ONUS ID Privacy Policy

Biometric Notice

This is the “Biometric Notice” referred to on the ONUS ID screen. It is a plain-language summary of how ONUS ID handles your face and ID, and it is part of this Privacy Policy. Together with Sections 5 and 8, it is our publicly available written policy on the retention and destruction of biometric identifiers and biometric information, and our facial recognition policy for locations where one must be posted. Sections 4, 5 and 8 contain the full details and control if the two differ.

Nothing is captured until you tap VERIFY AGE (at Washington locations, until you also tap I consent to sharing). When you do, the ONUS ID device takes a live image of your face and sends it to our identity verification provider, which:

• checks that a real, present person is in front of the camera (a “liveness” check);
• checks whether your face matches a customer who has already enrolled in ONUS ID; if it does, ONUS ID confirms your age from the date of birth recorded at your enrollment and shows the store a result;
• if you are not enrolled, estimates your age from your facial features to assist the store’s own age check. An estimate is an approximation; the store decides whether to complete the sale and may ask to see your ID.

If you are not enrolled and the store offers enrollment, ONUS ID may then invite you to scan your government-issued ID to enroll, so participating stores can recognize you on future visits. Enrollment is optional and starts only when you tap Scan my ID beneath a statement in which you consent to the collection, storage and use of your ID information and the keeping of your faceprint, and agree to the Terms of Service. You must be at least 18 and the ID must be yours. Enrollment can also start on your own phone from a link a staff member sends you by text, with your agreement, or from a QR code; the same consent statement is shown there and you tap CONTINUE.

You can always choose Hand My ID to Cashier instead. The store will check your ID the traditional way, at no disadvantage to you.

• Your facial image (a photograph) and a faceprint — a mathematical map of your facial features created from that image. The faceprint is a biometric identifier. For age estimation, measurements of your facial features are also derived from your image.
• If you enroll: an image of your government-issued ID and the information printed on or encoded in it (such as name, date of birth, ID number, expiration date and address), and a faceprint that is kept so you can be recognized on future visits.

ONUS ID does not collect fingerprints, voiceprints, or iris or retina scans, and does not ask for your Social Security number or payment details.

Only to verify your age and identity for purchases of age-restricted products — today and, if you enroll, on future visits — and to detect fraud such as fake, borrowed or stolen IDs or a photo held up to the camera. Not for surveillance, advertising, marketing or profiling.

• ONUS keeps your name, date of birth and age (if you enroll), the phone number you give us, a reference number for your record with our provider, and a record of each verification (store, outcome, date and time) and of your consent. ONUS does not store your facial image, faceprint, ID image or ID number in its own systems.
• Our identity verification provider performs the checks described above for ONUS and holds your facial image, faceprint, ID image and ID information. It performs the verification for us under a written agreement, and as an independent business is also responsible for using verification data to detect and prevent fraud and to secure its service, and for its own legal compliance and business operations. Its published policy is not to sell biometric data and to use it to train or improve its technology only with the individual’s consent — and ONUS ID does not ask you for that consent, and ONUS has not given it. We will identify the provider and give you links to its notices on request.
• The store where you are verified sees your name (if enrolled) and the result — not your images or faceprint.

Where the law of the state where you were verified requires a shorter period, the shorter period applies. Deleted information may remain in secure backups for up to 35 days.

• We do not sell, lease, trade or otherwise profit from your biometric information.
• We do not disclose it except to our identity verification provider as described here, with your consent, to complete a transaction you requested, or as required by law or a valid warrant or subpoena.
• We do not use it for advertising or marketing, to build a profile of you, or for any purpose unrelated to the verification.
• We protect it using the reasonable standard of care in our industry and in a manner that is the same as or more protective than the manner in which we protect other confidential and sensitive information.

• Decline. Tap Hand My ID to Cashier. Nothing is captured.
• Withdraw consent or end your enrollment at any time. Contact us (Section 15). We delete your profile and instruct our provider to destroy your faceprint and images within 30 days.
• Access, correct or delete your information, or appeal a decision, as described in Section 9. Residents of Illinois, Texas, Colorado, Washington, Connecticut, Maryland, California and other states have additional rights described in Section 10. Washington residents: see our Consumer Health Data Privacy Policy in Section 16.
• Questions about facial recognition in Connecticut may also be directed to the Connecticut Office of the Attorney General, portal.ct.gov/ag, (860) 808-5318.

Questions or requests: ONUS Technologies Inc (d/b/a ONUS Merchant Solutions), Attn: Privacy, 207 Kiley Dr, Salisbury, MD 21801 · 844-551-6687 · hello@onusid.com. Terms of Service: onusid.com/terms-of-service.html.

1. Introduction

ONUS ID is an age and identity verification service operated by ONUS Technologies Inc, doing business as ONUS Merchant Solutions (“ONUS,” “we,” “us” or “our”). Businesses that sell age-restricted products, such as liquor stores and other retailers, use ONUS ID to help confirm that a customer meets the legal age requirement for a purchase and that the identification presented is valid.

