Biometric Privacy Policy

1. Purpose and Scope

EPASS Inc., doing business as PROFID (“PROFID,” “we,” “us,” or “our”), uses identity-verification technology to help confirm that an individual is the person associated with identity information submitted for a background-screening workflow, to detect impersonation and fraud, and to protect the integrity and security of the screening process.

This Policy describes how PROFID collects, uses, discloses, protects, retains, and destroys Covered Biometric Data. It applies when PROFID or a service provider acting on PROFID’s behalf processes Covered Biometric Data in connection with PROFID’s services. It is intended to satisfy applicable biometric-privacy requirements, including the public-policy requirements of the Illinois Biometric Information Privacy Act and the Colorado Privacy Act, and applicable biometric requirements under Texas and other state law.

2. Covered Biometric and Related Verification Data

“Applicable Law” means any federal, state, or local law applicable to the relevant biometric processing activity. “Covered Biometric Data” means biometric identifiers and biometric information protected by Applicable Law, including a scan, map, template, or measurement of face geometry and information derived from such data when used to identify or verify an individual. PROFID also applies the handling and destruction controls in this Policy to source facial captures used to create or evaluate a biometric identifier, even where a particular law excludes a photograph or video from its statutory definition.

Covered Biometric Data may include:

source selfies, facial images, or short videos used for facial comparison or liveness analysis;
facial geometry, facial maps, facial templates, or comparable biometric identifiers; and
raw liveness, anti-spoofing, or presentation-attack signals used to verify identity.

“Related Verification Data” means non-biometric information used to conduct, secure, document, or audit identity verification, including identity-document images and extracted document information.

Related Verification Data may also include device, session, and transaction information; consent evidence; non-biometric verification results; quality and fraud indicators; support records; security logs; and audit records.

Related Verification Data is retained under the applicable general privacy, consumer-reporting, security, contractual, and legal schedules. It is not subject to the thirty-day destruction schedule solely because it relates to a biometric verification. Any Covered Biometric Data embedded in a Related Verification Data record remains subject to the biometric retention and destruction requirements in this Policy.

PROFID does not use Covered Biometric Data to evaluate an individual’s qualifications, predict conduct, assign an employment-suitability score, or make an employment decision.

Before collecting or obtaining Covered Biometric Data, PROFID will provide any notice and obtain any consent or written release required by Applicable Law. The notice will identify the categories of data involved, the specific purpose of the processing, the applicable retention period, and whether the data will be disclosed to a processor or other authorized recipient.

An individual may decline or withdraw consent where Applicable Law permits. Declining or withdrawing consent may prevent completion of an automated identity-verification step. PROFID does not make the resulting employment decision. PROFID makes a non-biometric or manual identity-verification path available for each biometric identity-verification workflow. PROFID does not treat use of the alternative path, a mismatch, failure, or inability to verify as an automatic negative factor. Where Colorado law applies, PROFID may collect and process biometric identifiers for identity verification as part of a reasonable background check, application, or identification process aligned with a prospective employee’s reasonable expectations under C.R.S. § 6-1-1314(6)(d)(II), or for a current employee use aligned with the employee’s job description or role under C.R.S. § 6-1-1314(6)(d)(I), in each case subject to the notice and consent requirements of C.R.S. § 6-1-1314(4). PROFID does not use biometric information for an unrelated purpose. For a use outside the statutory background-check, application, identification, job-role, or other permitted purposes, the restrictions of C.R.S. § 6-1-1314(6)(a)-(b), including voluntary consent and non-retaliation, continue to apply. In other circumstances, the employer or other PROFID client remains responsible for determining whether any additional alternative is legally required and whether any employment action is lawful.

4. Permitted Purposes

PROFID and its authorized service providers may process Covered Biometric Data only as reasonably necessary to:

authenticate identity and compare a live capture with an identity document or other authorized reference;
detect impersonation, manipulated media, spoofing, duplicate identity use, or other fraud;
secure the background-screening workflow and connect the correct individual to the correct screening request;
conduct quality control, security validation, error correction, and investigation of identity-related disputes;
maintain audit evidence required by law or reasonably necessary to demonstrate that the verification was properly performed; and
comply with a valid legal requirement, court order, warrant, or subpoena.

