Biometric Consent Policy

Purpose

This Biometric Data Collection and Retention Policy (“the Policy”) describes how we collect, use, store and safeguard the identification and photographic or video image data you provide (“your ID data”) in order to verify your age in connection with determining your eligibility to use or continue to use our services (the “Services”).

ID Data

After obtaining your voluntary written consent through your electronic acceptance of this Policy, we will ask you to provide a photo of your government-issued ID to us at the time you begin using the Services. You will also be asked to take and provide a photographic or video selfie (not an existing photograph) that will be used to estimate your age using a facial algorithm.

Our Use and Disclosure of ID Data

It is our policy to protect, use, and store your ID data in accordance with all applicable laws. We will use your ID data to verify your age only in connection with determining your eligibility to use the services. We may use one or more third-party vendors to assist us with verifying your age through analysis of your ID data. We will not sell or market your ID data and will only share or disclose your ID data to third parties for verifying your age or where: (i) required by applicable federal, state, or municipal law, including response to legal process (such as a subpoena, warrant or civil discovery request); (ii) you or your legally authorized representative consents to such disclosure; or (iii) the disclosure completes a transaction that you or your authorized representative has requested.

Storage and Retention of ID Data

We and/or our third-party vendors will store, transmit and protect your ID data using a reasonable standard of care in accordance with the terms of its agreement with us, and for no longer than three (3) years, unless legally permitted to be maintained longer, for example, if preservation of your ID data is required by a warrant or subpoena. We and/or our third-party vendors will store, transmit and protect your ID data using appropriate technical and organizational measures.