PURE’S BIOMETRIC DATA PRIVACY POLICY

1. POLICY STATEMENT

This Biometric privacy policy (“Biometric Data Privacy Policy”) applies to the use of the website https://pure.app/ in its entirety, including all of our subpages, associated sites or pages (“Website”), and the PURE mobile and web app, which is accessible through browser on your mobile phone, tablet computer and personal computer (“App”) (collectively, “PURE”), are operated by Online Classifieds AG, Baarerstrasse 8, 6300 Zug, Switzerland, CHE-274.401.166 (“we”, “us”, “our”). This Biometric Data Privacy Policy applies solely to individuals who are residents of the United States in jurisdictions where such maintenance of a Biometric Data Privacy Policy is required by applicable law, and supplements the information contained in our general Privacy Policy (here).

We use facial recognition software for the purposes of improving the user experience, enhancing user safety on PURE, and preventing fraud.

We recognize the sensitivity of Biometric Data and take seriously its obligations to maintain the confidentiality and protect security of such data. To promote these efforts, we have adopted the following Biometric Data Privacy Policy.

2. DEFINITIONS 

“Biometric Data” means any biological characteristics of a person, or information based upon such a characteristic, including characteristics such as those defined as “Biometric Identifiers” and “Biometric Information” under laws regulating the processing of biometric identifiers or information.  

“Biometric Identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, or any additional characteristics defined as such under laws regulating the processing of biometric identifiers or information.

“Biometric Information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual, or any additional characteristic or measurement defined as such under laws regulating the processing of biometric identifiers or information.  

3. PURPOSE FOR COLLECTION OF BIOMETRIC DATA 

As detailed further in our online Privacy Policy (here), Users have the option to complete an in-app Photo Verification process to earn a Verification badge on their profile. In connection with this process, we use internally developed software to compare a set of real-time photos captured during the verification flow with the photos the user has uploaded to their PURE profile. This feature is optional and is designed solely to confirm that the same individual appears in both sets of images; it does not verify identity or authenticate government-issued documents. 

The photos captured during the Photo verification process are stored on our servers and are used only for the core functionality of this feature. These photos are then compared exclusively on the server side to confirm a match. We do not and will not use collected Biometric Data to personally identify users. All Biometric Data collected during the comparison process will be securely stored on our servers, will not be shared with any third parties, and will be handled in strict accordance with our privacy and data protection standards. Upon account deletion, any Biometric Data collected during the process will also be permanently deleted. If you choose to cancel the Photo verification process at any point before its completion, no Biometric Data related to this process will be retained. 

4. DISCLOSURE AND AUTHORIZATION

We will not disclose or disseminate any Biometric Data to anyone other than service providers (who would be acting on our behalf and subject to contractual obligations) without/unless:

a. First obtaining written consent to such disclosure or dissemination, if such disclosure or dissemination occurs;

b. The disclosed Biometric Data completes a financial transaction requested or authorized by the user;

c. Disclosure is required by state or federal law or municipal ordinance; or

d. Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

5. SECURITY OF BIOMETRIC DATA

We will use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic Biometric Data collected.  

We will retain Biometric Data only until, and shall request that any service providers, as applicable, that may have access to the Biometric Data destroy such data when, the first of the following occurs:

a. The initial purpose for collecting or obtaining such Biometric Data has been satisfied; or 

b. Within 3 years of the user’s last interaction with PURE.

If legal obligations require us to retain Biometric Data for longer than the above, we will destroy such data not later than the first anniversary of the date the data is no longer required to be maintained by law.