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 Biometric Data Privacy Policy

1. Introduction. Scaramango Technologies Ltd (“Company,” “we,” or “us”), a private limited company registered in in England and Wales with company number 11844089 with an address First Floor, 129 High Street, Guildford, Surrey, United Kingdom, GU1 3AA has established the following Biometric Data Privacy Policy (the “Policy”) for Driver’s license, selfie, names, signatures, phone numbers and email ID’s. The data subjects/end users are “employees” & “third party contractor’s,” of Company’s biometric authentication of users system (the “Biometric System”). This Policy describes how Company facial images, face geometry, and other data that may be considered “biometric identifiers” or “biometric information” under applicable law (collectively, “Biometric Data”) that is collected, obtained, and/or processed by Company from drivers licenses, selfies, names, phone numbers and email IDs of data from employees and third party contractors in the United States through its operation of the Biometric System. Company reserves the right to amend this Policy at any time, without notice.

A copy of this Policy is available upon request and is publicly available at https://quikstep.co/privacy-policy/

2. Collection and Processing. Biometric systems are computer-based systems that scan an individual’s face, finger, hand, or other physical features for purposes of recognition and/or verification. These systems generate unique data points and create a unique mathematical representation, or algorithm, that is used to identify or verify an individual’s identity, such as when an individual uses their face or fingerprint as an authentication measure to gain access to a restricted area or an electronic device. Company’s Biometric System operates by scanning and analyzing a selfie and matching it against a copy of the license stored and the latest copy uploaded to verify their identities.

Any Biometric Data collected or processed by us will be used solely for purposes of “identity verification,” “fraud prevention and detection,” “security,” “access control,”, and to comply with our legal obligations under applicable law. Further, where permitted by applicable law, we may also use Biometric Data to improve our products, services, and related offerings. In the event we begin collecting or using Biometric Data in connection with the Biometric System for any additional purpose, we will update this Policy.

3. Disclosures. We may disclose Biometric Data with our third-party service providers, including cloud hosting providers (e.g., AWS, Google Cloud), AI verification providers (e.g., Anthropic Claude, Google Gemini), identity verification services (e.g., Jumio, Veriff), and our Authorized Clients, that assist with or otherwise facilitate our operation of the Biometric System, for purposes of verifying end user identity at the point of service, facilitating your use of the Biometric System, and providing the verification service you have been enrolled in. We may also disclose Biometric Data: (1) when required to do so by law; (2) when necessary to establish, exercise, or protect our rights; (3) to protect the vital interests of natural persons; (4) to investigate fraud or other criminal acts; or (5) in the context of merger, acquisition, or similar commercial transaction. Any Biometric Data disclosed by us will be solely for these purposes.

4.Retention and Destruction. Any Biometric Data collected, obtained, or otherwise processed by us will be permanently deleted by no later than: 1 year from collection, and permanent deletion of Biometric Data, e.g., “the date on which a customer instructs us to delete Biometric Data,” “the date on which a customer ends its contractual relationship with us,” “within one year after the date Biometric Data is first received from the Customer,” etc. ,whichever occurs first.

5.Contact Us. For more information, or if you have any questions about this Biometric Data Privacy Policy, you may contact us using the information below:

Mail: First Floor, 129 High Street, Guildford, Surrey, United Kingdom, GU1 3AA

Privacy Policy | Quikstep

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