Biometric Data Policy

This policy explains how Still My Home, Inc. ("we", "us") and our identity check provider, Didit Identity, Inc. ("Didit"), collect, use, keep and destroy biometric data during our identity check. It is our public retention schedule and our guidelines for permanently destroying biometric data, including under the Illinois Biometric Information Privacy Act and the laws of Colorado and Texas. It is part of our Privacy Policy.

1. Why we check identity

Deed fraud usually starts with someone pretending to be the owner. So before we record a notice or answer a request about a home, we confirm that the member is a real person and the person they say they are. We do a new check before a few sensitive steps, such as approving a closing request, releasing the notice on a home, or changing who holds a membership.

2. What is collected

During a check, Didit collects for us:

• images of your photo ID (front, and back for some IDs), including your ID photo, and the information printed on it;
• a short selfie video or photos, to confirm a real, live person is present;
• face geometry: measurements of the shape of your face, taken from your selfie and your ID photo so they can be compared. Face geometry is biometric data; and
• information about the device and network you use, such as your IP address and the approximate location it suggests, to detect fraud.

3. What it's used for

We use biometric data only to:

• (a) confirm your identity and that your ID is real;
• (b) catch anyone using your name, photos or ID to pretend to be you;
• (c) review a check that was declined or flagged, or that you or we have a question about; and
• (d) keep a record of who completed the check, in case someone later pretends to be you or disputes the check, or a Restoration Request or a fraud investigation needs it. For this, Didit keeps your ID and selfie images, never a face template, for the time in section 7.

We never use biometric data for marketing or advertising, or for any other purpose.

4. Your agreement comes first

Before any check starts, we show you a notice on its own screen and ask for your written agreement. You sign electronically by ticking a box and selecting "I agree, start the check". We keep a record of when you agreed and which version you saw. If you don't agree, the check doesn't start. The check is required to finish setup, because it's how we make sure no one else can control a notice on your home. If you'd rather not do it, you can end that home's membership before setup is finished and get a full refund, as our Terms of Service say. Section 11 explains the help we give if a disability makes the check hard.

5. Who holds it

Didit collects and stores your biometric data for us, as our service provider, under a contract that lets it use the data only to do our checks. We don't receive your ID images, selfie, video or face geometry, and we don't store them in our systems. We receive only the result (approved, declined or under review), the date and time, a reference number for the check, and the first and last name on your ID, so we can compare it with the deed.

A few trained members of our staff can view a check in Didit's system, including the images, while Didit still holds them. They do so only to review a declined or flagged check, to help you with a problem, or to look into fraud. They don't copy or save the images.

Didit stores the data on servers in the United States.

6. No selling, and limited sharing

We and Didit don't sell, lease, trade or otherwise profit from your biometric data. Didit may not use it to train its systems.

We disclose biometric data only:

• (a) to Didit, and the companies Didit uses to run its service, to do your check;
• (b) when you agree in writing, for example to your attorney if someone used your identity;
• (c) when a state or federal law requires it; or
• (d) when a valid warrant or subpoena issued by a court requires it.

Didit may also use information derived from checks, with names and other direct identifiers removed, to protect its own service against fraud. It may not use it to identify you, for marketing, or to sell.

7. How long it's kept (retention schedule)

Each check has its own 24-month limit. A new check doesn't extend how long an earlier check's images are kept.

In every case, biometric data is permanently destroyed no later than the earliest of:

• (1) 12 months after your membership ends (the time our Restoration Promise gives you to report fraud recorded while you were a member), when the record in section 3(d) is no longer needed;
• (2) 24 months after the check;
• (3) 45 days after a review finds it's no longer needed; or
• (4) 15 days after you withdraw your agreement or ask us to delete it.

All of these are within Illinois's limit of 3 years after your last interaction, Colorado's limit of 24 months after your last interaction, and Texas's limit of one year after the purpose ends. The only reason we would keep biometric data longer is a valid warrant or subpoena issued by a court. We review this schedule, and the biometric data held for us, at least once a year.

8. How it's destroyed

Didit deletes the images automatically 24 months after a check, and we tell Didit to delete them sooner when an earlier deadline in section 7 arrives. Deletion is permanent: Didit keeps no copy, and deletion covers every place Didit holds the data, including the systems of the companies it uses. We keep a record of each deletion instruction.

9. How it's protected

Didit encrypts the data in storage and in transit and limits who can see it. We require Didit to protect biometric data at least as carefully as other sensitive information, using the standard of care in its industry, and we do the same for anything we hold about a check.

10. If there's a security incident

We have a written plan for responding to any incident that may affect biometric data. Didit must tell us promptly about any incident affecting data it holds for us. We look into it, contain it, and notify you and government agencies as the law requires.

11. If a disability makes the face check hard

The face check is required, because it's how we make sure that only the real owner can control a notice on their home. If a disability makes the check hard or impossible for you, email help@stillmyhome.com or write to us. We'll help you complete it, for example with more time, step-by-step help, or someone you trust holding the phone. If you still can't, we'll find another way that works for you, decided case by case, such as a video call with a trained member of our team where you show your photo ID. We don't record these calls, take screenshots of them or use face-matching software on them. Where a step would normally use a new face check, we use the same arrangement.

12. Your rights

You can ask us, free of charge:

• what kinds of biometric data were collected about you, where they came from, why, and who received them;
• to delete them; or
• to withdraw your agreement.

Withdraw in your account settings ("Withdraw biometric consent") or by emailing help@stillmyhome.com. We stop using the data and tell Didit to delete it within 15 days. After that, when a step would need a new face check, such as approving a closing request, we confirm it's you by a video call with our team instead, as in section 11. We answer other requests within 45 days. You can also write to Didit at privacy@didit.me.

13. Changes

If we change this policy, we post the new version here with a new date. If a change affects how your biometric data is used or kept, we ask for your agreement again before it applies to you.

14. Contact

help@stillmyhome.com, or Still My Home, Inc., 82 Nassau St #61542, New York, NY 10038.