This Privacy Policy explains what personal information we collect through ONUS ID, how we use and protect it, when we share it, how long we keep it, and the choices and rights you have. It applies to:

• Individuals being verified — people who enroll in ONUS ID or whose age is checked using ONUS ID at a participating business. When this Policy says “you,” it generally means you in this role.
• Business users — the businesses that use ONUS ID (“Business Customers”) and the employees they authorize to use it.
• Website visitors — anyone who visits the ONUS ID website or contacts us.

Who is responsible for your information. ONUS is the business responsible (the “controller”) for the personal information collected through ONUS ID, including your enrollment, your verification records and your consent records, and ONUS obtains your consent through the ONUS ID consent screen. Each Business Customer is separately responsible for its own records — for example, its sales records, and the name and phone number its staff collect from you at the counter — and for any notice it is required to post or give you at its location. Our identity verification provider, described in Section 5, is responsible for the specific processing described there. Please read this Policy together with any notice provided by the business where you were verified.

2. Information We Collect

We aim to collect only the information reasonably necessary to perform a verification, operate and secure the service, and meet our legal obligations. What we collect depends on how you interact with ONUS ID.

When you tap VERIFY AGE. A live image of your face is captured and sent to our identity verification provider, which performs a liveness check, checks whether your face matches an enrolled ONUS ID customer and, if it does not, estimates your age from the image. A facial template (“faceprint”) and, for age estimation, measurements of facial features are derived from the image for that check. ONUS keeps a record of the check — the business and location, the outcome, and the date and time — but not the image.

When you enroll. If you are not enrolled and the business offers enrollment, you may choose to scan your government-issued ID (such as a driver’s license, state ID card or passport). Our identity verification provider reads the information printed on or encoded in your ID — which may include your name, date of birth, ID number, document type, issuing authority, issue and expiration dates, address, sex, physical descriptors and the ID photo — checks that the document is genuine, compares your live image to the ID photo, and keeps your facial template so that you can be recognized on future visits. Section 5 describes this in detail, including what the provider keeps.

What ONUS keeps about you. In our own systems, ONUS keeps your name, date of birth and age; any phone number you give us; a reference number for your record with our identity verification provider; and records of each enrollment and verification, such as the business and location, the outcome, the reason for any failure, and the date and time. ONUS does not store images of your face or your ID, your facial template, your ID number or your address in its own systems.

Fraud detection. During a verification, a liveness check helps detect fraud, such as a replayed image or a photo, screen or mask held to the camera. At enrollment, our identity verification provider may also check the details on your ID against the records of the issuing authority (for example, a state motor-vehicle agency) to confirm that the ID is valid; the result of that check is a match or no-match, and ONUS does not receive or keep the agency’s records. ONUS ID does not use watchlist-screening, precise-geolocation or fraud-sharing-network features.

Text messages. If you tap “Send by Text” on the ONUS ID screen and enter your mobile number, we send you one text message with links to this Policy, the Biometric Notice and the Terms of Service. We record the store, the time the message was sent and a one-way hashed form of your number, and delete the number itself after sending, unless you reply STOP. If a staff member starts your enrollment by text, we also collect your name and phone number at the counter and record that staff confirmed you agreed to receive the text, and whether the enrollment link was used. Text messages are sent by our identity verification provider on our behalf. ONUS does not sell or share mobile phone numbers or text-message opt-in information with third parties for their marketing purposes; our identity verification provider receives your number in order to send the text. If you opt out of text messages, we keep your phone number on an opt-out list so that we honor your choice.

Consent records. When you tap VERIFY AGE on the ONUS ID screen (and, at Washington locations, “I consent to sharing”), we record which consent wording you saw, when you tapped, and (if you enroll, when you tap “Scan my ID” or CONTINUE) which version of the Terms of Service you accepted, the store and device involved, and technical details such as the IP address, app version and device type. We keep this as evidence of your consent and electronic signature.

Device, technical and usage information. Technical information about the device used to enroll or verify (such as device type, operating system and app version), IP address, and logs of how the applications are used, which we use for security, troubleshooting and fraud prevention. Similar technical information is collected when you visit our website (Section 12).

Information from Business Customers and their staff. Business contact details, account and billing information, the names, work contact information, roles and login credentials of authorized users, service settings, and records of how the service is used.

Information you provide to us directly. For example, when you contact us with a question, request a demo or submit a privacy request.

What we do not collect. ONUS ID does not request your Social Security number, financial account or payment card numbers, or medical or health-care information (other than biometric data, which Washington law treats as consumer health data — see Section 16), and we do not collect fingerprints, voiceprints, or iris or retina scans.

