Facial Scan and Biometric Information Policy

Last Updated: September 2024

This Facial Scan and Biometric Information Policy (“Policy”) describes how Trulioo Information Services Inc., its affiliates and its third-party service providers (“Trulioo”, “we”, or “our”) use facial scan data extracted from photos in connection with the identity document verification services that we provide to our customers. For information about our privacy practices with respect to our identity verification and related online services, please visit our Services Privacy Policy.

The company that provides the service or operates the website or application that you are using or wish to gain access to (“Company”) uses Trulioo technology to verify your identity via a photo capture of your identity document and/or a photograph of you.

To provide these services for Company, Trulioo may extract a facial scan from your identity document and a facial scan from your photograph and compare these scans to verify your identity. Trulioo may also use your facial scans and other data to detect and prevent fraud or to develop and improve our products and services. The facial scans generated and used by Trulioo may be considered “biometric information”, “biometric data” or “biometric identifiers” under applicable law.

The images and facial scan data are collected, used, and stored by Trulioo and its service providers who are contractually committed to confidentiality and protection of your data. Trulioo will destroy your facial scan immediately upon completion of a verification check or up to one year after your last interaction with Trulioo, consistent with the Company’s instructions, unless further retention is required by law.

Any service providers used by Trulioo will process your data solely to provide the services necessary for your use of Company’s products and services. Trulioo does not share your facial scan data with Company. Based on the results of its comparison, Trulioo may advise Company whether your identity was verified or whether any indicators of fraud were detected. Trulioo does not sell, trade, or lease your facial scan data. Trulioo stores facial scans and photographs of you and your identity documents in encrypted format.

Trulioo is not responsible for Company’s practices. We encourage you to review Company’s privacy policies and terms to understand how Company uses data about you.

Except as otherwise noted, this Policy governs in the event of any inconsistencies between any Trulioo privacy policy, terms of service, or any other documentation provided by Trulioo.