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