3. How We Use Your Information

We use personal information for the following purposes:

• Age and identity verification. To determine whether you meet an applicable age requirement — by recognizing you if you are enrolled, or by estimating your age from a facial image if you are not — and, at enrollment, to check that your ID appears authentic and unexpired and belongs to the person presenting it.
• Text messages. To send you, at your request, one text message with links to our notices or an enrollment link, through our identity verification provider; to track whether an enrollment link was used; and to honor text-message opt-outs.
• Fraud and misuse prevention. To detect and prevent the use of fake, altered, borrowed or stolen IDs and other attempts to misuse the service.
• Security. To protect ONUS ID, our systems, our Business Customers’ accounts and the people we verify against unauthorized access and other threats.
• Operating and supporting the service. To provide the service to Business Customers, deliver verification results, manage accounts, provide customer support and bill for the service.
• Troubleshooting and reliability. To monitor performance and diagnose and fix problems. ONUS uses aggregated or de-identified information to measure and improve the reliability of ONUS ID; ONUS does not use your facial images, facial template or ID information to train or develop technology, and our identity verification provider’s published policy permits it to use biometric data to train or improve its technology only with the individual’s consent, which ONUS ID does not ask you for and ONUS has not given (Section 5); as an independent business, the provider may use other verification data, such as information read from your ID, to operate and improve its services.
• Record-keeping. To keep records of verifications and consents where reasonably necessary for the Business Customer’s or our own legal, regulatory and compliance obligations, to resolve disputes and to enforce our agreements.
• Legal compliance. To comply with applicable laws and lawful requests, and to protect the rights, safety and property of ONUS, our Business Customers, you and others.

ONUS does not use identity, verification or biometric information for advertising or marketing, to build marketing profiles, or to make decisions about you that are unrelated to the verification. Being verified with ONUS ID will not result in marketing from ONUS.

4. How ONUS ID Age Verification Works

At a participating business, ONUS ID is used from a single screen on the store’s ONUS ID device. Nothing is captured until you tap VERIFY AGE; you may instead tap Hand My ID to Cashier for a traditional ID check.

One tap, then three possible steps. The screen tells you what will be collected, why, who will hold it, how long it is kept and how to withdraw, and links to this Policy (which opens at the Biometric Notice) and the Terms of Service; see Section 5. When you tap VERIFY AGE, a live image of your face is captured and sent to our identity verification provider, and a “liveness” check helps confirm the image comes from a real, present person rather than a photo, screen or mask. Then:

• If you are already enrolled, the provider recognizes you by comparing your face to the facial templates of enrolled customers, ONUS ID uses the date of birth from your enrollment to determine whether you meet the age rule for the product being purchased, and staff see the result. You are not normally asked to present your ID again unless recognition is unsuccessful, unless staff choose to check it, or unless the law of the state where you are shopping requires the business to inspect or scan your ID at each purchase.
• If you are not enrolled, the provider estimates your age from the image, and that estimate assists the business’s own age check. An estimated age is an approximation, not a determination based on your ID; the business decides whether to complete the sale and may ask to see your government-issued ID. The image, and the facial template and measurements derived from it for this check, are deleted within 30 days (except any copy our provider keeps for its own fraud-prevention or security purposes, as described in Section 5) and are not used to create an enrollment unless you choose to enroll.
• Enrolling (optional, one time). If you are not enrolled and the business offers enrollment, ONUS ID may invite you to scan your government-issued ID; nothing further is captured unless you tap Scan my ID. Our identity verification provider reads the information on your ID, checks that the document is genuine and unexpired, confirms that the face presented matches the photo on the ID, and keeps your facial template. ONUS then creates your ONUS ID profile. Enrollment can also start by an enrollment link that a staff member sends you by text, with your agreement, or by a QR code. You enroll only once; your enrollment can be used at any participating business, and it lasts until you end it or until 24 months pass without a verification.

The business makes the final decision. In every case, ONUS ID supports — but does not replace — the business’s own age-verification process. Verification results and age estimates are generated automatically by software and can be wrong; the business and its staff make the final decision, and the business is expected to complete a sale only if it is satisfied that you meet the age requirement. If a result or estimate seems wrong, you can ask the business to review your ID. You may also decline to use ONUS ID; the business may verify your age another way, such as by checking your ID manually.

Accessibility. If you cannot use, or would prefer not to use, a camera-based check — for any reason, including a disability — you may ask the business to check your ID manually instead, at no disadvantage. We are working to make the ONUS ID screens accessible (including screen-reader support and adequate contrast) and welcome feedback at hello@onusid.com.

5. Facial, Biometric and Sensitive Information

Some of the information ONUS ID handles is especially sensitive, including government ID numbers, ID images, and facial images and the information derived from them. In this Policy, “Facial Processing” means every use of your face by ONUS ID: capturing a live image when you tap VERIFY AGE; comparing it to enrolled customers’ facial templates; estimating age from it if you are not recognized; and, at enrollment, comparing it to your ID photo and creating and storing a facial template. This section applies to all Facial Processing.

