FIELDPRINT, INC.

POLICY ESTABLISHING RETENTION SCHEDULE

AND

GUIDELINES FOR DESTROYING BIOMETRIC INFORMATION

Definitions

"Biometric information" means any information, regardless of how it is captured, converted, stored, or shared, based on an individual's biometric identifier used to identify an individual.

"Biometric identifier" means a fingerprint. Fieldprint, Inc. does not collect or use other types of biometric identifiers.

Retention Schedule

An individual's biometric information and biometric identifiers will be retained and stored by Fieldprint, Inc., and will be permanently destroyed when the initial purpose for collecting the information or identifiers has been satisfied or after three (3) years from the individual's last interaction with Fieldprint, Inc., whichever occurs first.

Guidelines For Destroying Biometric Information and Biometric Identifiers

Fieldprint, Inc. utilizes best practices when purging electronic biometric information and biometric identifiers and hard copy fingerprint cards. The sanitization method used will depend on the type of media and the intended disposition of the media. The process is to render access to target data on the media infeasible for a given level of recovery effort. We apply techniques such as those created by industry standards organizations. Electronic media may be purged of biometric information and biometric identifiers using steps such as: clearing/wiping, data purging, and physical media destruction. Hard or paper copies of fingerprints, which include biometric data, are destroyed via a National Association for Information Destruction (NAID) AAA-certified shredding company for destruction of media. We ensure that destruction of all physical and electronic media is witnessed or carried out by authorized personnel.

Absent a valid warrant or subpoena issued by a court of competent jurisdiction, Fieldprint, Inc. shall comply with the retention schedule and guidelines in this policy.