Biometric Data Retention Policy

1. Scope and Definitions

This policy applies to all biometric data collected by FaceAccess across its products and services including FaceAccess Home, FaceAccess Business, FaceAccess Mobile, and the FaceAccess Web Dashboard.

Biometric Identifiers

As used in this policy, "biometric identifiers" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. FaceAccess specifically collects facial geometry scans in the form of encrypted 128-dimensional mathematical templates derived from camera imagery.

Biometric Information

"Biometric information" 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. FaceAccess biometric information includes facial recognition embeddings and associated liveness and quality scores stored per enrolled face.

2. Purpose of Collection

Biometric data is collected solely for the following purposes:

• Identity verification and authentication for access control systems
• Multi-factor authentication to secure accounts and devices
• Liveness detection to prevent spoofing and fraud
• Matching against enrolled templates for door and gate access events

Biometric data is never used for advertising, employee monitoring beyond stated purposes, data mining, or sale to third parties.

3. Informed Written Consent

Prior to collecting biometric identifiers, FaceAccess:

• Informs the subject in writing that biometric identifiers are being collected and stored
• Provides this written policy to the subject
• Receives a written release (via checkbox consent at enrollment) from the subject or their legally authorized representative

Consent records are stored with a timestamp and may be accessed by the subject upon request.

4. Retention Schedule

Biometric identifiers and biometric information collected by FaceAccess are retained according to the following schedule:

Event / Trigger	Retention Action	Timeframe
User deletes face enrollment in account settings	Permanent deletion	Within 30 days of request
Account deletion / termination	Biometric data permanently destroyed	Within 30 days of account closure
Initial purpose fulfilled (access event logged)	Raw frame data deleted; template retained for ongoing auth	Immediately (raw frames)
User inactivity (no logins or access events)	Retention review; deletion if purpose no longer active	After 3 years of inactivity
User submits deletion request to support	Permanent deletion from all systems	Within 30 days of verified request
Consent withdrawal	Biometric data permanently destroyed	Within 30 days
Maximum retention period (from last active use)	Automatic deletion regardless of other status	3 years from last activity

In all cases, biometric identifiers are destroyed no later than the earlier of: (a) when the initial purpose for collecting or obtaining such identifiers has been satisfied, or (b) within 3 years of the individual's last interaction with the Company.

5. Destruction Method

Biometric data is permanently destroyed using the following methods:

• Database records: Cryptographic zeroing and row deletion with cascading foreign key removal from all associated tables
• Backup systems: Biometric data fields are excluded from routine database backups; existing backups containing the data are overwritten or purged within 90 days of the deletion event
• Encryption keys: Per-user encryption keys associated with biometric data may be permanently destroyed to cryptographically render stored data unrecoverable

FaceAccess maintains deletion logs for compliance audit purposes. These logs contain the timestamp and type of data deleted but do not re-contain the deleted biometric data itself.

6. Storage and Security

During the retention period, biometric data is:

• Stored only on access-controlled, encrypted infrastructure operated by FaceAccess or its infrastructure provider (Cloudflare)
• Encrypted at rest using AES-256 or equivalent
• Transmitted only over TLS 1.2+ encrypted connections
• Never stored as raw photographs or video — only as mathematical templates
• Access-controlled so that only authorized systems can query biometric templates during authentication

7. Prohibition on Sale or Profit

FaceAccess does not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. This prohibition applies permanently and is not subject to waiver.

8. Third-Party Disclosure

Biometric data is disclosed to third parties only:

• When required by applicable law, warrant, or court order (and, to the extent legally permissible, with prior notice to the subject)
• With the express written consent of the subject
• To Cloudflare as our infrastructure provider under a strict Data Processing Agreement that prohibits Cloudflare from independently accessing or using biometric data

9. State-Specific Compliance

Illinois (BIPA — 740 ILCS 14/)

FaceAccess complies with all BIPA requirements including: obtaining written informed consent, maintaining this publicly available retention policy, prohibiting sale or profit from biometric data, and implementing reasonable security measures.

Texas (CUBI — Tex. Bus. & Com. Code § 503.001)

FaceAccess captures biometric identifiers only for identity verification purposes. Biometric data is destroyed within a reasonable time no later than one year after the purpose for collection has been fulfilled, consistent with our schedule above.

Washington (My Health MY Data Act)

Washington residents may request deletion of all biometric data at any time through account settings or by contacting support@faceaccess.com. Deletion will be completed within 30 days.

California (CCPA / CPRA)

California residents have the right to know what biometric data is collected, request deletion, opt out of sale (FaceAccess does not sell biometric data), and not be discriminated against for exercising these rights. Submit requests via support@faceaccess.com.

10. Subject Rights and Requests

To exercise any right under this policy:

• In-app: Account Settings → Privacy → Manage Biometric Data
• Email: support@faceaccess.com with subject "Biometric Data Request"

FaceAccess will respond to verified requests within 30 days. Identity verification may be required prior to processing deletion or access requests.

11. Policy Updates

This policy may be updated to reflect changes in law or business practices. Material updates will be communicated via email and in-app notice. The retention schedule will never be extended beyond statutory maximums without renewed consent.

12. Contact

Biometric Data Privacy Officer:
support@faceaccess.com