Biometric Data Policy

This Biometric Data Policy explains how Coffr, LLC ("Coffr," "we," "us") collects, uses, shares, keeps and destroys Biometric Data. It applies to every person who completes identity verification on Coffr, including account holders, invited team members and recipients who never create an account.

This policy supplements our Privacy Policy. If the two conflict on Biometric Data, this policy controls. Where a state law gives you more protection than this policy, we follow that law.

Biometric Data means any scan of face geometry, face template or similar measurement of your facial features, and any information based on it that is used to identify you. In this policy, Biometric Data also includes the selfie images and liveness video captured during verification and the photo on your ID document as captured, even where a law would not treat a photograph as biometric.

Verification means the identity check you complete through our Verification Provider: capture of a government ID, capture of a selfie, and comparison of the two (face matching).

Verification Result means the outcome of a Verification (for example, passed or failed), the date, the verification reference ID, and non-biometric details such as your name, date of birth and ID type. A Verification Result is not Biometric Data.

Verification Provider means the identity verification company that performs Verification for Coffr as our service provider.

Last Interaction means the last date you logged in to Coffr, completed a Verification, or sent or received a payment or request through Coffr.

We collect Biometric Data only to verify your identity and to prevent fraud, including someone using another person's ID. We do not use Biometric Data for marketing, profiling, or as a profile photo.

Our Verification Provider captures your ID photo and selfie and performs the face match for us. It returns the Verification Result to Coffr. Companies you work with on Coffr may rely on your Verification Result so you do not have to verify again. They receive the result, never your Biometric Data.

Our Verification Provider acts as our service provider. We require it to process Biometric Data only on our instructions and to delete it on the schedule in Section 6.

Before any Biometric Data is captured, we ask for your written consent on the first screen of Verification. Biometric consent is its own checkbox, separate from our Terms of Service. You cannot start Verification without checking it, and we keep a record of your consent (date, time, the wording you saw and its version).

If you do not consent, we will not collect your Biometric Data. You will not be able to complete Verification, which may limit what you can do on Coffr. We do not currently offer a verification option that does not use Biometric Data.

Coffr never sells, leases, trades or otherwise profits from Biometric Data. We do not disclose Biometric Data to anyone except:

• our Verification Provider and our other service providers, only to perform Verification for us and under written contracts;
• where you consent to the specific disclosure;
• where required by law, subpoena or a valid court order; or
• to complete a financial transaction you request or authorize, where permitted by law.

Companies that rely on your Verification on Coffr receive only the Verification Result.

We permanently destroy Biometric Data on the schedule below. In every case, we destroy it no later than the earlier of (a) when the purpose of collecting it has been met, or (b) 3 years after your Last Interaction with Coffr.

What we keep after destruction. We keep the Verification Result and your consent record, which contain no Biometric Data, for 7 years after your Last Interaction to meet legal, audit and fraud-prevention obligations.

Re-verification. When you verify again, new Biometric Data is captured with new consent, and the schedule above starts again.

How we destroy it. Biometric Data is deleted from Coffr's systems and from our Verification Provider's systems. Copies in backups are overwritten within 35 days as backups rotate and are not restored for any other use.

You can ask us to delete your Biometric Data before the schedule in Section 6. Email privacy@getcoffr.com with the subject "Biometric deletion request." We will delete your Biometric Data from Coffr's systems and instruct our Verification Provider to delete its copy.

We will confirm deletion within 30 days. To protect you, we may ask you to confirm your identity first without collecting new Biometric Data. Deleting Biometric Data does not delete your Verification Result; if you also want that deleted, say so in your request and we will tell you whether a legal obligation requires us to keep it.

Security. We store, transmit and protect Biometric Data using a reasonable standard of care for our industry, and in a way that is the same as or more protective than how we protect other confidential and sensitive information. This includes encryption in transit and at rest and access limited to people who need it.

Changes. If we change this policy, we will update the date above. If a change affects how we use Biometric Data already collected, we will ask for your consent again.

Contact. Questions about this policy: privacy@getcoffr.com or Coffr, LLC, 7415 Southwest Parkway, Building 5, Suite 500-670, Austin, TX 78735.