Biometric Information Policy

We at Zengo Ltd. (“Zengo”, “Company”, “we”, “us”, “our”) respect your privacy. This Biometric Information Policy (“Policy”) explains how we collect, use and retain your Biometric Information (as defined in this Policy) when you use the Zengo mobile application (“App”), in accordance with the Illinois Biometric Information Privacy Act (BIPA) of 2008, 740 ILCS 14. (740 ILCS 14/1) (“BIPA“).

We may change this Policy from time to time, to comply with the law or for any reason. We will update you on any such changes through the App or via email.

You may contact us at any time by emailing us at [email protected].

What is Biometric Information?

Biometric Information is any information, however generated, stored or shared, that is based on an individual’s biometric identifier, and used to identify that individual.

A “biometric identifier” is any of the following: a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.

When you use our App, Zengo allows you to unlock your wallet using facial recognition technology. The information derived from the scan of your face geometry, which is a biometric identifier, is considered Biometric Information protected under BIPA.

Collection and Use of Biometric Information

Your Biometric Information is collected when you choose to use facial recognition as your preferred method of identification for accessing your wallet. Please note that this is not mandatory; you may choose to skip biometric identification and use any alternative method of identification available on the App.

Prior to using your Biometric Information for the first time, we will require you to consent to this Policy.

We, and our service providers assisting us in facilitating your access to your wallet, will use your Biometric Information solely for the purpose of identifying you prior to providing you with access to your wallet, in order to maintain the safety and security of your wallet and prevent unauthorized access to it.

Storage and Retention of Biometric Information

Your Biometric Information will be stored on our servers. We implement technical and organizational measures to reduce risks of damage, loss of information and unauthorized access or use of the Biometric Information.

We will retain your Biometric Information as long as your account is active and 7 years thereafter, to allow you to recover your wallet whenever initiated by you.

Disclosure of Biometric Data

Except for our service providers who assist us in facilitating your access to your wallet, we will not share or disclose your Biometric Information with any third party, unless:

you consent to the disclosure;
the disclosure completes a financial transaction requested or authorized by you;
the disclosure is required by State or federal law or municipal ordinance; or
the disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Last update: May 2024.

Table of Contents

Biometric Information Policy

Table of Contents

What is Biometric Information?

Collection and Use of Biometric Information

Storage and Retention of Biometric Information

Disclosure of Biometric Data

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