Photographs versus biometric identifiers. An image of your face or of your ID photo is a photograph. Facial Processing generates a mathematical representation of facial features (sometimes called a facial template or “faceprint”), which state laws treat as a “biometric identifier,” and age estimation derives measurements of facial features from your image. This Policy applies the commitments below to facial templates, to those measurements, and to the facial images used to create or compare them (together, “biometric information”).

Why we process it. Facial Processing is used to (a) create your ONUS ID profile and recognize you on return visits, so your age can be confirmed without re-scanning your ID; (b) confirm at enrollment that the ID presented belongs to the person enrolling; (c) for walk-in customers, check whether you are already enrolled and, if not, estimate your age to assist the business’s check; and (d) detect fraud, such as a borrowed or stolen ID, a photograph held up to the camera, or a digitally altered image. ONUS does not use biometric information to identify you in any other context, for surveillance, for advertising or marketing, or to build a profile of you.

Our identity verification provider. ONUS uses a specialist identity verification provider to perform Facial Processing and to read and authenticate IDs. The provider holds the images of your ID and face, the information read from your ID (subject to the state limits described in Section 8), your facial template, and the liveness and face-match scores; ONUS holds none of these — only a reference number that points to your record with the provider. Under our agreement with the provider:

• The provider performs the verification for ONUS, as our service provider, and must protect your information.
• The provider is also an independent business. In that role it is responsible for using verification data to detect and prevent fraud and to secure its service, and for its own legal compliance, records and business operations.
• Our provider’s published policy permits it to use biometric data to train or improve its technology only with the individual’s consent, and states that it does not sell biometric data. ONUS ID does not ask you for, and ONUS has not given the provider, that consent. If ONUS ever offers such a choice, it will be a separate, optional choice on the consent screen and will never be required to enroll or be verified.
• The provider may create and use aggregated, de-identified or statistical information that does not identify you, for its own business purposes, including to operate and improve its services.
• As an independent business, the provider may also use non-biometric verification data, such as information read from your ID, to operate and improve its services. ONUS does not authorize the provider or any other service provider to use your personal information to market to you, and ONUS will act on any report that this has occurred.
• According to its published policies, the provider uses its own affiliates and service providers (for example, cloud hosting) to deliver the verification under contracts that require them to protect your information, does not sell biometric information, and discloses it to its vendors only as needed to perform the service.
• The provider’s own privacy notice and biometric data policy govern its processing as an independent business. We will identify the provider and give you links to those notices on request.

Notice and consent. Before any image of your face is captured, the ONUS ID screen tells you in writing that your face is scanned and your faceprint (a biometric identifier) is kept by ONUS and our identity verification provider, and the specific purpose (verifying your age now and on future visits); it links to this Policy, opening at the Biometric Notice, which states what is collected, how long your faceprint is kept (30 days if you do not enroll; 24 months after your last verification if you do), the fraud-prevention purpose, the provider’s own uses, and how to withdraw; and it links to the Terms of Service. Your consent to the collection, storage and use of your ID information is given on the “Scan my ID” screen, before your ID is scanned. Facial Processing proceeds only after you tap VERIFY AGE beneath the statement “By tapping VERIFY AGE, I sign this consent electronically.” — which we record as your electronic signature and written release, together with the consent wording shown, the time, the store and device, and technical details. Your ID is scanned for enrollment only if you then tap “Scan my ID” beneath a further statement in which you consent to the collection, storage and use of your ID information and the keeping of your faceprint for enrollment. If you enroll on your own phone through a link or QR code, the same consent statement is shown and you tap CONTINUE. Approaching the counter or the device is not consent. If you do not wish to complete Facial Processing, tap “Hand My ID to Cashier,” and the business will verify your age by other means, such as a manual review of your ID.

No sale. ONUS does not sell, lease, trade or otherwise profit from biometric information.

Limited disclosure. ONUS discloses biometric information only (a) to our identity verification provider, as described in this Policy; (b) with your consent; (c) to complete a financial transaction you requested or authorized; or (d) as required by law or by a valid warrant or subpoena. The business where you were verified receives the verification result, not your images or facial template.

Retention schedule. Our retention schedule for biometric information is:

• Facial template — permanently destroyed at the earliest of: when you end your enrollment; when 24 months pass without a verification; or when we determine it is no longer needed for the purpose for which it was collected, which we review at least once a year.
• Images of your face and ID, and liveness and face-match scores, from enrollment — retained by the provider only as long as needed to complete and secure your enrollment, and deleted no later than your facial template and normally much sooner.
• Live images, and the templates, measurements and scores derived from them, from checks that do not result in enrollment (a recognized customer’s visit or a walk-in age estimate) — used to complete the check and deleted within 30 days, except any copy the provider holds for its own fraud-prevention or security purposes, which is subject to the limit stated below.

ONUS applies this schedule by instructing its identity verification provider, through the provider’s deletion interface, to delete the biometric information it holds for ONUS ID — your record when your enrollment ends, and each non-enrollment session within 30 days. Any copy the provider holds for its own fraud-prevention or security purposes is subject to its own published retention limits, which are no longer than three years. Where a shorter period is required by the law of the state where you were verified, the shorter period applies. Section 8 describes our broader retention approach.

