Biometric Information Policy

1. Introduction

Cosnap LLC ("we," "us," or "our") utilizes facial recognition technology to provide automated photo-matching services. This Biometric Information Policy outlines our practices regarding the collection, use, safeguarding, storage, and permanent destruction of biometric identifiers and biometric information.

2. Definition of Biometric Data

In the context of our Services, "biometric identifiers" refer to facial embeddings, which are mathematical representations of facial geometry derived from photos you upload or that are uploaded to events where you are a participant. "Biometric information" refers to any information based on these identifiers used to identify an individual.

3. Purpose of Collection

We collect and use biometric data for the sole purpose of matching event photographs uploaded by photographers to registered users, allowing for the automated delivery of digital media to your account. We do not use this data for any other purpose, such as marketing, profiling, or training external machine learning models.

4. Informed Consent

We only collect biometric data from individuals who have provided express written consent. By enabling facial recognition features within the Cosnap app, you acknowledge that you have read this policy and authorize Cosnap LLC to collect and process your biometric identifiers. You may withdraw your consent at any time by disabling facial recognition in your account settings.

5. Data Storage and Security

Cosnap LLC employs industry-standard security measures to protect biometric data:

• Storage Location: All biometric data is stored on Amazon Web Services (AWS) servers located in the United States.

• Encryption: Biometric identifiers are encrypted at rest using AES-256 encryption and in transit using TLS/SSL protocols.

• Access Control: Access to biometric data is strictly limited to authorized personnel and automated system functions necessary for service delivery.

6. Disclosure to Third Parties

Cosnap LLC does not sell, lease, trade, or otherwise profit from your biometric identifiers. We share biometric data only with our service provider, AWS, which is contractually bound to process the data only as instructed by us and is prohibited from using it for its own purposes. We may disclose biometric data if required by a valid warrant or subpoena.

7. Retention and Destruction Schedule

We adhere to a strict retention and destruction schedule for biometric data:

• Retention Period: Biometric identifiers are retained only for as long as your account remains active to facilitate ongoing matching services.

• Deletion Upon Request: When you delete your account, your biometric identifiers are flagged for deletion and removed from active production systems within 30 days.

• Permanent Purge: Backup copies of biometric data in disaster recovery systems are permanently purged within 90 days of an account deletion.

• Inactivity: If an account remains inactive for three (3) consecutive years, Cosnap LLC will permanently destroy the associated biometric identifiers.

8. Contact Information

Cosnap LLC / info@cosnap.ai / https://cosnap.ai / Subject Line: Biometric Privacy Inquiry