Team Clarity, Inc. DBA Iron Gorilla Biometric Information Privacy and Retention Policy

This Policy applies when Team Clarity directly collects, captures, purchases, receives through trade, or otherwise obtains a biometric identifier or biometric information for its own determined purpose. It does not authorize a customer to submit biometric data and does not replace a customer's own notice, consent, retention schedule, or legal obligations.

1. Covered Data

Depending on applicable law, biometric data may include a retina or iris scan, fingerprint, voiceprint, scan of hand or face geometry, facial template, or data generated from measurement or technological processing of physiological, biological, or behavioral characteristics that identifies or can be used to identify a person. Ordinary photographs, audio recordings, writing samples, and demographic descriptions may be excluded under some laws unless processed to create an identifier or template.

2. Written Notice and Consent

Before collecting a covered biometric identifier, Team Clarity will provide a specific written notice describing the data, purpose, length of collection and use, disclosures, retention, and destruction. Team Clarity will obtain the legally required written release, informed consent, or other authorization before collection. Consent to general Terms or a broad privacy policy does not replace a specific biometric consent where specific consent is required.

3. Purpose Limitation

Team Clarity will use biometric data only for the purpose stated in the notice and consent, for security and fraud prevention reasonably related to that purpose, or as otherwise permitted by law. We will not use biometric data to infer health, race, ethnicity, disability, emotion, religion, sexual orientation, immigration status, or another highly sensitive trait unless a signed agreement, explicit consent, and applicable law expressly permit the specific use.

4. No Sale or Profit

Team Clarity will not sell, lease, trade, or otherwise profit from a person's biometric identifier or biometric information. We will not use biometric data for targeted advertising or general AI-model training.

5. Disclosure

Team Clarity will not disclose or disseminate biometric data unless the person or authorized representative consents, disclosure completes a transaction requested or authorized by the person, disclosure is required by a valid warrant or other law, or another statutory exception applies. A processor receiving biometric data must be bound by written confidentiality, security, purpose, retention, deletion, and non-sale restrictions.

6. Security

Team Clarity will store, transmit, and protect biometric data using a reasonable standard of care and in a manner at least as protective as the manner in which Team Clarity protects other confidential and sensitive information. Controls should include strict access limitation, encryption where appropriate, segregation or pseudonymization, audit logging, incident response, vendor review, and prohibition on placement in logs, analytics, support tickets, or unapproved model-provider paths.

7. Retention and Destruction Schedule

Unless a shorter period is required by law or the specific consent, Team Clarity will permanently destroy a biometric identifier and associated biometric information when the initial purpose for collecting or obtaining it has been satisfied or within three years after the person's last interaction with Team Clarity, whichever occurs first. Where Texas law applies, destruction will occur within a reasonable time and no later than one year after the collection purpose expires. A narrowly tailored legal hold may delay deletion only to the extent required by law, after which destruction will occur promptly.

8. Customer-Submitted Biometric Data

Customers may not submit biometric identifiers through the Services unless a signed Biometric and Consumer Health Data Addendum and activation schedule authorizes the exact data, purpose, feature, region, retention, and subprocessors. The customer is responsible for notices, releases, consents, employment or labor requirements, and lawful collection. Team Clarity acts only in the role identified in the signed addendum.

9. Rights and Contact

A person may contact legal@teamclarity.ai to ask whether Team Clarity directly maintains covered biometric data, withdraw consent where applicable, request deletion, or raise a concern. Team Clarity will respond as required by applicable law and verify identity before disclosing or deleting sensitive data.