Biometric Information Policy

This Biometric Information Policy outlines Funnel Leasing, Inc.’s (“Funnel”, “we”, or “our”) policies and procedures for collecting, storing, using, protecting, retaining, and deleting Biometric Information.

Funnel provides services to property managers, including support for rental and lease processes of properties to individuals. These services include, but are not limited to:

• Online Leasing Application: Funnel provides a website-based online leasing experience that supports individual rental prospects and existing renter identity verification, income verification, and other renter lifecycle functionalities. This facilitates tours, rental applications (including screening), and other interactions between prospective or existing renters and landlords/property management companies.
• Call Analysis Platform: Funnel provides a call analysis platform that supports property managers by providing insights into the performance of their leasing agents and conversations with prospective and existing residents, including by identifying individuals answering calls, with the aim to improve customer service.

Definition of Biometric Information

When “Biometric Information” is used in this Biometric Information Policy, it refers to any biological characteristics of a person, such as a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, including information based on such characteristics. This includes any data derived from these characteristics used to identify an individual.

Biometric Information Collection and Use

Funnel collects Biometric Information through two primary methods, depending on how you interact with our services:

• Online Leasing Application: When using Funnel Leasing’s online leasing application, Funnel may prompt you to take a photograph of your face using your mobile device’s camera. This image is collected by Funnel Leasing’s vendor Plaid Inc. (“Plaid”). Plaid and/or Plaid’s service providers receive the image of your face and analyze it to verify identity. They do so through facial mapping technology that compares specific facial features from the selfie—such as the distance between the eyes, nose, and ears—against those of the ID photo, ensuring they’re the same person. Your identity document image, photograph, or video image, and any derived facial geometry scan from those images, may be considered Biometric Information in some jurisdictions.
  
  Funnel Leasing does not receive the biometric identifier generated from the images. The image from your identity document, photograph, or video images of your face, and your derived facial geometry, if applicable, are stored in an encrypted format by Plaid and Plaid’s service providers. Plaid processes this information on our behalf in accordance with our contractual agreements. It is generated and held by Plaid. When the biometric identifier is no longer needed for the purposes described in this paragraph, we inform Plaid that the biometric identifier must be destroyed. For identity verification and security purposes, we will have access to the selfie image and will receive the information extracted from the scan of the government ID document as well as the results of the verification process. We may use this process and associated information to verify your identity and your identity documents before scheduling a tour, as part of the rental application process, to comply with legal obligations, and protect against fraud and abuse. We do not use, disclose or retain your Biometric Information for any other commercial purpose.
  
  For more information about Plaid’s privacy practices, please review their Privacy Policy and Biometric Policy and Release .
• Call Analysis Platform: As part of the Funnel Leasing platform, customer may activate Speaker ID. When activated, Funnel Leasing will, at the direction of our customers, use call recordings to extract voiceprints from individuals participating on calls and will use that voiceprint to engage in voice comparison to identify specific individuals (i.e., the agent). The extraction of voiceprints and voiceprint comparison to identify a particular individual may qualify as Biometric Information under some laws.

Funnel uses voiceprints within its platform to enhance service delivery and operational efficiency for each customer. This includes facilitating our customer’s ability to evaluate leasing agents, identify high performers, address training needs, and ensure a high level of service. Voiceprints may also be utilized for identity verification and fraud prevention. Additionally, we use voice recordings to make our software smarter and provide customers with a better experience. The way we do this is by training our computer models on voice data from specific locations. For example, we might train a model using voice recordings from leasing agents at a particular apartment complex or across company locations. Importantly, we do not combine voice data across customers. This ensures that each model is specifically tailored to the client and location where it’s being used, and that your data is kept private.

Call recordings and voiceprint data are securely stored with our technology providers, such as Amazon Web Services, Inc. in accordance with our contractual agreements. As permitted by law, Funnel (or its third-party providers) may collect or disclose your Biometric Information: (a) with your consent, to complete a financial transaction you authorize, (b) as required by federal, state, or municipal law or ordinance, or (c) pursuant to a valid warrant or subpoena. Funnel does not sell, lease, trade, or otherwise profit from any of the Biometric Information it collects.

Storage and Retention Policy for Biometric Information

Biometric Information will be retained for no longer than necessary to fulfill the purposes outlined at the time of collection. In no event will Biometric Information be retained longer than allowed by law. Notwithstanding the above, Funnel and its technology providers may retain Biometric Information pursuant to a valid warrant or subpoena, as permitted by law.

To protect Biometric Information, Funnel Leasing employs industry-standard security measures, including encryption both in transit and at rest, access controls, and regular security audits. These measures are designed to prevent unauthorized access, disclosure, alteration, or destruction of Biometric Information. Our security protocols are reviewed regularly and updated as necessary to maintain reasonable and appropriate levels of protection.

While we make best efforts to secure your information, no security measures can guarantee absolute protection, particularly given evolving security threats. As such, there is always a residual risk of unauthorized access, use or disclosure of your Biometric Information. You acknowledge and accept that the security of your Biometric Information cannot be guaranteed.

User Rights

Users have specific rights regarding their Biometric Information, including the right to access, correct, or request deletion of their data. Requests to exercise these rights can be submitted to Funnel Leasing via consumer@funnelleasing.com.

Contact Us

For questions or concerns about this policy, please contact us at legal@funnelleasing.com .