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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