Biometric Data Usage Policy

Last Updated on July 5, 2026

Welcome to Marketeq Digital Inc. (hereinafter referred to as "Marketeq," "we," "us," or "our"). This Biometric Data Usage Policy (the "Policy") describes how Marketeq approaches the collection, use, storage, and protection of biometric data, where such data is processed. Because biometric data is a sensitive category of personal data, Marketeq applies heightened safeguards and processes it only where there is a valid legal basis and a legitimate purpose. This Policy supplements our Privacy Policy and GDPR Compliance and Data Protection Statement and should be read together with them. If you have any questions about this Policy, you may contact us at legal@marketeqdigital.com.

1. Purpose and Scope

The purpose of this Policy is to explain the principles and safeguards that apply where Marketeq processes biometric data. This Policy applies to any biometric data that Marketeq may collect or process in connection with its services, systems, or operations. Biometric data is treated as a special category of personal data warranting enhanced protection. Marketeq does not process biometric data unless it is necessary for a specific and legitimate purpose and permitted under applicable law. This Policy reflects our commitment to handling such sensitive data with particular care.

2. Definition of Biometric Data

For the purposes of this Policy, "Biometric Data" means personal data resulting from specific technical processing relating to the physical, physiological, or behavioral characteristics of a natural person that allow or confirm the unique identification of that person. Examples may include facial geometry, fingerprints, voiceprints, and similar identifiers. Not all data relating to physical characteristics constitutes biometric data; the defining feature is its use for unique identification. This definition guides how we identify and protect biometric data across our operations. We apply this Policy whenever data meeting this definition is processed.

3. Legal Basis and Consent

Where Marketeq processes biometric data, we do so only where we have a valid legal basis under applicable law. Because biometric data is a special category of personal data, our legal basis will typically require the explicit consent of the individual or another specific condition permitted by law. Where we rely on explicit consent, we provide clear information about the processing and obtain that consent through an affirmative action. Individuals may withdraw their consent to the processing of their biometric data at any time, subject to applicable law. We do not process biometric data in the absence of a valid legal basis.

4. Purposes of Processing

Where biometric data is processed, it is used only for the specific purposes for which it was collected and which have been communicated to the individual. Such purposes may include identity verification, authentication, or security, depending on the context. We do not use biometric data for purposes that are incompatible with those for which it was collected. Any change in the purpose of processing would require an appropriate legal basis and, where applicable, renewed consent. We limit the processing of biometric data to what is necessary for the relevant purpose.

5. Storage and Security

Biometric data, where processed, is subject to enhanced technical and organizational security measures appropriate to its sensitivity. Such measures may include encryption, strict access controls, and secure storage arrangements designed to protect the data against unauthorized access or disclosure. Access to biometric data is limited to authorized personnel and processors with a legitimate need. We take particular care to protect biometric data throughout its lifecycle, given the potential consequences of its compromise. Our security measures for biometric data are consistent with, and often exceed, those applied to other categories of personal data.

6. Retention and Deletion

Marketeq retains biometric data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law. Once the data is no longer required, or upon the withdrawal of consent where consent is the legal basis, we take steps to securely delete or destroy it. We do not retain biometric data indefinitely. Our retention and deletion practices for biometric data are subject to the principles set out in our Data Retention Policy, with heightened care given to the sensitivity of the data. The secure deletion of biometric data is an important safeguard against its misuse.

7. Sharing of Biometric Data

Marketeq does not sell biometric data and shares it only where necessary and permitted under applicable law. Where biometric data is shared with a processor acting on our behalf, we require appropriate contractual and security safeguards. We do not disclose biometric data to third parties for their own independent purposes without a valid legal basis. Any sharing of biometric data is limited to what is necessary and subject to the protections described in our Third-party Data Sharing Policy. We treat the sharing of biometric data as warranting particular scrutiny.

8. Individual Rights

Individuals whose biometric data is processed by Marketeq may exercise the rights afforded to them under applicable data protection law, including rights of access, rectification, erasure, and, where processing is based on consent, the right to withdraw consent. We facilitate the exercise of these rights in accordance with our Privacy Policy and applicable law. Given the sensitivity of biometric data, we handle related requests with particular care. Individuals may contact us to exercise their rights or to raise concerns regarding the processing of their biometric data.

9. Changes to This Policy

Marketeq reserves the right to modify or update this Biometric Data Usage Policy at any time to reflect changes in our practices or legal requirements. Any changes will become effective upon posting the revised Policy, and we encourage you to review it periodically. Where changes are material, we will endeavor to provide additional notice through appropriate means.

10. Contact Information

If you have any questions, concerns, or requests regarding this Biometric Data Usage Policy, please contact us at legal@marketeqdigital.com. We are committed to handling biometric data responsibly and to addressing your inquiries promptly and transparently.