Biometric Information Privacy Policy

Last updated: May 13, 2025

Various laws require us to provide you notice and obtain your consent to collect and use your Biometric Information. This Biometric Information Privacy Policy explains Emblem's approach to biometric data, which has been updated to reflect our current role as a privacy infrastructure provider.

Important Notice: Emblem's Role

Emblem does not directly collect, process, or store biometric information for verification purposes. Emblem provides privacy infrastructure that connects users with third-party verification providers who may collect and process biometric information according to their own privacy policies and terms of service.

When biometric verification is required, you will be redirected to a third-party verification provider who will perform the verification. Emblem only receives verification status information, not the actual biometric data used in verification.

Biometric Authentication for Account Security

The only biometric functionality directly associated with Emblem is the optional use of your device's built-in biometric authentication (such as FaceID or TouchID) to secure access to your Emblem account. This biometric data is processed exclusively by your device's operating system - Emblem does not collect, store, or have access to your actual biometric information.

1. What are Personal Information and Sensitive Personal Information

In order to provide our privacy infrastructure services, Emblem collects certain Personal Information. The specific categories of Personal Information that may be collected through your use of Emblem Services may include name, email address, and phone number for account management and authentication.

Important: Any Sensitive Personal Information that may be required for verification (such as government ID numbers, date of birth, or biometric data) is collected and processed directly by third-party verification providers, not by Emblem. Please refer to the privacy policies and terms of service of these verification providers for information about how they handle your Sensitive Personal Information.

Emblem will never sell, rent, or trade any information we collect. 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. Third-Party Verification Providers and Biometric Information

When you need to verify your identity or age using biometric verification methods:

1. You will be redirected to a third-party verification provider
2. The verification provider may collect biometric information according to their privacy policy and terms of service
3. The verification provider performs the verification and determines your verification status
4. Upon completion, the verification provider informs Emblem only of your verification status, not your biometric data
5. Emblem creates a secure token representing this status without storing any biometric information
6. With your consent, Emblem shares only your verification status with requesting platforms

Before being redirected to a third-party verification provider, you will have the opportunity to review their privacy policy and provide consent for their collection of your biometric information. This consent is separate from your consent to Emblem's terms and policies.

4. Device Biometric Authentication

The only biometric functionality that Emblem directly interacts with is your device's built-in biometric authentication system (such as FaceID or TouchID) for securing access to your Emblem account. Important points about this functionality:

• This biometric data is processed entirely on your device by your device's operating system
• Emblem never receives, collects, or stores any of this biometric data
• Using biometric authentication to access your Emblem account is completely optional
• You can disable biometric authentication for your Emblem account at any time through your device settings

5. Can I refuse to provide Biometric Information?

Yes, you may refuse to consent to the use of biometric verification methods. If you choose not to use biometric verification when redirected to a third-party verification provider, alternative verification methods may be available depending on the verification provider's capabilities.

If you refuse to use biometric verification and no acceptable alternative is available, this may limit your ability to use certain services that require high levels of identity assurance. However, this is determined by the requirements of the service you are attempting to access, not by Emblem.

6. Security of Verification Tokens

While Emblem does not collect or store biometric information, we do create and store verification tokens that represent your verification status. These tokens:

1. Contain only verification status information (e.g., "verified" or "over 18")
2. Do not contain any actual biometric data or measurements
3. Cannot be used to recreate or access your biometric information

We employ appropriate security safeguards to protect these tokens, including 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 information practices or our Services. We will post a notice for users at the top of this Biometric Information Privacy Policy addressing any significant changes.

8. Contact Information

If you have any questions or concerns about this Biometric Information Privacy Policy or about Emblem's privacy practices in general, please contact us at:

VerityGuard, LLC2207 N. Molter Rd LL100Liberty Lake, WA 99019

Email: support@emblemapp.com

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