Biometric Information Privacy Policy

Entropy Protocol Ltd (“us”, “we” or the “Company”) will not sell, rent, or trade your Biometric Information, and after verification you may request we delete your Biometric Information. Your Biometric Information will only be used by us to verify your identity or as required for the prevention of fraud. We use Onfido, a service provider in the United States, to process your Biometric Information, but we won't transfer your Biometric Information to other third parties, except when required by a subpoena, warrant, or other legal action.

This Biometric Information Privacy Policy describes how we or our service provider Onfido, collect and use certain Biometric Information, including facial geometry.

Please carefully review this Biometric Information Privacy Policy prior to consenting to our collection and use of your Biometric Information. Please note that once consent has been provided for the collection and processing of Biometric Information as part of your verification it may not be revoked where it is required to complete the transaction for which it was collected, or to complete the verification of your identity.

Additionally, by consenting to the collection and use of your Biometric Information you acknowledge that you have been provided with, and agree to be bound by, our Terms of Use and our Privacy Policy. You also agree to you have read and accept Onfido's Facial Scan Policy and Release.

“Biometric Information” is a form of personal information that comprises biometric characteristics which may be used to identify you, such as fingerprints, voiceprints, facial geometry scans, and iris or retina scans. As used in this policy, Biometric Information includes any “biometric identifiers” or “biometric information” as defined under applicable law.

When you sign up or request access to certain services on our Websites (such as, when you onboard into Blastoff or CommonFund) our service provider Onfido will collect a copy of your photograph (e.g., a selfie), and a copy of your governmental issued identification document, including the photograph on that document. Onfido will use these images to create a recording of your facial geometry, or faceprint, which they then use for purposes of identity verification (i.e., to confirm that the photograph on your governmental issued document matches that of your face, as seen on the selfie). We use this information to verify your identity, but also to prevent the creation of multiple accounts by the same person, and may use it for other fraud prevention activities.

We use your Biometric Information only as follows:

• To verify your identity prior to being allowed access to certain services on our Websites;
• To verify your country of citizenship and residence
• To prevent fraudulent uses of our services, or the creation of multiple accounts; and
• To comply with legal obligations or comply with a request from law enforcement or government entities where not prohibited by law.

We will only share your Biometric Information in the following circumstances:

• Where permitted by law, to enforce our Terms of Use, to comply with legal obligations, or to cooperate with law enforcement agencies concerning conduct or activity that we reasonably believe may violate laws, when required by a subpoena, warrant, or other ordered legal action, and to prevent harm, loss or injury to others or ourselves.
• With our service provider Onfido who performs identity verification functions on our behalf.

We will not sell, rent, or trade your Biometric Information.

We or Onfido may retain your Biometric Information for up to 20 days. However, if you are a resident of Illinois, U.S., in accordance with Illinois state law, we will retain Biometric Information only until the occurrence of the first of the following:(a) the initial purpose for collecting or obtaining such Biometric Information has been satisfied; or (b) twenty days following your last interaction with us or Onfido.

After successfully verifying your identity, you may request that we delete your Biometric Information (both or either of the selfie image and/or your Biometric Information) by submitting a request support@common.fund. Deletion of the selfie image and associated Biometric Information may take up to ten (10) days after we receive your request. However, we reserve the right to retain this information as needed to comply with our legal obligations, including warrants, subpoenas or other orders, or to help prevent fraud.

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), residents of California are entitled to additional rights and disclosures regarding their personal information, including Biometric Information. Please see our Notice to California Residents in our Privacy Policy for additional details regarding these disclosures and how to exercise your rights.

Yes, you may refuse to provide us or Onfido your Biometric Information. However, if you do so, we will be unable to verify your identity, and as such, we may need to withhold certain services from you. You acknowledge and agree that this is not a discriminatory practice, but a requirement to keep our Websites and other users safe, and to allow us to comply with applicable laws.

We have adopted technical, administrative, and physical security controls intended to protect your information from loss, misuse, unauthorized access and alteration (e.g., encryption, firewalls and endpoint detection software), but you acknowledge that that no data transmission or storage can be guaranteed to be 100% secure.

This Biometric Information Privacy Policy may be periodically updated. Please review it from time to time to make sure you understand how your Biometric Information might be used.