Biometric Data Policy
1. Scope
This policy explains how FinVerified, Inc. ("FinVerified," "we") collects, uses, stores, discloses, retains, and permanently destroys biometric identifiers and biometric information. It applies to everyone whose identity we verify with a face comparison: patients who receive a secure link ("Magic Link") from a dental or medical practice, and authorized signatories of lenders and other partners. It is published to meet the requirements of the Illinois Biometric Information Privacy Act (740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code § 503.001), Washington's biometric identifier law (RCW 19.375), the Colorado Privacy Act as amended by HB 24-1130, and other applicable laws.
2. What we collect
When you choose to complete an identity check, you take a photo of your government-issued ID and three short selfies (facing the camera, turned left, turned right) on your own device. From those photos we create a scan of face geometry of your selfie and of the portrait on your ID, and we compare the two. That face-geometry scan is a biometric identifier. We do not collect fingerprints, voiceprints, or retina or iris scans.
From your ID we record only your name, birth year, the document type, and the expiry date. Your ID number, address, and full date of birth appear only in the ID image, which is deleted within 24 hours. We never copy them into our records.
2A. Who completes the check
The ID check is for adults. It must be completed by the person 18 or older who is reviewing, signing, or paying. For a patient under 18, that is the parent or legal guardian.
3. Why we collect it — the only purpose
We use face geometry for one purpose: to confirm that the person reviewing, signing, or paying is the person named on the ID, so that no one else can act in their name. For patients, this is part of the practice's payment and consent process. For lender signatories, it confirms the identity of the person who signed the application.
We do not use biometric data for marketing, advertising, profiling, training artificial-intelligence models, or any purpose other than the one above.
4. Consent before collection
Before the camera opens, we show you a notice that states what we collect, why, and how long we keep it, and we ask you to agree by checking a box. Checking the box is your electronic signature and written release. We record the date, time, version of the notice you saw, and the device you used. If you do not agree, we do not collect anything, and you can continue another way: patients confirm their identity with the text code already sent to their phone and a typed signature, and the practice may confirm in person or by phone; lender signatories may upload a copy of their ID instead.
If you skip this step, the practice will see that the ID check was not completed and may confirm your identity another way. Skipping never stops you from continuing.
5. Retention schedule and destruction
| Data | Kept for | How it is destroyed |
|---|---|---|
| Patients: ID photo, selfies, and the face-geometry comparison | No longer than 24 hours after the check finishes or is abandoned | An automated process runs every hour and permanently deletes the images from encrypted storage. The face-geometry comparison exists only while the check runs and is never stored. |
| Lender signatories: ID images, selfies, and the comparison | No longer than 24 hours after the check finishes or is abandoned | An automated process runs every hour and permanently deletes the images from encrypted storage. The face-geometry comparison exists only while the check runs and is never stored. |
| The result: verified or not, the match score, date, name and birth year as printed on the ID, ID type and expiry date | As part of the practice's or partner's compliance record, for as long as that record must be kept by law or contract. So patients are not asked again, we also keep a note that the phone number on file (stored only as a one-way code, never the number itself) belongs to a verified person, until the ID's expiry date. | The result is not a biometric identifier and cannot be used to recreate one. It is deleted with the record it belongs to. |
In every case we permanently destroy biometric identifiers and biometric information on or before the earliest of: (a) the date the purpose for collecting them is satisfied; (b) 24 months after your last interaction with FinVerified; or (c) 45 days after we determine they are no longer needed. In practice, we destroy them within the periods in the table above.
6. No sale, and limited disclosure
We do not sell, lease, trade, or otherwise profit from biometric data. We do not disclose it to anyone except:
- Amazon Web Services, which runs the face comparison and stores the images for us, as our service provider, under a written contract that prohibits any other use. We do not permit AWS to retain these images or use them to improve its services.
- Where a federal, state, or local law requires it, or in response to a valid warrant or subpoena.
The practice or partner you are working with receives only the result described in section 5 — never your images or face geometry.
7. How we protect it
Biometric data is encrypted in transit and at rest, stored separately from other records, and accessible only to automated systems and the minimum number of authorized personnel. We protect it with at least the same care we use for other confidential and sensitive information, including protected health information under HIPAA.
8. Security incidents
If we learn that biometric data may have been accessed without authorization, we will contain the incident, investigate, delete any affected data that is no longer needed, and notify affected individuals and regulators as the law requires and without unreasonable delay. Our incident-response procedure is part of our information-security program and is reviewed at least annually.
9. Your choices and rights
Giving biometric data is always optional. You may ask us to confirm whether we hold any biometric data about you, or to delete it, by writing to privacy@finverified.ai. Because patient images are destroyed within 24 hours, in most cases we will have nothing to delete. Residents of states with additional privacy rights may exercise them through the same address; see our Privacy Policy.
10. Changes
If we change this policy we will update the date and version above. We will not use biometric data collected under an earlier version for any new purpose without asking for your consent again.
11. Additional notices for certain states
Texas. We capture a biometric identifier only after we tell you and you consent. We do not sell, lease, or otherwise disclose it except as section 6 allows. We store and protect it with reasonable care, at least as carefully as our other confidential information. We destroy it within 24 hours, well inside the one-year limit in Texas Business & Commerce Code § 503.001.
Washington. We do not enroll your biometric identifier in a database for a commercial purpose. We compare it once to verify your identity, only after notice and your consent, and destroy it within 24 hours (RCW 19.375). We do not sell it or use it for any other purpose.
Colorado. We give this policy and our notice before collection, collect only with your consent, and delete biometric identifiers on the earliest of the dates in section 5. We never sell them. If you ask us to confirm, access, or delete your biometric data, we respond within 45 days (Colorado Privacy Act, C.R.S. 6-1-1314 and 6-1-1306).
12. Contact
FinVerified, Inc. · 11718 SE Federal Hwy, Ste 202, Hobe Sound, FL 33455 · privacy@finverified.ai