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Privacy Policy & Disclosure

BIOMETRIC INFORMATION PRIVACY POLICY

Loeber Motors, Inc., (“Loeber”) has instituted the following biometric information privacy policy.

Biometric Data Defined

As used in this policy, biometric data includes “biometric identifiers” and “biometric information” as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq., (“the BIPA”) which regulates the collection, storage, use and retention of “Biometric identifiers” and “Biometric information.” “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996.

“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 information does not include information derived from items or procedures excluded under the definition of biometric identifiers.

Purpose for Collection of Biometric Data

Loeber maintains the keys to its vehicles for sale, for lease, and loaners as well as and the keys to customer vehicles in key cabinets for safe-keeping. Loeber also maintains license plates within key cabinets. Access to these key cabinets is available by authorized Loeber personnel only through a key login pad which allows entry through stored information relating to the fingerprints of those personnel. AS A CONDITION OF YOUR EMPLOYMENT at Loeber, it is required that Loeber optically scan your fingerprints through the keypad to allow access in order that Loeber may track individuals entering the key cabinets to maintain control, accountability and the safety and security of Loeber’s and the customer’s vehicles and the license plates. The fingerprint reader component of Loeber’s biometric login key control is a computer based system that optically scans the fingerprint for purposes of identification. The computer system extracts unique data points and creates a unique mathematical representation used to verify the employee’s identity, for example here, when the employee accesses the key cabinets.

Loeber obtains this Biometric identifier of you as described in this notice, which we handle as stated in this notice. As a valued employee, we want to ensure your Biometric identifier is kept securely and shared with the vendor only as authorized either by yourself or as allowed or required by law. This document explains our Biometric Policy and your signing this document authorizes Loeber to use your Biometric identifier as described. PLEASE TAKE A MOMENT TO READ THIS ENTIRE POLICY.

Disclosure and Authorization

To the extent that Loeber through the biometric login key control system collects, captures, or otherwise obtains biometric data relating to an employee, Loeber must first:

  1. inform the employee in writing that Loeber is collecting, storing, or otherwise obtaining the employee’s biometric data and that Loeber may share this data with the vendor of Loeber’s login key control system to the extent the vendor has access to the system for purposes of diagnostics or service of the system;
  2. inform the employee in writing of the specific purpose and length of time for which the employee’s biometric data is being collected, stored, and used; and
  3. receive a written release signed by the employee (or his or her legally authorized representative) authorizing Loeber to collect, store, and use the employee’s biometric data for the specific purposes disclosed by Loeber, and for Loeber to share this data with the vendor of Loeber’s login key control system to the extent the vendor has access to the system for purposes of diagnostics or service of the system.

Loeber or its vendor of Loeber’s biometric login key control system will not sell, lease, trade, or otherwise profit from employees’ biometric data, provided, however, that Loeber’s vendor is paid for the biometric login key control system that utilizes such biometric data.

Disclosure

Loeber will not disclose, redisclose, or otherwise disseminate any biometric data to anyone other than its vendor of Loeber’s biometric login key control system without/unless:

  1. first obtaining written consent from the employee or their authorized representative’s to such disclosure, redisclosure, or dissemination;
  2. the disclosed or redisclosed data completes a financial transaction requested or authorized by the employee;
  3. disclosure is required by state or federal law or municipal ordinance; or
  4. disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction

Retention Schedule

Loeber will retain employee biometric data only until, and will request that its vendor of Loeber’s biometric login key control system permanently destroy such data when, the first of the following occurs:

  1. The initial purpose for collecting or obtaining such biometric data has been satisfied, which will be within six (6) months of the termination of the employee’s employment with Loeber, or the employee moves to a role within Loeber for which the biometric data is not used; or
  2. Within 3 years of the employee's last interaction with Loeber.

Data Storage

Loeber will use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic biometric data collected. Such storage, transmission, and protection from disclosure will be performed in a manner that is the same as or more protective than the manner in which Loeber stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as account numbers, PINs, driver’s license numbers and social security numbers.