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Legal

Biometric Information Policy

Shown before the face-match liveness step (Screen 24). Written consent captured with a

checkbox + timestamp. Drafted against Illinois BIPA (740 ILCS 14), Texas CUBI, and Washington

HB 1493 — the strictest standards, applied to all members regardless of state.

What we collect and why

To keep Marlow verified-only, our identity partner (Persona/[Onfido]) captures:

— an image of your government ID, and

— a short live selfie video, from which a mathematical representation of your face

("face geometry" / biometric template) is derived.

The template is used for exactly two purposes:

1. Verification — confirming the person applying matches the ID; and

2. Re-verification — periodic liveness checks (roughly annually, or on suspicious activity)

so the pool stays real.

What we never do with it

— Never shown to other members. Never used in matching or the pairing algorithms.

— Never used to train AI models — ours or anyone's.

— Never sold, leased, traded, or otherwise profited from (a BIPA requirement we adopt

everywhere).

— Never disclosed except: to the verification processor under contract; with your further

consent; or when required by law or valid legal process.

Retention and destruction schedule

Your biometric template and ID images are permanently destroyed at the earliest of:

— successful completion of the verification purpose plus [12] months (kept only to speed

re-verification);

— your account deletion becoming final (7-day recovery window + processing); or

— 3 years after your last interaction with Marlow (BIPA's outer limit) —

whichever comes first. Destruction is certified by the processor and logged. [Counsel: confirm

Persona/Onfido default retention configs match this schedule.]

Your consent

By checking "I consent" you: (1) acknowledge you've read this policy; (2) consent in writing to

Marlow and its verification processor collecting, using, and storing your biometric identifiers

and biometric information as described; and (3) understand you may decline — in which case we

cannot verify you and cannot offer membership (verification is a core, non-waivable part of the

Service).

Withdraw consent any time by deleting your account (Privacy Dashboard), which triggers the

destruction schedule above.

Questions: privacy@marlowlove.com. This policy is publicly available and incorporated into the

Privacy Policy.

Draft — under legal review · legal@marlowlove.com