Biometric Data Policy
What face data identity verification collects, who holds it, how long it is kept, and when it is destroyed.
This policy explains how BuddyPath handles biometric information. It applies to one thing only: the identity verification that mentors complete before their profile can be listed. Nothing else on BuddyPath collects biometric information — not video calls, not profile photos, not video bios.
What is collected, and by whom
To confirm a mentor is the person shown on their government ID, our identity verification provider asks them to photograph an ID document and record a short selfie video. From that video the provider derives a face geometry scan — a mathematical representation of facial features — and compares it against the photograph on the ID.
That scan is a “biometric identifier” under the Illinois Biometric Information Privacy Act (740 ILCS 14), a “biometric identifier” under Texas Business & Commerce Code § 503.001, a “biometric identifier” under Colorado Revised Statutes § 6-1-1314, and “biometric data” under RCW 19.375. We treat it as such regardless of where a mentor lives.
The provider performs the comparison and holds the result. BuddyPath, LLC never receives, stores, or has access to the face scan, the ID image, or the personal details read from the document. What reaches BuddyPath is a single outcome: whether the check passed, together with an opaque reference number and the date. We keep no copy of the underlying material because we never hold it in the first place.
Our current provider is Persona Identities, Inc. (“Persona”), a Delaware corporation based in San Francisco.
Why it is collected
For one purpose: confirming that a mentor is who they say they are, before mentees can find, contact, or book them. BuddyPath connects people for one-to-one conversations, often about difficult parts of their lives, and identity verification is a basic safeguard for the person on the other side of that conversation.
We do not use biometric information for advertising, for training machine-learning models, for tracking anyone across the internet, or for any purpose other than the identity check described above.
Retention schedule
Biometric information is retained only as long as it is needed to complete the identity check that prompted its collection. Specifically:
- Face geometry scan: retained by the provider for 45 days from the date of the check, then permanently destroyed.
- Government ID image and extracted details: retained by the provider under the same schedule. BuddyPath never holds these.
- Verification outcome (passed / did not pass, a reference number, and the date): retained by BuddyPath for as long as the account exists, and then as required by law. This is not biometric information — it is a result, and it contains nothing about anyone’s face.
- Record of your consent (that you agreed, when, to which version of this policy): retained for as long as the account exists, and afterwards as needed to demonstrate compliance. This is also not biometric information.
In every case, biometric information is destroyed no later than the earlier of: (a) the date the purpose above has been satisfied, or (b) 45 days after the check — whichever comes first. Destruction is permanent and is not reversible.
Destruction guidelines
When the retention period ends, the provider permanently redacts the biometric information and the other personal information gathered in the same check, including the ID image and the details read from it. What survives is the record that a check happened, with that information removed from it. Redaction is permanent and cannot be reversed.
The 45-day window is one we set with the provider, and destruction is not deferred pending any business need of ours. BuddyPath, LLC keeps no copy of its own that could outlive it, because it never holds the underlying material in the first place.
We do not sell it
BuddyPath, LLC does not and will not sell, lease, trade, or otherwise profit from biometric information. Neither does our provider, under our contract with them.
When it is disclosed
Biometric information is disclosed only to the provider that performs the check, and only for that purpose. Beyond that, it is disclosed only if: the person it belongs to consents; disclosure completes a transaction they requested; disclosure is required by a law or municipal ordinance; or disclosure is compelled by a valid warrant or subpoena.
Your consent, and declining
Nothing is collected until a mentor has read a notice describing what is collected, why, and for how long, and has given a written release. That release is presented before the verification starts, not during it.
Providing biometric information is voluntary, but it is a condition of being listed as a mentor: a mentor who declines keeps their account and their profile, and can continue to use BuddyPath, but will not appear in mentee search and cannot receive new connection requests. Mentees are never asked for biometric information.
Questions
Write to support@buddypath.com. For how BuddyPath handles personal information generally, see the Privacy Policy.