BIOMETRIC DATA COLLECTIONAND RETENTION POLICY

  • SVB Express (“SVB”) may collect, store, and use Biometric Data for certain purposes described below, and it may disclose that Biometric Data in certain circumstances. This Policy explains what that means for you, and how you consent to SVB’s activities.

    Definitions

    “Biometric Data” as used in this Policy includes both: (i) “Biometric Identifiers”, meaning a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits. Biometric Identifiers do not include writing samples, written signatures, photographs, human biological samples used for scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color; and (ii) “Biometric Information”, meaning any information, regardless of how it is captured, converted, stored, or shared, that is based on Biometric Identifiers, including a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, that is used to identify an individual.

    Data Collection and Purpose
    SVB uses Motive’s AI Dashcam system (“AI Dashcam”). The AI Dashcam system includes both a road-facing camera and an inward facing camera to capture video footage of critical events. AI Dashcam uses certain artificial intelligence techniques and detection models on the data collected from the cameras to provide analysis, including event and object recognition, of driver performance and other safety and efficiency objectives.
    Certain data collected from AI Dashcam may be considered Biometric Data under Illinois law. AI Dashcam, and the related technology and processing techniques, allows SVB to use this Biometric Data to confirm that the AI Dashcam dash cameras are not obstructed or blocked, analyze driving and driver performance, improve customer service, optimize efficiency, improve safety, use for legal or litigation purposes and defense, analyze risk and to analyze harsh driving events. Using the features on AI Dashcam enhances safety by increasing the efficacy of the AI Dashcam driver-based insights, improve driver safety and efficiency, and helps SVB to maintain accurate logs of our operations.
    The data collected from AI Dashcam will be disclosed to Motive and stored on Motive’s cloud servers which are accessible through a Motive account. Motive will have access to the Biometric Data to perform the functions of its services agreement with SVB. A copy of the Motive privacy policy is available at https://gomotive.com/legal/privacy/ and Biometric Data Collection Policy is available at https://gomotive.com/legal/biometric-data-collection-policy/.

    Data Storage, Protection and Disclosure Policy

    SVB’s policy is to protect and store Biometric Data in accordance with applicable laws and regulations, including, but not limited to, the Illinois Biometric Information Privacy Act. Specifically, SVB shall use a reasonable standard of care to store, transmit, and protect from disclosure any Biometric Data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which SVB stores, transmits, and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual such as social security numbers.

    Any Biometric Data collected from drivers using AI Dashcam will not be disclosed to parties other than SVB or Motive, except in the following circumstances: (1) after SVB obtains appropriate written consent from the driver(s); (2) when disclosure completes a financial transaction requested or authorized by the driver(s); (3) when disclosure is required by federal, state, or local law; or (4) when disclosure is required by a valid subpoena or warrant issued by a court. Within SVB, the Biometric Data may be shared with only those employees who have a need to know for a specific business purpose.

    Retention and Destruction of Biometric Data
    SVB will retain any Biometric Data collected using AI Dashcam during the time that an individual is employed with SVB in a role for which AI Dashcam is used. Within a reasonable time following the conclusion of the employment relationship, or upon an employee’s transfer to a position for which AI Dashcam is not utilized, whichever occurs first, SVB will permanently delete the Biometric Data that it retained. In any event, any Biometric Data will be permanently deleted within three years of the driver’s last contact with SVB. Absent a valid warrant or subpoena issued by a court of competent jurisdiction, SVB will comply with this retention schedule and destruction guidelines.

    Consent Form
    Before you begin or continue your employment with SVB in a role for which Motive’s AI Dashcam is used, you must execute the Notice and Consent to Collection of Biometric Data form accompanying this Policy.



    4905-0948-7713, v. 2

  • SVB Express (“SVB”) may collect, store, and use Biometric Data for certain purposes described below, and it may disclose that Biometric Data in certain circumstances. This Policy explains what that means for you, and how you consent to SVB’s activities.
    Definitions
    “Biometric Data” as used in this Policy includes both: (i) “Biometric Identifiers”, meaning a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits. Biometric Identifiers do not include writing samples, written signatures, photographs, human biological samples used for scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color; and (ii) “Biometric Information”, meaning any information, regardless of how it is captured, converted, stored, or shared, that is based on Biometric Identifiers, including a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, that is used to identify an individual.
    Data Collection and PurposeSVB uses Motive’s AI Dashcam system (“AI Dashcam”). The AI Dashcam system includes both a road-facing camera and an inward facing camera to capture video footage of critical events. AI Dashcam uses certain artificial intelligence techniques and detection models on the data collected from the cameras to provide analysis, including event and object recognition, of driver performance and other safety and efficiency objectives.Certain data collected from AI Dashcam may be considered Biometric Data under Illinois law. AI Dashcam, and the related technology and processing techniques, allows SVB to use this Biometric Data to confirm that the AI Dashcam dash cameras are not obstructed or blocked, analyze driving and driver performance, improve customer service, optimize efficiency, improve safety, use for legal or litigation purposes and defense, analyze risk and to analyze harsh driving events. Using the features on AI Dashcam enhances safety by increasing the efficacy of the AI Dashcam driver-based insights, improve driver safety and efficiency, and helps SVB to maintain accurate logs of our operations.
    The data collected from AI Dashcam will be disclosed to Motive and stored on Motive’s cloud servers which are accessible through a Motive account. Motive will have access to the Biometric Data to perform the functions of its services agreement with SVB. A copy of the Motive privacy policy is available at https://gomotive.com/legal/privacy/ and Biometric Data Collection Policy is available at https://gomotive.com/legal/biometric-data-collection-policy/.
    Data Storage, Protection and Disclosure Policy
    SVB’s policy is to protect and store Biometric Data in accordance with applicable laws and regulations, including, but not limited to, the Illinois Biometric Information Privacy Act. Specifically, SVB shall use a reasonable standard of care to store, transmit, and protect from disclosure any Biometric Data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which SVB stores, transmits, and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual such as social security numbers.
    Any Biometric Data collected from drivers using AI Dashcam will not be disclosed to parties other than SVB or Motive, except in the following circumstances: (1) after SVB obtains appropriate written consent from the driver(s); (2) when disclosure completes a financial transaction requested or authorized by the driver(s); (3) when disclosure is required by federal, state, or local law; or (4) when disclosure is required by a valid subpoena or warrant issued by a court. Within SVB, the Biometric Data may be shared with only those employees who have a need to know for a specific business purpose.
    Retention and Destruction of Biometric DataSVB will retain any Biometric Data collected using AI Dashcam during the time that an individual is contracted with SVB in a role for which AI Dashcam is used. Within a reasonable time following the conclusion of the contractual relationship, or upon a contractor’s transfer to a position for which AI Dashcam is not utilized, whichever occurs first, SVB will permanently delete the Biometric Data that it retained. In any event, any Biometric Data will be permanently deleted within three years of the driver’s last contact with SVB. Absent a valid warrant or subpoena issued by a court of competent jurisdiction, SVB will comply with this retention schedule and destruction guidelines.
    Consent FormBefore you begin or continue your contract with SVB in a role for which Motive’s AI Dashcam is used, you must execute the Notice and Consent to Collection of Biometric Data form accompanying this Policy.

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