Security. We protect biometric information using the reasonable standard of care in our industry and in a manner that is the same as or more protective than the manner in which we store, transmit and protect other confidential and sensitive information, as described in Section 6.

6. How We Protect Information

We maintain technical and organizational safeguards designed to protect personal information against unauthorized access, use, alteration and disclosure, taking into account the sensitivity of the information. These safeguards include:

• Encryption of personal information in ONUS’s systems, in transit and at rest; our identity verification provider has represented to us that it encrypts ID and facial information in transit and at rest.
• Access controls and authentication that limit access to the personnel and systems that need the information to perform the service, using role-based permissions.
• Monitoring and logging to detect and respond to unauthorized access or unusual activity.
• Security procedures, including review of our identity verification provider’s independent security assessments, and an incident-response protocol that includes notifying affected individuals, Business Customers and authorities where required by law.
• Organizational safeguards, including confidentiality obligations and privacy and security training for our personnel, and written contracts requiring service providers to protect information appropriately.

No method of transmitting or storing information is completely secure, and we cannot guarantee absolute security. If you believe your information has been compromised, please contact us (Section 15).

7. How We Share Information

ONUS does not sell personal information — including identity, verification and biometric information — and does not share it for targeted or cross-context behavioral advertising. We share personal information only in the following circumstances.

Businesses using ONUS ID. We provide the verification result to the Business Customer where you were verified so that it can decide whether to complete the sale and maintain its own compliance records; if the Business Customer has connected ONUS ID to its point-of-sale or other system, only the verification result is passed to that system. Because staff at the business can see your name (if you are enrolled) and verification outcome, and may collect your name and phone number if they start your enrollment by text, the business also holds that information. Our agreements require Business Customers to use this information only for age and identity verification, fraud prevention and their legal compliance, and not for marketing or other unrelated purposes.

Our identity verification provider. As described in Section 5, our identity verification provider performs ID authentication, facial comparison, liveness checks and age estimation; holds ID and facial images and facial templates; and sends text messages on our behalf. It processes verification data for ONUS as our service provider and, for fraud prevention, security, its own compliance and business operations, as an independent business under its own privacy notice and biometric data policy. Its published policy permits it to use biometric data to train or improve its technology only with the individual’s consent, which ONUS ID does not ask you for and ONUS has not given (Section 5).

Other service providers. We rely on other third-party service providers to operate portions of ONUS ID on our behalf, including cloud hosting and infrastructure providers, security providers, and providers of customer support, communications and billing tools. These providers act on our instructions under written agreements that require them to protect the information, use it only to provide services to us, and delete or return it when it is no longer needed. We disclose the categories of providers we use, and will identify a specific provider on request.

Legal, safety and security purposes. We may disclose information when we believe in good faith that doing so is required by law, regulation, court order, subpoena, warrant or other lawful request, or is reasonably necessary to protect the rights, property or safety of ONUS, our Business Customers, you or others; to investigate, prevent or address fraud, security incidents or illegal activity; or to enforce our agreements. Biometric information is disclosed only as described in Section 5.

Corporate transactions. If ONUS is involved in a merger, acquisition, financing, reorganization or sale of some or all of its business or assets, personal information may be transferred as part of that transaction, subject to protections at least equivalent to this Policy and to any notice required by law. Biometric information would be transferred only as permitted by law, and we would provide notice and obtain new consent where the law requires it.

With your direction or consent. We may share information in other ways if you ask us to or consent.

Aggregated and de-identified information. We may create and use aggregated or de-identified information that cannot reasonably be linked to you — for example, the number of verifications performed at a location — and we do not attempt to re-identify it.

8. Data Retention and Deletion

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy — performing and recording verifications, providing the service, preventing fraud, security, resolving disputes, enforcing our agreements and meeting legal obligations — and then delete or de-identify it.

• Biometric information — see the retention schedule in Section 5.
• Your ONUS ID profile (name, date of birth, age, phone number, provider reference number) — kept while you are enrolled. Your enrollment ends when you ask us to end it or when 24 months pass without a verification, and your profile is then deleted, except as noted below.
• Phone numbers entered only to receive links by text — deleted after the message is sent, unless you reply STOP (kept on the opt-out list).
• Enrollment invitations that are never completed — deleted 90 days after the enrollment link expires, except that a phone number on our text-message opt-out list is kept so that we honor your choice.
• Consent records and verification records (the business and location, the outcome and the date and time) — kept for as long as reasonably necessary to show that consent was given and that a verification occurred, including for the Business Customer’s and our own record-keeping obligations, and subject to any shorter limits in the law of the state where you were verified. These records do not contain your ID number, address or images.
• Business Customer account and billing records — kept for the duration of the relationship and as long afterward as needed for legal, tax and accounting purposes.
• Device, technical and log information — kept for a period reasonably necessary for security, troubleshooting and fraud prevention.