Covered Biometric Data will not be used for unrelated advertising, cross-context behavioral advertising, or unrelated generalized model development. It will not be used to train or fine-tune a generalized model unless PROFID first establishes a separate lawful basis, provides any required notice, obtains any required consent, and confirms that the use is permitted by its contractual and source restrictions.

5. Disclosure and Service Providers

PROFID may disclose or make Covered Biometric Data available only:

to confidential identity-verification, security, hosting, and technology service providers acting on PROFID’s behalf and only as necessary for the disclosed purpose;
with the individual’s consent or at the individual’s direction;
where required or expressly permitted by applicable law, regulation, court order, warrant, or subpoena; or
as otherwise necessary to complete a transaction or service specifically requested or authorized by the individual, where permitted by law.

PROFID may provide the Client that requested the verification with a non-biometric verification result. Limited supporting evidence may be provided only when specifically disclosed to the individual, legally permitted, and covered by any required consent. PROFID does not provide raw biometric identifiers, source facial captures, raw liveness data, or reusable biometric templates to a Client unless expressly authorized by Applicable Law and the individual’s specific written consent.

PROFID contractually restricts service providers from using Covered Biometric Data for their own unrelated purposes and requires appropriate confidentiality, security, incident-response, retention, and deletion controls. Covered Biometric Data is stored and processed only in the United States. Personnel and contractors located outside the United States are prohibited from accessing production systems or Covered Biometric Data. PROFID does not publish the commercial identities of confidential service providers in this Policy, but will provide information about a recipient when disclosure is required by Applicable Law or a valid consumer request.

6. No Sale or Profit From Biometric Data

PROFID does not sell, lease, trade, or otherwise profit from an individual’s Covered Biometric Data. Fees charged for identity-verification and background-screening services are fees for performing the requested services and do not authorize the sale, licensing, or unrelated commercial use of Covered Biometric Data.

7. Retention Schedule

PROFID retains Covered Biometric Data only for the shortest period reasonably necessary for the disclosed purpose, subject to the following schedule and any shorter period required by law or stated in the individual notice:

7.1 Open Verification

While pending, Covered Biometric Data may be retained to complete the verification, support an authorized retry or manual review, investigate fraud or security anomalies, and resolve a dispute. A verification still pending thirty (30) calendar days after initiation is deemed abandoned and subject to Section 7.2.

7.2 Closed Verification

After a verification is completed, canceled, or abandoned, PROFID’s default schedule is to permanently destroy source selfies or videos, facial templates or maps, and raw liveness or anti-spoofing biometric signals within thirty (30) calendar days. If a documented fraud investigation, security review, identity-related dispute, or manual-review process remains open, PROFID may retain only the Covered Biometric Data reasonably necessary for that specific purpose and only while retention remains permitted by Applicable Law. PROFID reviews each exception at least every ninety (90) days and initiates permanent destruction within thirty (30) calendar days after the exception ends. Any shorter period required by Applicable Law or stated in the individual notice controls. Related Verification Data may be retained under separate schedules, but any Covered Biometric Data embedded in those records remains subject to this Section. For data governed by the Illinois Biometric Information Privacy Act, no exception in this Policy extends retention after the initial collection purpose has been satisfied, except pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

7.3 State-Specific Maximum Periods

Illinois:Covered Biometric Data subject to the Illinois Biometric Information Privacy Act will be permanently destroyed when the initial purpose for collecting or obtaining it has been satisfied or within three years after the individual’s last interaction with PROFID or the collecting entity, whichever occurs first. Absent a valid warrant or subpoena issued by a court of competent jurisdiction, PROFID will comply with that retention schedule and destruction requirement.
Colorado:A biometric identifier subject to Colorado law will be deleted by the earliest of: (a) the date the initial collection purpose is satisfied; (b) twenty-four months after the individual’s last interaction with PROFID; or (c) no more than forty-five days after an annual review determines that storage is no longer necessary, adequate, or relevant to the express processing purpose. PROFID may use one additional period of up to forty-five days only where Colorado law permits and the extension is reasonably necessary because of the complexity or number of records to be deleted.
Texas: A biometric identifier subject to Texas law will be destroyed within a reasonable time and no later than one year after the purpose for collecting it expires, unless Texas law authorizes a longer period.
Washington: A biometric identifier subject to Washington law will be retained no longer than reasonably necessary to provide the authorized service, comply with law, and protect against fraud, criminal activity, claims, security threats, or liability.
Other Jurisdictions: PROFID will apply any shorter retention period, deletion trigger, or additional restriction required by Applicable Law.

