FINGERCHECK PRIVACY POLICY

Effective Date: November 6, 2020

Last Updated: November 6, 2020

CONTENTS

What This Privacy Policy Covers

Collection of Information

Use of Information

Sharing of Information

Links to Third Party Sites

Cookies and Other Tracking Technologies

Advertising and Analytics Services Provided by Others

Data Retention

Transfer of Information to the U.S. and Other Countries

Residents of the European Economic Area

Your California Privacy Rights

Your Choices

Contact Us

Fingercheck Biometric Data Privacy Policy

WHAT THIS PRIVACY POLICY COVERS

Fingercheck LLC (“Fingercheck”, “we” or “us”) provides an all-in-one HR platform. This Privacy Policy applies to information we collect from or about you, including when you use our website located at www.fingercheck.com, our mobile application and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us. This Privacy Policy does not apply to aggregated or de-identified information that cannot reasonably be used to identify you.

We provide our Services to our business clients “Customers” who use our Services to manage their HR and we permit access and use of our Services by individuals who are our Customers’ end users (each a “User” and, collectively “Users”).

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).  We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Fingercheck collects personal information from several different sources, including:

  • Directly from a website visitor, prospects, customers, applicants, or employee;
  • Directly or indirectly from website visitors, customers, vendors, service providers or other third parties; and
  • From your use, visit or activity on any of our websites or products.
  • Please review each of the sections below to learn more about how Fingercheck collects personal information, and what personal information is collected.
  • Website visitors:
    • How do we collect personal information? Fingercheck collects personal information about a website visitor when the visitor visits our website and when the visitor chooses to provide personal information. For example, we collect information when you visit our website and when you contact us via our website, provide your email, phone or other similar information, such as the information that you provide when you sign up to receive additional information.
    • What is collected? The personal information collected from a website visitor includes:
    • Name;
    • Company;
    • Job Title;
    • Address;
    • Phone Number; and
    • Email Address.
  • Children: We do not knowingly collect personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information to Fingercheck. If you have reason to believe that a child under the age of 13 has provided his/her personal information to Fingercheck, please contact us in accordance with Section 12 of this Notice, and we will do our best to delete that information from our databases.
  • Fingercheck Job Applicants and Employees:
    • How do we collect personal information? Fingercheck collects personal information about a job applicant when an application for employment with Fingercheck is completed. Additionally, Fingercheck collects information about individuals who create a profile on our website, regardless of whether or not an application is completed.

If hired by Fingercheck following an application, additional information is collected during the onboarding process and throughout the employment relationship. We may also collect information that you have voluntarily made public and/or shared on publicly visible accounts, such as social media platforms.

  • What is collected? The personal information collected from an applicant or employee of Fingercheck includes, but is not limited to:
  • Personal Identifiers (name, address, phone number, age, date of birth, social security number);
  • Professional or employment-related information (employment record, salary);
  • Education information; and
  • Personal/Professional contact information.
  • Customers’ Information (and the information of their Users):
    • How do we collect personal information? When using our products and services, we receive personal information from our Customers about their Users, which may include their current, prospective and former employees and contractors as well as their respective dependents and family members, as needed to provide benefits. The information may be collected through our SaaS platform or mobile application, by members of our support team who provide support to customers, by subprocessors engaged by Fingercheck to provide you with the Services, or when Fingercheck provides professional services to its Customers.

Our Customers are solely responsible for determining what personal information is collected regarding their Users. Fingercheck will collect and process your personal information only as instructed or permitted by our Customer or you.

For Users who use Fingercheck devices with a biometric or finger scanning device for timekeeping, please see the Biometric Data Privacy Policy section of this Privacy Policy.