Deleted information is removed from our active systems, and we instruct our service providers to delete it from theirs; information our identity verification provider holds as an independent business is subject to the limits described in Section 5. Deleted information may remain in secure backups for up to 35 days before being overwritten and is not used during that time. We may keep limited information where the law requires it or to resolve a dispute or enforce our agreements — for example, a record that a verification occurred and its outcome.

What is read and kept from your ID varies by state. Some states restrict what may be recorded or retained when an ID is scanned to verify age. ONUS does not keep your ID number, address or ID images in its own systems; for enrolled customers it keeps only the name, date of birth and age described in Section 2. Where the law of the state in which you were verified restricts what may be retained from a scanned ID, ONUS limits what its identity verification provider retains accordingly.

9. Your Privacy Rights

Depending on where you live, you may have the right to:

• Access — confirm whether we process your personal information and obtain a copy of it, along with information about how it is used and shared.
• Correct — request correction of inaccurate personal information.
• Delete — request deletion of your personal information, subject to exceptions (for example, where we must retain a record that a verification occurred).
• End your enrollment / withdraw consent — end your ONUS ID enrollment and withdraw your consent to Facial Processing at any time. We will delete your profile and instruct our identity verification provider to destroy your facial template and images promptly, and in any event within 30 days. Withdrawal does not affect processing that already occurred, and a record that a verification occurred, its outcome and your consent record are retained as described in Section 8.
• Portability — receive the information you provided to us in a portable format.
• Opt out — of the sale or sharing of personal information, targeted advertising and certain profiling. ONUS does not engage in these activities; if that ever changes, we will update this Policy and provide the required choices.
• Limit the use of sensitive information — ONUS uses sensitive information only to perform the service you requested, to prevent fraud and secure the service, and for the record-keeping and legal-compliance purposes in Section 3. You may nevertheless ask us to limit the use of your sensitive information; we will honor the request and forward it to our identity verification provider for the processing it performs as an independent business.
• Stop text messages — reply STOP to any message, or ask us or the business to add your phone number to our text-message opt-out list.
• Appeal — if we deny a request, ask us to reconsider. We will tell you the result and, where applicable, how to contact your state’s attorney general or privacy regulator.

We will not discriminate against you for exercising your rights. A business may still decline a sale if your age cannot be verified.

How to submit a request. Email hello@onusid.com, call 844-551-6687, or write to the address in Section 15. We will verify your identity before acting on a request, asking only for information reasonably necessary to do so. Where the law allows, you may use an authorized agent; we may require proof of the agent’s authority and may still verify your identity directly. We will respond within 45 days; where the law allows, we may extend this once by a further 45 days, and we will tell you if we do.

Requests involving a Business Customer or our provider. ONUS handles requests about your ONUS ID enrollment, verification and consent records. For the business’s own records, you may also contact the business where you were verified. Where our identity verification provider holds information as an independent business, we will forward your request to it and tell you that we have done so. Business Customer employees may also contact their employer, which manages their account.

10. U.S. State Privacy Rights

This section provides additional disclosures for residents of states with specific privacy or biometric laws. Not every right or requirement applies to every person or activity. Where this section conflicts with the rest of this Policy, it controls for residents of the relevant state.

Illinois. This Policy — in particular Sections 5 and 8 — serves as our publicly available written policy establishing our retention schedule and guidelines for permanently destroying biometric identifiers and biometric information. We collect biometric identifiers and biometric information only after informing you in writing that they are being collected and stored, the specific purpose, and the length of time for which they will be collected, stored and used, and after receiving your written release, which you give by electronic signature when you tap VERIFY AGE beneath the statement “By tapping VERIFY AGE, I sign this consent electronically.” (or CONTINUE on the phone enrollment screen). We permanently destroy biometric identifiers and biometric information when the initial purpose for collecting them has been satisfied or within three years of your last interaction with us, whichever occurs first — and, for your facial template and ONUS’s own records, no later than 24 months after your last verification, as described in Section 5 — absent a valid warrant or subpoena issued by a court of competent jurisdiction. We do not sell, lease, trade or otherwise profit from biometric identifiers or biometric information; we disclose them only as described in Section 5; and we protect them using the reasonable standard of care in our industry and in a manner that is the same as or more protective than the manner in which we store, transmit and protect other confidential and sensitive information.

Texas. Texas regulates the capture of biometric identifiers for a commercial purpose. We inform you and obtain your consent before capturing a biometric identifier; we do not sell, lease or otherwise disclose biometric identifiers except with your consent, as described on the consent screen and in Section 5, or as Texas law otherwise permits; we protect them with reasonable care; and we destroy them at the times stated in Section 5, which is within a reasonable time after, and not later than the first anniversary of, the date the purpose for collecting them expires, as to the biometric identifiers held for ONUS ID; any copy our provider keeps for its own fraud-prevention or security purposes is subject to its published limits described in Section 5. Our provider’s published policy permits it to use biometric data to train or improve its technology only with the individual’s consent, which ONUS ID does not ask you for and ONUS has not given.

