Biometric Data Retention & Destruction Policy

Definitions

For the purposes of this policy, “biometric data” refers to a scan of face geometry and any mathematical representation (such as a facial descriptor or template) derived from an image of a user’s face that could be used to identify an individual.

A “verification selfie” refers to a still photograph captured during the verification process. A verification selfie is a photograph and is not, by itself, a biometric identifier or biometric template.

How Our Verification Works

Harpply’s facial verification and age estimation process runs entirely on your own device, within your web browser. When you complete verification:

• The facial scan, liveness check, and age estimation are performed locally on your device.
• Any scan of face geometry or facial descriptor generated during this process exists only temporarily in your device’s memory for the duration of the check and is not transmitted to Harpply or any third party.
• Harpply does not receive, collect, or store any scan of face geometry, facial descriptor, or facial template at any point.
• No biometric data is sold, leased, traded, or otherwise disclosed to any third party, because Harpply never receives it.

Because the biometric analysis occurs entirely on your device and the resulting biometric data is never transmitted to us, Harpply does not possess or maintain a database of biometric identifiers or biometric templates.

What Harpply Stores

The verification process produces an on-device age estimate that determines how your verification is handled. Depending on the result, one of the following occurs:

• If the age estimate meets our automatic-approval threshold, verification passes on your device and no verification selfie is transmitted to or stored by Harpply.
• If the age estimate falls within a range that requires manual confirmation, or falls below our threshold and is held for review, a verification selfie may be transmitted to Harpply solely for the purpose of manual age review by our team.

A verification selfie that is sent for manual review is a photograph only. It does not include any scan of face geometry, facial descriptor, or biometric template. No biometric data accompanies the verification selfie.

Separately, and regardless of which outcome applies, Harpply retains a limited compliance record of the verification. This record consists of whether you passed or were reviewed, your resulting age band, and your consent. Harpply never retains the raw face-geometry scan.

Retention and Destruction of Verification Selfies

For any verification selfie transmitted to Harpply for manual review, the following retention and destruction practices apply:

• Verification selfies are stored in encrypted, access-controlled storage.
• Access is limited to authorized personnel for the sole purpose of conducting manual age review.
• A verification selfie is deleted immediately upon completion of the manual review decision.
• In any event, a verification selfie is retained for no longer than thirty (30) days from the date of capture, after which it is permanently deleted, whether or not a review decision has been made.
• Verification selfies are not used for any purpose other than age verification. They are not used for marketing, advertising, profiling, or training of any system.
• Verification selfies are not sold, leased, traded, or otherwise disclosed to any third party for any commercial purpose.

Consent

Harpply obtains your consent through a two-step process before any facial verification begins:

• First, you are presented with the Age & Verification Agreement, which you must read and affirmatively accept. This agreement notifies you that facial and age verification may involve biometric identifiers or biometric information as defined by applicable law, including the Illinois Biometric Information Privacy Act (BIPA), and that separate, specific consent will be required before your camera is used.
• Second, immediately before your device camera is activated, you are presented with a dedicated verification consent screen. This screen describes what the verification does, that the facial scan occurs on your device, that face-geometry data is not saved, and what limited information is retained. You must provide your affirmative consent on this screen before the camera is activated.

Your camera will not turn on until you have provided consent on the dedicated verification consent screen. If you do not consent, you may not complete verification and may not gain full access to the Services.

A record of your consent is retained by Harpply as a compliance record. You may contact Harpply at any time with questions regarding this consent or the verification process using the contact information below.

Data Security

Harpply maintains reasonable technical and organizational safeguards designed to protect verification selfies during the limited period they are stored, including encryption and access controls. However, no method of electronic storage or transmission is completely secure, and Harpply cannot guarantee absolute security.

Changes to This Policy

Harpply may update this policy from time to time. The updated version will be indicated by a revised “Last Updated” date. Your continued use of the Services following any modification constitutes your acceptance of the updated policy.

Contact Us

If you have questions about this Biometric Data Retention & Destruction Policy, contact us at:

Harpply LLC 97049 Cutlass Way, Yulee, FL 32097, United States Email: support@harpply.com Phone: (+1) 904-310-0829