Biometric Data Policy

BIOMETRIC DATA POLICY

Purpose and Scope

Parksite Inc. (“Parksite”) may use Biometric Data (as defined below) for identity verification, time management and warehouse operations.  To the extent that Parksite collects Biometric Data, this Biometric Data Policy (the “Policy”) sets forth Parksite’s policy for the collection, use, safeguarding, storage, retention and destruction of Biometric Data.

Definitions

Biometric Identifier means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include donated organs, tissues, or parts as defined in the Illinois Anatomical Gift Act or blood or serum stored on behalf of recipients or potential recipients of living or cadaveric transplants and obtained or stored by a federally designated organ procurement agency. Biometric identifiers do not include biological materials regulated under the Genetic Information Privacy Act. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996. Biometric identifiers do not include an X-ray, roentgen process, computed tomography, MRI, PET scan, mammography, or other image or film of the human anatomy used to diagnose, prognose, or treat an illness or other medical condition or to further validate scientific testing or screening.

Biometric Information means any information, regardless of how it is captured, converted, stored, or shared, based on an individuals’ Biometric Identifier used to identify any individual. Biometric Information does not include information derived from items or procedures excluded under the definition of Biometric Identifiers.

Biometric Data means both or either of Biometric Identifier or Biometric Information.

Purpose for Collection of Biometric Data

Parksite or its service providers may collect, possess, store, and/or use employee Biometric Data solely for:

• Identity verification and time management in connection with ADP timeclocks
• Voiceprint collection and use in connection with Vocollect

Authorization

Parksite will:

1. Inform each employee in writing that Parksite and/or its service providers may be collecting, processing, storing or using the employee’s Biometric Data, including;
2. Inform each employee in writing of the specific purpose, circumstances and manner of such collection, processing, storage or usage, including the length of time of storage, if applicable;
3. Inform each employee in writing of the manner in which the employee may opt out of the collection, processing, storage or usage of their Biometric Data; and
4. If the employee consents to the collection, processing, storage or usage of their Biometric Data, receive a written release signed by the employee authorizing Parksite and its service providers to collect, store and use Biometric Data for the specific reasons set forth in the written release.

Disclosure

Parksite will not disclose, re-disclose or otherwise disseminate any Biometric Data to any third party unless:

1. The employee consents to the disclosure or dissemination;
2. Disclosure or re-disclosure completes a financial transaction requested or authorized by the employee or contractor;
3. Disclosure or re-disclosure is required by state or federal law or municipal ordinance; or
4. Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Parksite will not knowingly sell, lease, trade, or otherwise profit from an employee’s Biometric Data.

Retention Schedule

Parksite will retain employee Biometric Data, if it is retained at all, until the first of the following options occurs:

1. The initial purpose for collecting or obtaining the Biometric Data has been satisfied, such as the termination of the employee’s employment with Parksite or Parksite is no longer using Biometric Data for the purposes described above; or
2. Within 3 years of the employee’s last interaction with Parksite.

Data Storage

To the extent Parksite collects, stores and retains Biometric Data, it shall maintain reasonable physical, administrative and technical safeguards to store, transmit, and protect from disclosure any such Biometric Data collected, stored or retained.  Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same or more protective than the manner Parksite transmits, stores, and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing confirmation, account numbers, PINs, driver’s license numbers and social security numbers.