  • What is collected? The personal information processed by Fingercheck on behalf of our Customers varies, includes but is not limited to information such as name, company name, phone number, address, email address, time and attendance and schedule information, Social Security Numbers, date of birth. Please contact your employer, the company that you provide subcontracting services to or the company with whom you applied to learn more about the information they collect for use with Fingercheck’s products and services or if you have any questions about your privacy rights.
  • Mobile Application
    • How do we collect personal information? Fingercheck collects personal information about a user of our mobile application when the user chooses to provide such information. We also collect information about you through the use of mobile analytics software.
    • What is collected? Our mobile application may record information concerning how often you use the application, the events that occur within the application, aggregated usage, performance data, the type of device used, and from where the application was downloaded.
    • Location Information: In accordance with your device permissions, we may also collect information about the precise location of your device. You may stop the collection of precise location information at any time (see “Your Choices” below for details).
  • Automatically Collected Information:

When you access or use the Services, we automatically collect information about you, including:

  • How do we collect personal information? Fingercheck collects information through the use of website tracking software, as well as from your use or activity on any of our websites, utilizing cookies and other tracking technologies.
  • What is collected? The website tracking software automatically captures technical information that is stored in our server’s log files. For example, when you visit our websites, we and our partners store and access non-sensitive information from your device, such as cookies or a unique device identifier, and process personal information such as your IP address, device manufacturer and model, the type of browser being used, the web pages visited, and the amount of time spent on our website.

To learn more about our use of cookies and other tracking technologies, please visit our “COOKIES AND OTHER TRACKING TECHNOLOGIES” section.

  • Social Media Features and Widgets:
    • How do we collect personal information? Our websites may include social media features, such as video links, “Like” buttons, and widgets such as “Share” buttons or interactive mini-programs, and may set a cookie to enable the feature to function. Social media features and widgets may be hosted by a third party or hosted directly on our websites. Your use and interactions with these features are at your discretion, and are governed by the privacy policy of the companies providing them.
    • What is collected? These features may collect your personal information such as your IP address and which website page you are visiting.
  • Information from other sources:

We may obtain information from other sources and combine that with the information described above. For example, we may collect information about you from third parties, including but not limited to, identity verification services, credit bureaus, mailing list providers and publicly available sources.

  • Information We Derive

We may derive information or draw inferences about you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

USE OF INFORMATION

Fingercheck uses your information for several purposes, including:

  • To provide the Services;
  • To improve our website, products and services, through testing, research, analysis and product development;
  • To deliver the products and services you request and customize your experience with us;
  • To communicate with you regarding our products and/or services;
  • To monitor and analyze trends, usage and activities in connection with the Services;
  • For security purposes, such as to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your information and to allow only the appropriate use of your information;
  • To monitor and analyze trends, usage and activities in connection with the Services;
  • To detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Fingercheck and others;
  • To personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
  • To fulfill the purpose(s) for which the information was collected/provided, including providing contractually-obligated products and/or services or to carry out any other purpose described to you at the time the information was collected; and
  • To comply with all applicable legal obligations.

For Users who use Fingercheck devices with a biometric or finger scanning device for timekeeping, please see the Biometric Data Privacy Policy section of this Privacy Policy.

SHARING OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • Third Parties (Vendors/Service Providers): We may engage with third parties (vendors and/or service providers) in order to deliver a product or service (or perform certain functions such as enhancing and/or delivering our product and service offerings) or complete a task that you requested. We have contracts with third-party providers (vendors and/or service providers) to perform certain functions on our behalf, and only at our direction.
  • Affiliates and Subsidiaries: We may share your information with our current and future parents, affiliates, subsidiaries and other companies under common control and ownership in order to deliver a product or service or complete a task that you requested.
  • Business transfer: We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Customers’ Information (and the Information of their Users): If you are a User, Fingercheck will disclose your information to your employer, the company you provide subcontractor services to or the company you have applied to and to other entities when instructed by your employer.
  • Additional Disclosures: Fingercheck might disclose your information:
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
  • If we believe your actions are inconsistent with our Terms of Use or policies,
  • To protect the rights, property and safety of Fingercheck or others (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions);
  • To protect against misuse or unauthorized use of our website;
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Our Services may contain links to other web sites, including but not limited to affiliated or co-branded web sites and sites of our subsidiary companies.  Other web sites which are not controlled by Fingercheck may reference or link to our Services.  We encourage you to review the privacy policies of every web site that you visit that our Services may link to or that may link to our Services.  We are not responsible for the privacy practices or content of such other web sites or mobile applications.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We (and our service providers) use different technologies to collect information, including cookies and web beacons.  Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, count visits and times visited, see what products and services are displayed and searched, and collect server log information other than the above.  Web beacons (such as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.

