November 18, 2025
EFFECTIVE DATE: March 31, 2026
INTRODUCTION
This Policy governs the collection, use, retention, disclosure, and protection of Biometric Data by Impersonas Inc. (“Impersonas”) and its subsidiaries, contractors, service providers, and vendors (“Vendors”), in compliance with applicable laws, including the Illinois Biometric Information Privacy Act and recent amendments to the Colorado Privacy Act (CPA), specifically HB 1130 (Biometric Data Amendments)[SM1.1][NH1.2], and all other applicable federal, state, and local Biometric Laws [SM2.1](“Biometric Laws”).
DEFINITION OF BIOMETRIC DATA
“Biometric Data” means one or more biometric identifiers—such as fingerprints, voiceprints, retina or iris scans or records, facial maps, geometry or templates, or other unique biological, physical, or behavioral characteristics (as defined by Biometric Laws)—that are used or intended for use to uniquely identify an individual.
Biometric Data does not include digital or physical photographs, audio or video recordings, or any data derived from such photographs or recordings, unless used for identification purposes.
PURPOSES FOR COLLECTION AND USE
Impersonas and its Vendors may collect, use, and retain Biometric Data only for purposes of:
• Providing the avatar (“impersona”) services that you request;
• Verifying identity for fraud prevention and security;
• Providing and improving Impersonas’ and Vendors’ services;
• Recordkeeping or compliance with applicable laws.
NOTICE AND CONSENT
Before any Biometric Data is collected or processed:
• Individuals must be provided clear and understandable notice detailing the type(s) of Biometric Data, the collection purpose(s), the retention period, and potential third-party disclosures and their purposes.
• Informed, written consent must be obtained from the individual (or the individual’s parent/guardian if under 18, where required by law).
Impersonas does not condition the provision of goods or services upon the collection of Biometric Data, except where such data is necessary to provide the requested service. Impersonas also does not retaliate or price discriminate based on the exercise of Biometric Data rights.
RETENTION AND DELETION
Biometric Data is retained only as long as reasonably necessary to fulfill the purpose for which it was collected, or as required by law, and is subject to the following guidelines:
• Biometric Data will be destroyed within one year after the individual’s last interaction with Impersonas, or within a reasonable period after the initial collection purpose is satisfied, whichever occurs first.
DATA SECURITY MEASURES
Impersonas and its Vendors will:
• Store, transmit, and protect Biometric Data using reasonable standards of care appropriate to Impersonas’ industry, at a level equal to or greater than used for other confidential and sensitive information;
• Adopt and maintain a written data security incident response protocol specific to Biometric Data, including prompt written notification to impacted individuals and controllers if an incident occurs.
DISCLOSURES AND SHARING
Impersonas and its Vendors will not sell, lease, trade, or otherwise profit from Biometric Data. Biometric Data will not be disclosed to third parties without the individual’s consent, except:
• To Impersonas’ processors and Vendors solely for the limited, disclosed purposes above;
• As required by law or valid legal process;
• For security, fraud prevention, or compliance with other legal obligations.
Impersonas and its Vendors will not purchase Biometric Data unless it pays the individual for their Biometric Data in a transaction unrelated to the provision of a product or service, and only after obtaining explicit, informed consent.
YOUR RIGHTS
Individuals, upon request and free of charge, have the right to:
• Access and receive a description of the Biometric Data Impersonas holds about them;
• Know the source of Biometric Data collection;
• Understand the purpose of collecting or processing Biometric Data;
• Know the identity of any third party to whom Impersonas disclosed their Biometric Data and the purpose of such disclosure;
• Receive a description of the specific Biometric Data disclosed to third parties.
Impersonas will not retaliate against, deny services to, or charge higher prices to individuals who choose not to provide or who exercise their rights with respect to Biometric Data.
CONTACT INFORMATION
For questions about this Policy, to exercise your rights, or to seek further information, please contact: info@impersonas.com.
Impersonas Inc. is a company registered in Delaware, USA. We operate a platform that connects public figures, talent, and studios to opportunities in digital identity and media licensing. © IMPERSONAS Inc. All rights reserved.