Authorized Users GDPR Biometric Use Policy TruU, Inc. Updated March 2023

Introduction

This Biometric Use Policy (“Policy”) describes how TruU, Inc. (“we”, “us”, or “our”) collects, uses, and protects biometric data in accordance with the General Data Protection Regulation (“GDPR”). We recognize the sensitivity and value of biometric data and are committed to complying with all applicable laws and regulations.

Definitions

  • “Biometric Data” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifiers or biometric information.
  • “Biometric Identifier” means a physiological or biological characteristic that is used to identify a specific individual, including but not limited to fingerprints, hand geometry, and facial recognition.
  • “Biometric Information” means any information based on an individual’s biometric identifiers, including but not limited to a template, algorithm, or any other representation of biometric data.

Collection and Use of Biometric Data

We may collect and use biometric data for the following purposes:

  • Security and access control: We may use biometric data to control access to our facilities, equipment, or systems.
  • Authorized User identity and access management: We may use biometric data to verify the identity of authorized users of employer network, data, applications and web assets.
  • Other lawful purposes: We may use biometric data for other purposes that are consistent with GDPR and applicable laws. 

We will only collect and use biometric data with your consent, or as required or permitted by law.

Legal Basis for Processing Biometric Data

Under GDPR, we may process biometric data based on the following legal bases:

  • Consent: If we obtain your explicit consent to process your biometric data.
  • Contractual necessity: If processing your biometric data is necessary for the performance of a contract between us and you.
  • Legal obligation: If processing your biometric data is necessary to comply with a legal obligation.
  • Legitimate interests: If processing your biometric data is necessary for our legitimate interests or those of a third party.

Storage and Protection of Biometric Data

  • We will store biometric data using reasonable and appropriate security measures to protect it from unauthorized access, disclosure, or destruction. 
  • We will retain biometric data for no longer than necessary to fulfill the purpose for which it was collected or as required by law.

Sharing and Disclosure of Biometric Data

We will not sell, lease, trade, or otherwise profit from biometric data. We will not disclose biometric data to third parties without your consent, or as required or permitted by law.

Your Rights and Choices

Under GDPR, you have the right to:

  • Be informed: Receive clear and concise information about our biometric data collection and use practices.
  • Access: Access your biometric data and obtain additional information about how it is being processed.
  • Rectify: Request that we correct or update any inaccuracies in your biometric data.
  • Erase: Request that we erase your biometric data in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.
  • Restrict processing: Request that we restrict the processing of your biometric data in certain circumstances, such as when you contest its accuracy.
  • Object: Object to the processing of your biometric data for certain reasons, such as when it is being processed for direct marketing purposes.
  • Portability: Receive a copy of your biometric data in a structured, commonly used, and machine-readable format, and have the right to transmit it to another data controller.

If you have any questions or concerns about our biometric data collection and use practices, or if you wish to exercise your rights under GDPR, please contact us at legalandprivacy@truu.ai

Updates

This Privacy Policy may be updated periodically to reflect new TruU features or changes in our Personal Information practices. We will post a notice for consumers at the top of this Policy of any significant changes. We will indicate at the top of the Policy when the policy was most recently updated.

Corporate Address and Contact Number

TruU, Inc. 2350 Mission College Blvd., Suite 780 Santa Clara, CA 95054

Toll Free: 1 877 214 2838

For Questions, Concerns or Legal Notices

legalandprivacy@truu.ai

To Request Deletion of Data or Exercise Rights in Relation Thereto:

biometricdeletionrequest@truu.ai

Copyright © 2023 TruU, Inc. All rights reserved.