of this Section, 'wallet closure' means the permanent deactivation of your ID.me wallet.

ID.me retains your Biometric Information in accordance with applicable law and our data retention policies. Biometric Information will be retained while your ID.me wallet remains active. Following wallet closure, ID.me will delete your Biometric Information no later than one (1) year after the date of wallet closure, unless a shorter retention period is required pursuant to applicable law or contract.

If your Biometric Information is associated with a fraud investigation, suspected fraudulent activity, or confirmed fraud attempt, ID.me may retain such Biometric Information for up to three (3) years following wallet closure for fraud prevention, security, and legal compliance purposes.

ID.me may retain Biometric Information for a longer period where required by a subpoena, warrant, or other legally compelling justification.

8. Can I Request that ID.me Delete My Biometric Information?

Yes, you may direct ID.me to delete your Biometric Information by closing your ID.me Wallet. In order to continue using our Services your Biometric Data must be processed and retained. In order to delete your Biometric Information you must close your ID.me Wallet which will initiate ID.me's retention schedule. Biometric Data may be retained by ID.me for up to one (1) year following Wallet closure, shorter retention periods may apply where required by applicable law.

ID.me reserves the right to retain Biometric Information as needed to comply with our legal obligations, including warrants, subpoenas or other court orders, or for fraud prevention, investigation, or security purposes, consistent with applicable legal requirements.

9. Can I Refuse to Provide My Biometric Information?

Yes, you may refuse to consent for the collection of your Biometric Information. Please note that if you refuse to consent to the collection and processing of your Biometric Information then we may not be able to verify your identity or provide Services requested.

10. What Kind of Storage and Security Do You Use With My Biometric Information?

We are committed to protecting your information. We have adopted technical, administrative, and physical security procedures to help protect your information from loss, misuse, unauthorized access, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure.

We employ appropriate security safeguards. To safeguard certain sensitive information (such as Biometric Information and government-issued identification information), we implement security measures such as encryption, firewalls, and intrusion detection and prevention systems.

11. Changes

This Biometric Information Privacy Policy may be periodically updated. From time-to-time we may update this policy to reflect new features or changes in our Personal Information practices or our Services. We will post a notice for users at the top of this Privacy Policy addressing any significant changes.