Coterie Biometric Data Notice and Consent

Coterie collects, stores, and uses personnel Biometric Data (i.e., fingerprint scan and/or face geometry scan) if the individual has voluntarily selected to use their fingerprint scan as the method to authenticate their identity to access Coterie approved laptops and/or their face geometry scan to access Coterie approved cell phones to access Coterie information. Such voluntary use of Biometric Data, allows Coterie to use the Biometric Data to confirm the identity of Coterie personnel accessing devices that are approved by Coterie to access Coterie information, optimize efficiency, ensure and verify security of Coterie information, use for legal or litigation purposes and defense, and analyze potential security risk and the effectiveness of Coterie’s security practices and policies. Coterie does not use personnel fingerprints or face geometry scans for any other purpose.

Additionally, Coterie does not require personnel to use their fingerprint or face geometry scans to authenticate their identity to access Coterie approved laptops or cell phones to access Coterie information. Personnel may choose to use alternative methods to authenticate their identity, such as passwords or numerical pins, consistent with Coterie’s security policies.

If personnel elect to use their fingerprint or face geometry scan as their method of authentication to access their Coterie approved device(s) to access Coterie information, the individual consents to Coterie collecting, storing, and using that Biometric Data for the purposes described above.

Coterie will permanently and securely destroy an individual’s Biometric Data the earlier of (a) after an individual revokes consent for use of their Biometric data; or (b) after the individual’s separation from Coterie.  In any event, any Biometric Data will be permanently, and security deleted within three years of the individual’s last contact with Coterie. Absent a valid warrant or subpoena issued by a court of competent jurisdiction, Coterie will comply with this retention schedule and destruction guidelines.

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