Colorado. Colorado treats biometric identifiers and biometric data as sensitive data that may be processed only with your consent, and requires businesses that collect them to adopt and publish a written policy establishing a retention schedule, a protocol for responding to a security incident, and guidelines for deletion. Sections 5, 6 and 8 of this Policy are that policy. Consistent with Colorado law, ONUS deletes your facial template and its own records at the earliest of the date the initial purpose is satisfied, 24 months after your last verification, or within 45 days after we determine that storage is no longer necessary, and instructs its identity verification provider, through the provider’s deletion interface, to delete the biometric identifiers it holds for ONUS. Colorado law also limits a business’s ability to deny goods or services, or charge a different price, because a consumer declines to provide biometric identifiers that are not necessary to provide them; you may decline Facial Processing, and the business may verify your age another way.

Washington. Washington’s My Health My Data Act treats biometric data as consumer health data. Our Consumer Health Data Privacy Policy for Washington is Section 16 of this Policy, and our website homepage carries a separate, prominent link titled “Consumer Health Data Privacy Policy” that opens directly at that section (onusid.com/privacy-policy.html#sec-16).

Connecticut. Connecticut treats biometric data and government identification numbers as sensitive data that may be processed only with your consent, which we obtain on the consent screen. Businesses in Connecticut that use facial recognition technology for security or fraud-prevention purposes have additional signage and policy obligations; ONUS ID is offered in Connecticut on the basis of your consent, participating businesses are asked to post notice at their entrances with a link to our Biometric Notice, which serves as our facial recognition policy, and you may contact the Connecticut Office of the Attorney General (portal.ct.gov/ag) with questions or concerns about the use of facial recognition technology.

Maryland. Maryland law permits sensitive data, including biometric data, to be collected, processed or shared only where strictly necessary to provide or maintain a specific product or service you have requested, and prohibits the sale of sensitive data. ONUS processes your biometric data only as strictly necessary to perform the verification you have requested and does not sell it; our provider’s published policy permits it to use biometric data to train or improve its technology only with the individual’s consent, which ONUS ID does not ask you for and ONUS has not given.

California. In the 12 months before the Effective Date, we have collected the following categories of personal information, as described in Section 2: identifiers (including name, phone number and IP address); personal information described in California’s customer records law (such as name, address and driver’s license or passport number, which are read from your ID by our identity verification provider); characteristics of protected classifications (age and sex as shown on an ID); biometric information; internet or other network activity information; audio, electronic, visual or similar information (images of your ID and face, which are processed by our identity verification provider and not stored by ONUS); professional or employment-related information (Business Customer staff only); and sensitive personal information (government ID numbers and biometric information processed to verify identity, and, for Business Customer staff, account log-in credentials). We do not use personal information to draw inferences about your preferences or characteristics for profiling. The sources of this information are described in Section 2, our purposes in Section 3, our retention criteria in Sections 5 and 8, and the categories of recipients — Business Customers, our identity verification provider, other service providers and contractors, and legal and governmental authorities — in Section 7. This Policy also serves as our notice at collection; a business using ONUS ID may provide its own notice at the point of verification. We do not sell personal information or share it for cross-context behavioral advertising and have not done so in the preceding 12 months, and we do not sell or share the personal information of consumers under 16. We use sensitive personal information only for the purposes permitted by California law, such as performing the service you requested and preventing fraud and security incidents (our provider’s published policy permits it to use biometric data to train or improve its technology only with the individual’s consent, which ONUS ID does not ask you for and ONUS has not given); because we do not use sensitive personal information for other purposes, we are not required to offer a “Limit the Use of My Sensitive Personal Information” link, but you may submit a limit request as described in Section 9; the provider’s independent processing is described in Section 5. California residents may exercise the rights in Section 9, including through an authorized agent, without discrimination. We do not disclose personal information to third parties for their own direct marketing purposes.

Other states. Residents of other states with comprehensive privacy laws — including Delaware, New Jersey, Texas, Virginia, Oregon, Montana, Minnesota, New Hampshire, Rhode Island, Kentucky, Indiana, Iowa, Nebraska, Tennessee and Utah — may have rights to access, correct, delete and obtain a copy of their personal data; to opt out of targeted advertising, sales and certain profiling (which ONUS does not engage in); and to appeal a denied request. These laws treat biometric data, and in many cases government ID numbers, as sensitive data that may be processed only with consent or, in some states, after notice and an opportunity to opt out; we obtain your consent on the consent screen. Where these laws apply to us, we honor them. To exercise your rights, use the contact information in Section 15.

Local laws. Some cities and states require businesses that use facial recognition or biometric technology to post a notice at their entrances, and a small number of localities prohibit its use. Business Customers are responsible for those requirements at their locations, and ONUS does not permit Business Customers to use ONUS ID where its use is prohibited.