In particular, our Services use the following categories of cookies:

  • Strictly Necessary Cookies: We may use cookies required for system administration, to prevent fraudulent activity, or improve security. We are not required to obtain your consent to cookies that are strictly necessary.
  • Analytics and Performance Related Cookies: We may use cookies to assess the performance of our Services, including as part of our analytic practices to improve the content offered through the Services.
  • Functionality Related Cookies: We may use cookies to tell us, for example, whether you have visited the Services before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.
  • Targeting Related Cookies: We may use cookies to deliver content, including ads, relevant to your interests on our Services and third-party sites based on how you interact with our advertisements or content. We have set out further information about the use of cookies by our advertising and analytics service providers below.

Your use of our Services indicates your consent to such use of cookies. For further information about our use of cookies and your opt-out choices, see the “YOUR CHOICES” section below.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications.  These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information.  This information may be used by Fingercheck and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Services and other websites and better understand your online activity.  For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. For more information about third-party cookies and how to disable them, see “YOUR CALIFORNIA PRIVACY RIGHTS” section below.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interest. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

DATA RETENTION

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it or as required or permitted by applicable laws, (including the resolution of disputes) and in accordance with our customer contracts.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

Fingercheck is based in the United States and we process and store information in the U.S.  As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.  We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

  • Legal Basis for Processing

If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the Company products or services you have requested).
  • We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to the Services, and to provide, secure, and improve the Services.
  • Data Subject Requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred.  You may also have the right to object to, or request that we restrict, certain processing.  If you would like to exercise any of these rights, you may contact us as indicated below.

  • Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.  For contact details of your local Data Protection Authority, please see: //ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information.  If you are a California resident, this section applies to you,

In the preceding 12 months, we have collected the categories of personal information set forth in the table below. For examples of the precise data points we collect and the categories of sources of such collection, please see Collection of Information above. We collect personal information for the business and commercial purposes described in Use of Information above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Categories of Personal Information Categories of Sources of Personal Information Commercial / Business Purpose(s) for Collecting Personal Information Categories of Vendors to which Personal Information Is Disclosed for a Business Purpose Categories of Personal Information Disclosed to Vendors for a Business Purpose
Identifiers, such as Name (not alias), Address, Unique Personal Identifier, IP Address, Account Name, Social Security Number or other similar identifiers. Sources stated in Collection of Information, including:

  • You
  • Your computer or mobile device used to access our Services
  • Vendors/service providers, and/or third parties
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your personal information and to allow only the appropriate use of your personal information
  • To comply with all applicable legal obligations, including, but not limited to, the CCPA
  • Advertising or marketing
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Law enforcement, government agencies, and for legal compliance, when necessary
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
  • Identifiers
Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Sources stated in Collection of Information, including:

  • Vendors/service providers, and/or third parties
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • To improve our website, services and products, through testing, research, analysis and product development
  • Advertising or marketing
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Commercial Information
Personal information described in California Civil Code Section 1798.80(e), Name, Social Security number, physical characteristics or description, passport or state identification (including driver’s license) number, education and employment history, financial information, medical information or other similar identifiers Sources stated in Collection of Information, including:

  • You
  • Your computer or mobile device used to access our Services
  • Vendors/service providers, and/or third parties
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your personal information and to allow only the appropriate use of your personal information
  • To comply with all applicable legal obligations, including, but not limited to, the CCPA
  • Advertising or marketing
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Law enforcement, government agencies, and for legal compliance, when necessary
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
Personal information described in California Civil Code Section 1798.80(e)
Internet or Other Electronic Network Activity, information including (but not limited to) browsing history and search history Sources stated in Collection of Information, including:

  • Your computer or mobile device used to access our Services
Uses and Purposes stated in Use of Information, including:

  • To improve our website, services and products, through testing, research, analysis and product development
  • For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your personal information and to allow only the appropriate use of your personal information
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Law enforcement, government agencies, and for legal compliance, when necessary
Internet or Other Electronic Network Activity
Characteristics of Protected Classifications under California or federal law, such as age, date of birth, gender, military or veteran status, marital status, nationality, citizenship, pregnancy and related medical conditions, genetic information or other similar identifiers Sources stated in Collection of Information, including:

  • You
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • To comply with all applicable legal obligations, including, but not limited to, the CCPA
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Law enforcement, government agencies, and for legal compliance, when necessary
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
Characteristics of Protected Classifications under California or federal law
Biometric Data, Includes (but not limited to) imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings, from which an identifier template, such as a faceprint or a voiceprint can be extracted. Sources stated in Collection of Information, including:

  • You
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • To improve our website, services and products, through testing, research, analysis and product development
  •  For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your personal information and to allow only the appropriate use of your personal information
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Law enforcement, government agencies, and for legal compliance, when necessary
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
Biometric data
Geolocation data, information used to identify your physical location Sources stated in Collection of Information, including:

  • You
  • Your computer or mobile device used to access our Services
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your personal information and to allow only the appropriate use of your personal information
  • To comply with all applicable legal obligations, including, but not limited to, the CCPA
Entities stated in Sharing of Information, including:

  • Vendors/service providers
Geolocation Data
Audio, electronic, visual, thermal, olfactory or other similar information, chat communications, video conferencing, webcasts, customer support. Sources stated in Collection of Information, including:

  • You
  • Your computer or mobile device used to access our Services
  • Vendors/service providers, and/or third parties
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • To improve our website, services and products, through testing, research, analysis and product development
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Law enforcement, government agencies, and for legal compliance, when necessary
Audio, electronic, visual, thermal, olfactory or other similar information
Professional or employment related information, current or former job history, qualifications and skills, performance evaluations, payroll information, employment benefit information Sources stated in Collection of Information, including:

  • You
  • Your computer or mobile device used to access our Services
  • Vendors/service providers, and/or third parties
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your personal information and to allow only the appropriate use of your personal information
  • To comply with all applicable legal obligations, including, but not limited to, the CCPA
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
  • Law enforcement, government agencies, and for legal compliance, when necessary
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
Professional or employment related information
Inferences drawn from any of the information identified in the above categories used to create a profile about a consumer, consumer profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes Sources stated in Collection of Information, including:

  • You
Uses and Purposes stated in Use of Information, including:

  • To fulfill the purpose for which the information was collected/provided
  • To provide the Services or products contracted for with our Customers, at their direction
  • To provide you with information, products, or services you have requested from us or that may be of interest to you
  • To provide customer service and support
  • Legitimate purposes including, but not limited to, human resource business reasons such as personalized job opportunities, payroll processing, tax purposes, and the provision of employment benefits
  • To improve our website, services and products, through testing, research, analysis and product development
  • For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your personal information and to allow only the appropriate use of your personal information
Entities stated in Sharing of Information, including:

  • Vendors/service providers
  • Affiliates/Subsidiaries and related entities
Inferences drawn from any of the information identified in the above categories used to create a profile about a consumer

California law requires that we provide transparency about personal information we “sell,” which for purposes of the CCPA broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. Fingercheck does not sell your identifying information (such as your name, email address, phone number, or postal address); however, we do allow our advertising partners to use cookies and other technologies to collect personal information about you in order to show ads that are targeted to your interests. In order to opt out of the sale of your personal information, please see the “Consumer Requests” section below.

