BIOMETRIC DATA NOTICE · v1.0

Biometric Data Notice (BIPA)

What biometric data we collect, why we collect it, how long we keep it, and your rights — disclosed before you ever submit a selfie.

Last updated: July 2026

Your consent matters.

This notice is shown at the point where you submit your selfie and ID — before you submit. By proceeding with verification, you consent to the practices described here. You can decline and still browse, but verification is required to post and interact.

  • True Circle collects biometric data solely for the purpose of identity verification — confirming that you are a real human being and that the government ID you submit belongs to you.
  • Biometric data is never collected for surveillance, advertising, marketing, profiling, or any purpose other than identity verification.
  • When you complete verification, we capture a live selfie using your device camera.
  • A facial recognition template (a mathematical representation of your facial geometry) is generated from that selfie and matched against the photo on your government-issued ID.
  • We also collect the image of your government ID. This is identity documentation, not biometric data, but it is stored under the same strict protections described below.
  • Biometric data — the facial recognition template derived from your selfie — is deleted from our systems within 30 days of successful verification.
  • Your government ID image is likewise deleted within 30 days of verification, after it has been reviewed once by our team.
  • A written retention and destruction schedule is available upon request by contacting notify@truecircle.com.
  • If verification fails or is abandoned, the biometric data collected during that attempt is deleted within the same 30-day window.
  • All biometric data is encrypted in transit (TLS) and at rest.
  • Access to biometric data is restricted to a limited number of authorized trust-team members on a strict need-to-know basis.
  • Every access to verification data is logged and auditable.
  • Third-party verification providers we may use are contractually required to maintain equivalent security controls and to delete biometric data after processing.
  • Biometric data is not sold, leased, traded, or otherwise profited from — ever.
  • Biometric data is not shared with advertisers, marketers, data brokers, or any third party not strictly necessary for verification.
  • Third-party verification providers receive only the minimum data needed to process verification and are contractually prohibited from storing, reusing, or sharing it.
  • Law enforcement requests for biometric data are handled under the same legal-process standards described in our Privacy Policy; we do not voluntarily share biometric data.
  • For questions about this Biometric Data Notice or your biometric data, contact notify@truecircle.com.
  • For legal inquiries, contact legal@truecircle.com.
  • To request the written retention and destruction schedule, email notify@truecircle.com.

Questions about your biometric data?

Contact us at notify@truecircle.com · request our retention schedule any time.