Purpose: This document details how Avant utilizes biometric information such as fingerprints, palm prints, hand and face geometry and other biometric identifiers in a variety of contexts. This Biometric Information Policy (“Policy”) defines Avant’s policy and procedures for collection, use, safeguarding, storage, retention and destruction of such data.

Applicability & Scope: Unless otherwise prohibited by state law, either directly or through a third-party vendor, Avant collects, stores, and uses biometric information for the specific purposes of identity verification and fraud prevention in connection with product applications. 

Biometric Information Defined: As used in this policy, biometric information includes personal information, regardless of how it is captured, converted, stored, or shared, that is based on an individual’s physical characteristics that can be used to identify that individual. Biometric information can include fingerprints, palm prints, voiceprints, retina scans, scans of hand or face geometry, or other data. 

Policy: Avant will protect and store biometric information in accordance with applicable industry standards and laws and will use such data solely for the purposes outlined herein.  

Avant will not sell, lease, trade, or otherwise profit from an individual’s biometric information. Avant will share individuals’ biometric information with its affiliates, contractor(s), subcontractor(s), or agent(s) of any identity verification vendors whose access to that information is required for business purposes, including to provide services to Avant. Avant will not collect an individual’s biometric information or share such information with any third party other than those described in this policy without the written consent of the individual unless:

• The disclosed data completes a financial transaction requested or authorized by the individual; or
• Disclosure is required by federal, state or local municipal laws; or
• Disclosure is required pursuant to a valid order, warrant or subpoena issued by a court of competent jurisdiction.

Avant maintains biometric information in accordance with Avant’s Record Retention Schedule, but in no event for a period longer than one year after an individual’s application is completed, unless a longer retention period is required or permitted by law. This retention period ensures that Avant is able to comply with its legal obligations and business interests in preventing fraud. When this period expires, Avant will permanently destroy biometric information and will request that its service providers in possession of biometric information permanently destroy such data. 

Finally, Avant will use a reasonable standard of care to store, transmit and protect from disclosure any collected paper or electronic biometric information. Such storage, transmission, and protection from disclosure will be performed in a manner that is consistent with the manner in which Avant 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.