  • Consumer Requests: Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) access a copy of your personal information collected and retained by us, (3) request deletion of your personal information, (4) opt out of any “sales” of your personal information that may be occurring, and (5) not to be discriminated against for exercising these rights. You may make these requests by calling 1-800-610-9501 or emailing us at info@fingercheck.com.
  • Opt-Out: We offer an opt-out from the use of cookies and other tracking technologies in connection with our Services, which may in some cases constitute the sale of your personal information under the CCPA or other privacy laws. To opt-out of the use of cookies and similar technologies through our Services by clicking Do Not Sell My Personal Information. This will cause information to cease to be added to any cookies or other tracking technologies that have been set on our Services or block them entirely. Please note that you will need to opt out again if you visit our Services from a different device or browser of if you clear your cookies. Fingercheck does not have knowledge that it sells the personal information of minors under 16 years of age. We will not discriminate against you if you exercise your rights under the CCPA.
  • Verification: Before responding to your request, we must verify your identity to confirm that the personal information requested relates to you. If you maintain an account with us, we will verify your identity through existing authentication practices for your account (e.g. login and password). If you do not have a registered account, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g. email, phone number, or billing address).
  • Authorized Agents: If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.
  • Shine the Light: California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Fingercheck does not share your information with third parties for their direct marketing purposes.

YOUR CHOICES

  • Account Information. You may be able to update, correct or delete information about you by doing the following. Please follow the instructions below based on your relationship with Fingercheck.
    • Website Visitors: You may be able to update, correct or delete information about you at any time by emailing us at info@fingercheck.com. If you wish to delete or deactivate your account, please email us at info@fingercheck.com, but note that we may retain certain information as required by law or for legitimate business purposes.  We may also retain cached or archived copies of information about you for a certain period of time.
    • Our Customers’ Users: When processing personal information on behalf of a Customer, Fingercheck has no direct business relationship with the individuals whose personal information it processes (Users of our Customers). If you are a current or former employee or contractor or job applicant (a User) of one of Fingercheck’s Customers, please contact your employer/former employer/company you applied with directly to exercise your rights relating to your personal information.
  • Location Information. When you first launch the Services that collect location information, you will be asked to consent to the collection of this information.  If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.
  • Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.
  • Promotional Communications. You may opt out of receiving promotional emails from Fingercheck by following the instructions in those emails.   If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
  • Do-Not-Track Signal. Because the do-not-track signal does not often reflect the preference of our consumers, our Services do not respond to do-not-track signals. You may, however, elect not to receive promotional communications and/or have certain cookies placed on your browser, as discussed above.

    CONTACT US

    If you have any questions about this Privacy Policy or our privacy practices, please contact us at the following:

    FingerCheck LLC

    1000 Gates Avenue, 3rd Floor

    Brooklyn, NY 11221

    info@fingercheck.com

    1-800-610-9501

    FINGERCHECK BIOMETRIC DATA PRIVACY POLICY

    Fingercheck has instituted this Biometric Data Policy related to biometric data with respect to Fingercheck’s Customers’ and Customer’s Users’ use of Fingercheck products and services. Fingercheck’s Customers are responsible for developing and complying with their own biometric data retention and destruction policies as may be required under applicable law. This policy applies with respect to state or federal statutes that regulate biometrics, including but not limited to, the Illinois Biometric Information Privacy Act, to the extent that it is consistent with those applicable laws.

    • Biometric Data Defined: Under the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq. (“BIPA”) the term “biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996. The term “biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information based on items or procedures excluded under the definition of biometric identifiers. Biometric identifiers and biometric information are referred to herein collectively as “biometric data.” Time and attendance data or information obtained by the timekeeping devices, Fingercheck, its vendors and/or its licensors shall not be considered to be biometric identifiers or biometric information under BIPA or any other applicable state or federal laws.
    • Fingercheck Devices: The Fingercheck devices (“Devices”) do not store raw fingerprint images. Instead, the algorithm in Fingercheck Devices is based on the Minutiae matching method and the device stores a template in the form of an encrypted code. The template is non-reversible to the original image thus it cannot be used elsewhere.

