Biometric Data Policy

Inferon, Inc. (“Inferon”, “we”, “us” or “our”) provides a platform to its users, which includes desktop, web, and mobile applications, as well as tools driven by artificial intelligence (the “Inferon Platform”). Through or in connection with the Inferon Platform, Inferon may process, derive or otherwise possess biometric data, as defined below. This Biometric Data Privacy Policy applies to Inferon’s processing of such biometric data from or regarding our users.

Inferon may also offer services, including the Inferon Platform or parts of the Inferon Platform, to its business customers. This Biometric Data Privacy Policy does not apply to biometric data we process on behalf of our business customers (e.g., where our business customers provide or make available to Inferon biometric data concerning their own customers or end users). We use biometric data we receive from our business customers solely on the instructions of our business customers, as governed by our agreements with those business customers.

If you have concerns regarding biometric data we process on behalf of one of our business customers, please direct your concerns to that customer.

1. Biometric Data Defined

2. Purpose for Collection of Biometric Data

Inferon may derive, generate, collect, store and use biometric data, which may include certain scans of facial geometry, in order to provide certain features of the Inferon Platform to our users. For example, Inferon may generate facial templates in connection with the scanning of user-provided photos, videos or other images and may derive certain information from user-provided audio or voice recordings in order to create avatars and may use biometric data in order to provide certain other video, image and audio editing and animation tools and features through the Inferon Platform. Inferon will only use this biometric data for purposes of providing the applicable features of the Inferon Platform to the user and for legal compliance purposes.

Before collecting, deriving or generating any biometric data from or regarding a user, we will obtain the user’s express written consent where and as required by Applicable Biometric Data Privacy Law.

3. Disclosure of Biometric Data

Inferon may disclose biometric data to its third-party vendors only as necessary to facilitate the provision of the Inferon Platform to the applicable user.

Inferon does not share biometric data with any other third parties unless:

• The user or the user’s legally authorized representative consents to the disclosure;
• The disclosure is required by applicable law or regulation or otherwise permitted by Applicable Biometric Data Privacy Law;
• The disclosure is required to complete a financial transaction requested or authorized by the user; or
• The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

4. Retention and Storage of Biometric Data

Inferon and its vendors generally retain biometric data for only as long as necessary to satisfy the purposes for collection and processing identified above. Notwithstanding the foregoing, except to the extent required by applicable law, in no event will Inferon retain a biometric data of a user beyond the date that is three years following the last interaction of the user with Inferon.