Version 2026-11-03. This is the written, public policy of ZOI LABS LLC for biometric data processed by Zoi ID. It is also our retention schedule and destruction guideline for biometric identifiers and biometric information under the Illinois Biometric Information Privacy Act (740 ILCS 14), the Texas Business and Commerce Code section 503.001, Washington RCW 19.375, Colorado's biometric rules and similar laws in other places.
What biometric data we process
Only one thing: face geometry, measured by software from
- the photo of your face stored on your document (or printed on it),
- still frames of the short face video you record, and
- faces that appear in the short videos recorded while you photograph your document (to check that no one else takes part).
We use it for these three purposes only:
- 1:1 face comparison: to check that the person in the video is the person on the document.
- Liveness: to check that the video shows a real, present person (not a photo, a screen or a mask).
- One person, one account: when another verified account has the same name and date of birth, a 1:1 comparison with the face from that account's verification.
We do not search your face against all other faces, we do not build a face database, and we do not use your face to guess age, sex, ethnicity, emotion, health or any other trait.
Consent first
We process biometric data only after you choose "Check automatically" on the consent screen, in the app or on the hosted page. Before that choice we tell you, in writing, what we collect, why, and how long we keep it (this policy). Your tap is your written consent and release; we keep a record of it (time, policy version, language). The choice is optional: the other button, "Have a person check", is shown in the same way. With it a trained person compares the photos by eye and no software measures your face.
Templates are never stored
The numbers that describe a face (a "template" or "embedding") are created in memory, used for one comparison and discarded within seconds. They are never written to disk, a database, a log or a backup.
Retention and destruction schedule
| Item | Destroyed |
|---|---|
| Face templates | immediately after each comparison (seconds) |
| Face video, document capture videos and still frames | 90 days after the verification decision |
| Document photos and chip portrait | 90 days after the verification decision |
| All of the above when you withdraw consent or delete your account | at once (within 24 hours) |
| All of the above when you are under the minimum age | within 24 hours |
In every case we destroy biometric data no later than the earliest of: when the purpose is met, 90 days after the decision, or 1 year after your last interaction with us. A legal hold (a court order or an active legal claim) can pause destruction only for the data it covers and only while it lasts.
Destruction means the encrypted file is deleted and its encryption key is destroyed, so the data cannot be recovered. Backups roll over within 30 days and are also encrypted.
No sale, no disclosure
We never sell, lease, trade or otherwise profit from biometric data. We do not disclose it to anyone except:
- our hosting providers, which store it only in encrypted form;
- the person or company you verify for, only if you ask us to;
- when a law, a court order or a subpoena requires it.
How we protect it
Encryption in transit (TLS) and at rest (AES-256 with a separate key per file), access only for named and trained reviewers, a log of every access, and the same or better care than we use for our most sensitive business data.
Contact
ZOI LABS LLC, 26 Broadway, Suite 934, New York, NY 10004, USA, support@zoi.network.