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Biometric Data Collection and Retention:
Hilco Holdings, Inc., and each of its affiliates and subsidiaries (collectively, “Company”) may collect, store, and use Biometric Data for certain purposes described below, and it may disclose that Biometric Data in certain circumstances. This Policy explains what that means for you, and how you consent to Company’s activities.
Definitions
“Biometric Data” as used in this Policy includes both: (i) “Biometric Identifiers”, meaning a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits. Biometric Identifiers do not include writing samples, written signatures, photographs, human biological samples used for scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color; and (ii) “Biometric Information”, meaning any information, regardless of how it is captured, converted, stored, or shared, that is based on Biometric Identifiers, including a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, that is used to identify an individual.
Data Collection and Purpose
Company uses a system offered by Netradyne, Inc. (“Netradyne”) called Driver.i, which includes both a road-facing camera and an inward facing camera to capture video footage of critical events. Driver.i applies certain processing and artificial intelligence techniques to the data collected from the forward and driver facing cameras to determine whether the driver of the vehicle in which it is installed is alert, focused, wearing their seatbelt, and whether they are engaging in unsafe driving behavior, such as distracted driving (for example, by talking on their cell phone, reading or sending text messages, or otherwise not paying attention to the road ahead of them). The processing supporting the Driver.i system’s features detects head orientation, location, whether the driver is holding an object such as a smartphone, as well as blinking, yawning, and whether the driver appears drowsy. The facial recognition technology operates, in part, through scans of a driver’s face geometry, along with artificial intelligence. These items may be considered Biometric Data under Illinois law. Netradyne’s technology allows Company to use this Biometric Data to analyze driving and driver performance, improve safety, and to analyze certain driving events. Using the features on Netradyne’s Driver.i enhances safety by increasing the efficacy of Netradyne’s driver-based insights, improving driver safety and efficiency, and encouraging good driving techniques.
The data collected from Driver.i will be disclosed to Netradyne and stored on Netradyne’s cloud servers which are accessible through Company’s Netradyne account. Netradyne will have access to Biometric Data to perform the functions of its services agreement with Company. A copy of Netradyne’s privacy policy is available at https://www.netradyne.com/privacy-policy and a copy of Netradyne’s Biometric Data policy is available at https://www.netradyne.com/biometric-data-privacy-policy.
Data Storage, Protection and Disclosure Policy
Company’s policy is to protect and store Biometric Data in accordance with applicable laws and regulations, including, but not limited to, the Illinois Biometric Information Privacy Act. Specifically, Company shall use a reasonable standard of care to store, transmit and protect from disclosure any Biometric Data collected. Such storage, transmission and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which Company stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual such as social security numbers.
Biometric Data collected from drivers using Netradyne’s Driver.i will not be disclosed to parties other than Company or Netradyne, except in the following circumstances: (1) after Company obtains appropriate written consent from the driver(s); (2) when disclosure completes a financial transaction requested or authorized by the driver(s); (3) when disclosure is required by federal, state, or local law; or (4) when disclosure is required by a valid subpoena or warrant issued by a court. Within Company, the Biometric Data may be shared with only those who have a need to know for a specific business purpose.
Retention and Destruction of Biometric Data
Company will retain the Biometric Data during the time that an individual is employed or contracted with Company in a role for which the Netradyne Driver.i is used. At the conclusion of the employment or contractual relationship, or upon an employee’s or contractor’s transfer to a position for which the Netradyne Driver.i is not utilized, whichever occurs first, Company will permanently delete the Biometric Data that it retained. In any event, except for instances involving litigation or a valid court order, any Biometric Data will be permanently deleted within three years of the employee’s or contractor’s last contact with Company.
Consent Form
Before you begin or continue employment or a contract with Company in a role for which the Netradyne Driver.i is used, you must execute the Notice and Consent to Collection of Biometric Data form accompanying this Policy.
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