“Last interaction” means the last date on which the individual interacted with PROFID or a service provider acting for PROFID in connection with the relevant biometric process.

8. Permanent Destruction Procedures

When a deletion trigger occurs, PROFID will:

identify the affected Covered Biometric Data and associated storage locations;
delete or render permanently unreadable the affected data in active systems using available secure-deletion or cryptographic-erasure methods;
instruct applicable service providers to delete the affected data under their contractual deletion procedures;
prevent deleted data from being used, restored to production, or processed for another purpose; and
document completion of the deletion workflow or the lawful basis for any permitted hold.

If data remains temporarily in a protected backup that cannot reasonably be edited record by record, the data will be isolated from ordinary use, will not be restored except for legitimate disaster recovery or security purposes, and will be deleted or overwritten through the applicable backup-rotation process within the period allowed by law. Any restored backup remains subject to the original deletion instruction.

PROFID may delay deletion only to the extent retention is expressly required or permitted by Applicable Law, including a valid court order, warrant, subpoena, or legally required preservation obligation. For data governed by the Illinois Biometric Information Privacy Act, only a valid warrant or subpoena issued by a court of competent jurisdiction may extend retention beyond the statutory destruction trigger. When the permitted hold ends, deletion will resume promptly. Related Verification Data may be retained under separate legal or compliance schedules, but any Covered Biometric Data within those records remains subject to this Policy.

9. Security Safeguards

PROFID protects Covered Biometric Data using a reasonable standard of care within its industry and in a manner that is the same as or more protective than the manner in which it protects other confidential and sensitive information. Safeguards include, as appropriate to the system and risk:

access controls and least-privilege permissions;
encryption or comparably protective controls during transmission and storage;
logging, monitoring, and separation of duties;
vendor diligence and contractual security requirements;
data minimization and purpose limitation; and
secure deletion and incident-response procedures.

No method of storage or transmission is completely secure, but PROFID maintains safeguards designed to reduce the risk of unauthorized access, acquisition, use, alteration, or disclosure.

10. Security Incident Response

PROFID maintains an internal incident-response protocol for Covered Biometric Data. It covers detection, containment, evidence preservation, risk assessment, remediation, coordination with service providers and clients, and legally required notices, including notice to affected Colorado residents under C.R.S. § 6-1-716. Service providers must maintain incident-response processes and notify PROFID as required by contract and Applicable Law.

The detailed internal incident-response protocol is confidential because publishing security-sensitive procedures could increase risk. This section describes the public portion of PROFID’s response framework.

11. Individual Requests

Where provided by Applicable Law, an individual may request access to, correction of, or deletion of Covered Biometric Data, withdraw consent, or request information about the categories, source, purpose, retention, or authorized recipients of the data. PROFID may take reasonable steps to verify the requester’s identity and authority before responding.

Requests may be submitted to support@theprofid.com. PROFID will respond within the period required by Applicable Law. Exercising a protected privacy right will not affect an individual’s right to dispute a consumer report or exercise other rights under the Fair Credit Reporting Act.

12. Changes to This Policy

PROFID may update this Policy to reflect changes in law, technology, or operations. The current version will state its effective date and last-updated date. PROFID will not materially expand the use of previously collected Covered Biometric Data in a manner inconsistent with the notice and consent under which it was collected without first providing any additional notice and obtaining any additional consent required by law.

13. Contact

EPASS Inc. d/b/a PROFID
Email: support@theprofid.com