Biometric Information Policy

BIOMETRIC INFORMATION POLICY

Purpose

This Biometric Information and Security Policy defines Vacmobile Corporation’s (“Vacmobile”) policies and procedures for the collection, storage, use, protection, retention, and deletion of biometric data collected by Vacmobile Corporation through its Vacmobile app or other means.

A copy of this policy is available at vacmobile.app/biometric-information-policy/.

Biometric Information Collected

Vacmobile scans its users’ facial geometry using the user’s smartphone camera. This may include two scans. The facial geometry scans are taken from the user’s face itself and from the photo on the user’s photo ID, as provided by the user or their employer or one of Vacmobile’s vendors. These facial geometry scans are referred to as “Biometric Information” for the purposes of this policy.

Use of Biometric Information

Vacmobile provides services to help track and verify vaccination status to a user’s employer. The Vacmobile app’s purpose as a verifiable and trustworthy form of proof of vaccination requires identity verification and the Biometric Information is collected for this purpose. A user’s specific identity is verified by comparing a photo of the user taken from the user’s smartphone with the photo on that user’s scanned photo ID. The photo IDs used could include a driver’s license, passport, military ID, or other form of government-issued ID card. The necessary data processing to accomplish this process is provided by Jumio, a third-party vendor. Beyond this, the Biometric Information may be used internally by Jumio to improve its facial recognition and identity verification services.

Vacmobile does not sell, lease, trade, or otherwise profit from any of the Biometric Information it collects. Biometric Information will only be disclosed as required by law, including by court order, or with the user’s consent. The Biometric Information may be sent to one of Vacmobile’s vendors, including Jumio, for the purposes of providing services to Vacmobile.

Storage Policy for Biometric Information

All Biometric Information is stored on servers located in the United States after having been received from the user’s Vacmobile app. Vacmobile will use reasonable means to protect all Biometric Information in its possession in accordance with applicable standards and laws, including the Illinois Biometric Information Privacy Act, and in every event with the same, or a higher, standard of protection than is given to other confidential and/or sensitive information in Vacmobile’s possession.

Retention Policy for Biometric Information

All Biometric Information will be retained for no longer than required for the purpose for which it was collected, which is to confirm that the individual setting up the account is the individual appearing on the government-issued ID. Such Biometric Information is stored for less than 1 business day.