    Fingercheck’s face recognition algorithm used in the Fingercheck Devices uses a combined Gabor-LDA (Linear Discriminant Analysis) based method which consist of various processes of comparing selected facial features from a given image with faces within a database. During face enrollment, the terminal will capture images of a person’s face with an infrared camera and generates a 3-dimensional template to be stored as a template for verification process. The encrypted template is non-reversible to the original image thus it cannot be used elsewhere.

    • Collection, Storage, Use, and Transmission of Biometric Data: Fingercheck Customers are responsible for compliance with applicable law governing any collection, storage, use, and/or transmission of biometric data they conduct or facilitate. Fingercheck and/or its vendors or licensors may collect, store, use and/or transmit biometric data during the course of providing products or services to Fingercheck Customers and Customer’s Users. With respect to biometric data collected, stored, used and/or transmitted by Fingercheck and/or its vendors or licensors, if any, to the extent required by law, Fingercheck’s Customers will obtain written consent from each individual User prior to the collection of such data.

    Fingercheck and/or its vendors or licensors may collect, store, use and/or transmit any biometric data solely for identity verification for purposes of recording time and attendance. Neither Fingercheck nor its vendors or licensors will sell, lease, trade or otherwise profit from any biometric data that it receives from Customers or Customer Users, if any.

    Fingercheck Customers agree that to the extent that such Customers use Fingercheck Devices they must:

    • Inform the User in writing that biometric data is being collected, stored, and used;
    • Indicate the specific purpose(s) for collecting biometric data and length of time for which it is being collected, stored, and used; and
    • Receive a written release from the User (or his or her legally authorized representative) authorizing the Customer, Fingercheck and/or Fingercheck’s authorized vendors or licensors to collect, use, store and transmit User biometric data, and authorizing the Customer to provide such data to Fingercheck and/or Fingercheck’s authorized vendors or licensors.
    • Disclosure: Fingercheck will not disclose, disseminate and/or transmit any Customer’s User biometric data to any person or entity other than the Customer and Fingercheck’s authorized vendors or licensors without/unless:
      • Having the Customer’s User’s written consent;
      • The disclosed information completes a financial transaction authorized by the Customer’s User;
      • Disclosure is required by state or federal law; or
      • Disclosure is required pursuant to a valid warrant or subpoena.
    • Retention Schedule: Fingercheck may retain any Customer’s User’s biometric data in Fingercheck’s possession, if any, generated by the Fingercheck Devices until the Customer notifies Fingercheck in writing that it has terminated the User or has otherwise discontinued using Fingercheck Devices, with respect to that User. When Fingercheck receives notification in writing that:
    • A Customer’s User’s access has been terminated;
    • The Customer otherwise has discontinued using Fingercheck Devices, with respect to that User; or
    • The Customer or the Customer’s User makes a written request to Fingercheck that such biometric data be destroyed; any User’s biometric data in Fingercheck’s possession will be destroyed within 30 days.

    Fingercheck shall make this policy available to the public by posting it on its publicly available website

    • Biometric Data Storage: Fingercheck and/or its vendors or licensors shall store, transmit and protect from disclosure any biometric data collected, and shall store, transmit, and protect from disclosure all biometric data using the reasonable standard of care in Fingercheck’s industry and in a manner that is the same as or more protective than the manner in which Fingercheck stores, transmits, and protects other personal and sensitive information.
    • Written User Release: Fingercheck’s Customers shall obtain a written consent from their Users in the from set forth below:

    “I acknowledge that I have received and reviewed the Company’s Biometric Data Privacy Policy. I understand that as described in that Policy, the Company, its vendors and/or licensors may collect, store and use biometric data in connection with its timekeeping and attendance system. I voluntarily consent to the collection, storage, and use of biometric data by the Company, its vendors and/or licensors for purposes of the Company’s timekeeping and attendance system and on the terms described in the Biometric Data Privacy Policy. I also voluntarily consent to the Company providing such biometric data to its vendors and/or licensors of the Company’s timekeeping and attendance system and as otherwise required by law. This consent also applies with respect to other state or federal statutes that regulate biometrics to the extent it is consistent with those applicable laws.”