Biometric Data Retention Policy

Scope

This Biometric Data Retention Policy (“Biometric Retention Policy”) describes how long Toptal, LLC (“Toptal”) will retain Biometric Data (defined below).

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Purpose

As stated in our privacy policy, if you are asking to be admitted to our network of professional freelancers (“Network”), with your explicit written informed consent (which you may provide at the time of submitting a request to be admitted) we may collect biometric information about you to verify and confirm your identity and as further described below. We may ask you to take a photo of yourself and of your government-issued identification through your mobile phone (the “Verification Data”).

The Verification Data will be provided to our biometric technology service provider (Mitek Systems, Inc. – “Mitek”), who will use facial recognition technology to analyze the geometry of your face through the photographs and extract biometric information or biometric identifiers relating to you (collectively, “Biometric Data”). Toptal will not receive the Biometric Data but will only receive scores that will indicate the authenticity of the government-issued identification, whether your identity has been verified and confirmed, and your name from your government-issued identification. For more information on how Mitek may handle your Verification Data or Biometric Data, please review Mitek’s website and privacy policy.

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Retention Schedule

Once the scores that will indicate the authenticity of your government-issued identification and whether your identity has been verified and confirmed are returned to Toptal, Mitek will not retain and will permanently delete your Biometric Data. As noted above, Toptal will not receive the Biometric Data. In no event will Biometric Data be retained for longer than the purpose described above, or three years from your last interaction with Toptal, whichever is earlier.

Unless required by law to maintain any specific Biometric Data for longer than the above retention schedule, Mitek will securely delete Biometric Data according to this schedule rendering it no longer available for inspection or access.

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Contacting Toptal

If you have questions about this Biometric Retention Policy, please see our privacy policy to learn how to contact Toptal.