11. Children’s Privacy

ONUS ID is for adults purchasing age-restricted products. You must be at least 18 years old to enroll. ONUS ID is not directed to children, and we do not knowingly collect personal information from children under 13. If an attempted verification shows that the person is under 13, we delete the information collected in that attempt, and instruct our provider to do the same, within 30 days, keeping only the record that a verification was attempted and failed where the law requires it.

A person under 18 may nevertheless present an ID and attempt to enroll. In that case, no enrollment is created, and the information collected during the attempt is used only to record the result, is handled under the protections and retention rules in this Policy, and is never used for advertising or profiling; ONUS does not use it to train or improve technology, and our provider’s own uses are described in Section 5. A person aged 18 or older who enrolls but is under the legal age for a particular product will receive a “Do not sell” result for that product. If you are a parent or guardian and believe we hold information about your child that should be deleted, please contact us using the details in Section 15.

12. Cookies and Similar Technologies

Our website uses cookies and similar technologies that are necessary for the site to function and to remember your preferences, and may use analytics cookies to understand how the site is used so that we can maintain and improve it. We do not currently use cookies or pixels on our website to serve you targeted advertising on other sites; if that changes, we will update this Policy and provide any choices the law requires. You can control cookies through your browser settings; disabling some cookies may affect how the site works. The ONUS ID verification process itself uses only the technologies necessary to run the verification and keep it secure, such as session identifiers, and does not use cookies or tracking technologies for advertising purposes.

13. International Data Processing

ONUS ID is intended for use in the United States. ONUS and its identity verification provider store and process ONUS ID personal information on infrastructure located in the United States. Where a service provider’s personnel outside the United States support that infrastructure, the safeguards described in this Policy continue to apply.

14. Changes to This Privacy Policy

We may update this Policy to reflect changes in our practices, the service or the law. When we do, we will post the updated Policy on our website and revise the “Last Updated” date. If we make material changes to how biometric information is collected, used, shared or retained, or to our commitments regarding the sale or advertising use of personal information, we will provide more prominent notice — including through the businesses where ONUS ID is used — and will obtain new consent before the change applies to you where the law requires it. Any future use of ONUS ID for purposes other than age and identity verification, such as payment, will be described in an updated Policy and will require your separate consent.

15. Contact Us

If you have questions about this Policy, want to exercise your privacy rights, or have a concern about how your information has been handled, please contact us. If you were verified at a participating business, you may also contact that business about its own privacy practices.

16. Washington Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy is issued by ONUS Technologies Inc under the Washington My Health My Data Act and applies to Washington residents and to individuals whose consumer health data is collected in Washington. Under that Act, biometric data — including facial images from which a facial template can be extracted, facial templates, and measurements of facial features — is “consumer health data.” ONUS ID does not collect any other category of consumer health data.

• Categories of consumer health data collected: live facial images captured when you tap VERIFY AGE; the facial template (“faceprint”) derived from them, which is kept if you enroll; facial measurements derived for age estimation; and liveness and face-match scores.
• Sources: you, through the camera on the ONUS ID device at the store, or on your own phone if you enroll by text or QR link.
• Purposes for collection and use: to verify your age and identity for a purchase you have requested; to confirm at enrollment that your ID belongs to you; to detect and prevent fraud; and to secure the service. We collect this data only with your consent, given by tapping VERIFY AGE beneath the consent statement on the ONUS ID screen (or CONTINUE on the phone enrollment screen), or as necessary to provide the verification you have requested, and we use it for no other purpose than those listed here.
• Categories of consumer health data shared, and with whom: all of the categories above are shared with our identity verification provider, which performs the verification for us and which, as an independent business, also uses verification data for its own fraud-prevention, security, compliance and business-operations purposes as described in Section 5 of this Policy. At Washington locations, we share consumer health data with the provider only with your separate consent, given on a separate “I consent to sharing” screen shown after you tap VERIFY AGE (or CONTINUE on your phone) and before any image is captured, which is distinct from your consent to the verification itself. We do not share consumer health data with any other third party or affiliate. Our identity verification provider’s published policy permits it to use biometric data to train or improve its technology only with the individual’s consent, which ONUS ID does not ask you for and ONUS has not given. The business where you were verified receives only the verification result (and, if you are enrolled, your name), never your facial images or facial template. We do not sell consumer health data and will not do so without your separate, valid authorization.
• Your rights: to confirm whether we are collecting, sharing or selling your consumer health data and to access it, including a list of all third parties and affiliates with whom we have shared it and their contact information; to withdraw consent; to have your consumer health data deleted; and to appeal a denied request. If your appeal is denied, you may contact the Washington Attorney General at atg.wa.gov.
• How to exercise your rights or withdraw consent: email hello@onusid.com, call 844-551-6687, or write to ONUS Technologies Inc, Attn: Privacy, 207 Kiley Dr, Salisbury, MD 21801.

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