Biometric Information Policy
Effective Date: November 7, 2023
This Biometric Information Policy defines Funnel Leasing (“Funnel” or “our”) policies and procedures regarding collection, storage, use, protection, retention, and deletion of biometric information and identifiers.
Biometric Information Collected
Funnel provides services to property managers, including support for prospective or existing rentals and leases of properties to individuals. Funnel provides a website based online leasing experience that supports individual rental prospect and existing renter identity verification, income verification, and other renter lifecycle functionality (to facilitates tours, rental applications (including screening) and other interactions between a prospective or existing renter and a landlord/property management company).
When using our online leasing application, Funnel may prompt you to take a photograph of your face using your mobile device’s camera. This image is collected to verify identity. This image of your face is automatically analyzed and qualifies as a ‘facial geometry scan’ under some laws. Thus, such image analyses are a biometric identifier or biometric information (“Biometric Information”).
Use of Biometric Information
Funnel, its vendors, and/or its service providers may collect, store, and use facial geometry scans to enable and verify your identify before scheduling a tour and/or as part of the rental application process.
Biometric Information may be shared with Funnel’s technology providers, such as a data storage provider or identity verification provider. These providers help support the online leasing application and related renter lifecycle services provided by Funnel to property managers, and individual residents/prospective residents. Accordingly, Biometric Information (including analysis of facial image / facial geometry scan) may be shared with the following third party providers:
- Plaid: Plaid receives the image of your face and analyzes it to verify identity. Plaid may further disclose and store your image/image analysis (or data derived from it) with IDVerse (its provider) and Amazon Web Services (AWS-East, for storage) for these purposes. Plaid’s privacy notice is available here. Please note that Plaid may choose to use different providers at any time.
As permitted by law, Funnel (or its third party providers) may additionally collect or disclose your Biometric Information: (a) with your consent, (b) to complete a financial transaction you authorize, (c) as required by federal, state or municipal law or ordinance, or (d) 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 by Funnel no longer than the earlier of:
- The initial purpose for collecting or obtaining such Biometric Information has been satisfied, such as the verification of your identity (or verification that an image is not suitable for identity verification); or
- Three years since your last interaction with us.
Funnel deletes any Biometric Information it retains after its retention period as described above. As required by law, Funnel uses methods designed to ensure permanent destruction of Biometric Information when it deletes such data at the end of its retention. Notwithstanding the above, Funnel and its technology providers may retain Biometric Information pursuant to a valid warrant or subpoena as permitted by law.
Biometric Information will be stored, transmitted, and protected from disclosure using a reasonable standard of care in compliance with Funnel’s industry, its other data protection policies and procedures, and other disclosures or statements made by Funnel; and in a manner that is the same or more protective than that used to store, transmit, and protect other confidential and sensitive information.