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Biometric Information Disclosure
Last updated: October 5, 2023
Various laws require us to provide you notice and obtain your consent to collect and use your Biometric Information. By affirming your consent to this policy you acknowledge, understand understanding and consent to the collection, specific use and storage of your Biometric Information as set forth in this section.
This Notice and Consent for the collection of Biometric Information, Personal Information and Sensitive Personal Information ("Consent") describes how Emblem collects and processes certain categories of Personal Information in connection with the Services provided by Emblem ("Services"). By providing your consent you acknowledge and agree that you have been provided with, and agree to be bound by the Emblem Terms and Conditions and the Emblem Privacy Policy.
Please carefully review the details below prior to consenting to our collection and use of your information. Please note that once consent has been provided for the collection and processing of your information as part of your verification it may not be revoked where it is required to complete the transaction for which it was collected, or to complete the verification Services.
Specifically, we collect a live capture of your face to indicate an age range, which is the basis for our identity and age verification process. The data generated during this verification process are not stored on our servers. If a manual review process is needed to verify your age, the data will be deleted upon completion of the transaction.
We maintain and store all information in accordance with the same federal law.
We will not disclose, disseminate, or transmit any Data to any person or entity unless
- We obtain a separate written release from you authorizing the disclosure, disseminate, or transmit your data.
- The disclosure is required by State or federal law or municipal ordinance; or
- The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
We retain the Data collected from you until the purposes outlined in this section and in our corresponding Biometrics Disclosure have been satisfied, or within three years of your last interaction with us, whichever occurs first.
1. What are Personal Information and Sensitive Personal Information
In order to verify your identity, Emblem 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 Emblem 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 verification. Emblem will never sell, rent, or trade any of this information. For more information about the information collected by Emblem, 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 information we collect will vary depending on the specific type of Services you request. Certain Services – those requiring a NIST 800-63A IAL2 credential may require a higher level of assurance for your identity verification. When you sign up for an applicable Emblem Service we may collect the following Biometric Information:
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 using your mobile or other device. We use these images to create a facial geometry or faceprint which we use for purposes of identity verification and to prevent the creation of multiple accounts in a fraudulent manner.
4. How Do We Use Your Biometric Information?
We use your Biometric Information only as follows:
- To verify your identity when you are opening an account or using our Services;
- To authenticate use of your account and the Services for a transaction;
- To prevent fraudulent uses of Emblem Services or the creation of multiple accounts; and
- To comply with legal obligations or comply with a request from law enforcement or government entities where not prohibited by law.
- To monitor and improve the operation, delivery, and general accessibility of our Services.
5. 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 you at the required level of assurance for use of all of our Services.
6. What Kind of Storage and Security Do You Use With My Biometric Information?
We employ appropriate security safeguards. To safeguard certain sensitive information, we implement security measures such as encryption, firewalls and intrusion detection and prevention systems.
7. 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 Biometric Data Consent Statement addressing any significant changes.