This Biometric Policy is Avala AI, Inc.'s public written policy for biometric identifiers and biometric information. It is part of the Contributor Terms and is incorporated into the Privacy Policy.
Avala's address is 403 Broderick Street, Unit 3, San Francisco, CA 94117. Questions go to [email protected].
1. What this policy covers
Capture Data recorded in Arcade can contain or be used to derive biometric identifiers or biometric information, including face geometry, hand geometry, gait, and a voiceprint. A government-identity check, if a campaign or a payout method requires one, may include a facial image used to match an identity document.
This policy does not cover Face ID or Touch ID. Those are processed by Apple on the device. Avala does not receive that biometric data. See Apple's privacy policy.
Customer Materials that an enterprise customer uploads, including faces or license plates incidentally present in the customer's own sensor data, are processed on the customer's instructions under the Master Services Agreement and, when executed, the Data Processing Addendum. This policy's retention schedule applies to biometric information Avala collects from contributors. For customer-uploaded data, Avala follows the customer's instructions and the agreement.
2. Purpose and consent
Avala uses biometric information from a capture to provide the capture, to check that the recording is a real human recording rather than a synthetic or duplicated one, and to license the accepted capture as Capture Data. Avala uses a facial image from an identity check only to verify identity and to prevent fraud.
Avala does not use biometric information to uniquely identify a bystander, to build a biometric template for sale, or to infer a sensitive characteristic for advertising. Data customers who receive accepted Capture Data are bound by the Dataset License, which prohibits re-identification and prohibits building biometric templates for identification.
Avala collects this information with the consent in the Contributor Terms and, for another adult who appears in a capture, the Household Release. You may refuse by not recording. Refusal means Avala cannot accept that capture.
3. No sale of biometric identifiers
Avala does not sell biometric identifiers or biometric information. Licensing an accepted recording that happens to depict a person is described in the Privacy Policy. It is not a sale of a biometric identifier extracted for identification, and Avala does not disclose face geometry, hand geometry, gait templates, or voiceprints as a standalone biometric product.
4. Retention and destruction
Avala permanently destroys biometric identifiers and biometric information when the first of these occurs:
- For a capture that was never accepted, within 30 days after rejection, unless a longer period is required to investigate fraud or a legal claim.
- For an identity-check facial image, when the verification purpose is complete, and in any event within three years after your last interaction with Avala.
- For biometric information derived from an accepted capture, within three years after your last interaction with Avala, unless you ask for earlier destruction and Avala can destroy its copies without breaking a duty to keep evidence of fraud or a legal claim.
- Where the Texas Capture or Use of Biometric Identifier Act requires a shorter period, within one year after the purpose for collecting the identifier has been satisfied.
Destruction means Avala deletes the identifier from active systems and overwrites or isolates backups until they age out. Where an accepted capture has already been licensed, Avala deletes its copies, notifies the data customers who received that capture, and requires them to delete their copies under the Dataset License. Model weights that do not retain the identifier are not biometric identifiers and are not destroyed under this section.
5. Illinois and Texas
This policy is the public written retention and destruction schedule Avala provides for purposes of the Illinois Biometric Information Privacy Act and the Texas Capture or Use of Biometric Identifier Act. Avala does not collect biometric identifiers for a commercial purpose other than the purposes in Section 2. If you are in Illinois or Texas and you believe Avala has biometric information about you outside this schedule, contact [email protected].
6. Contact
Email: [email protected]
Address: Avala AI, Inc., 403 Broderick Street, Unit 3, San Francisco, CA 94117