AceHR · Legal & privacy
Biometric Information Privacy Policy
Our public policy for biometric identifiers and biometric information, including our retention schedule and destruction guidelines. AceHR does not create or store facial templates.
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1. Purpose and scope
This policy explains how Ace HR Associates, Inc. (“AceHR”) handles biometric identifiers and biometric information in connection with the AceHR Services. It is our publicly available written policy under the Illinois Biometric Information Privacy Act (740 ILCS 14/15(a)), and it is designed to meet Texas Business and Commerce Code § 503.001, Washington RCW 19.375, the biometric provisions of the Colorado Privacy Act and other state laws that treat biometric data as sensitive.
In this policy, “biometric data” means biometric identifiers (such as a scan of face geometry) and biometric information (information based on a biometric identifier and used to identify a person), as applicable law defines those terms. Several of these laws exclude photographs and video or audio recordings unless they are used to extract identifying measurements. We describe recordings below for transparency.
2. When biometric data may be involved
AceHR does not create or store facial templates, faceprints or voiceprints. The activities below are the only ones in the Services that may involve biometric data, and they happen only in assessments where the hiring company enables them.
| Activity | What happens | Who processes it | Stored by AceHR? |
|---|---|---|---|
| On-device face analysis during proctored assessments | A model in the candidate’s browser locates facial landmarks to estimate face presence, the number of faces, head orientation and approximate gaze direction. | AceHR software running on the candidate’s own device. | No. The detector’s measurements are discarded immediately; it sends only event observations, such as “gaze away for 6 seconds”. |
| Object detection during proctored assessments | A model in the browser detects a phone or another person in view. It does not measure face geometry. | AceHR software on the candidate’s device. | No. Only event observations are sent. |
| Identity verification, if the hiring company requires it | Persona compares the face in a selfie with the photo on a government ID to confirm identity. Where an assessment uses Stripe Identity instead, Stripe does the same. | Persona Identities, Inc. (or Stripe, Inc.), in its hosted flow, as a service provider. | No. AceHR receives only the result status and a verification reference. |
| Assessment and interview recordings | Camera, microphone and screen recordings for human review; explanation audio is transcribed into text. | AceHR (storage), OpenAI (transcription) and Retell AI (interview calls). | Recordings are kept until their retention period ends, but no face or voice templates are extracted from them and they are not used to identify anyone. |
3. Notice and written release
Before any biometric data is collected, we inform the individual in writing that it will be collected or processed, of the specific purposes, and of how long it will be kept, and we obtain a written release. In AceHR assessments, the candidate reads this information and signs the release electronically by typing their full name, and we record the notice version, the name and the time. The identity provider (Persona, or Stripe where an assessment uses it) also presents its own notice and obtains its own consent before its face match.
Candidates may decline and request a human alternative without automatic penalty. The release is also written to serve as the signed waiver Maryland requires before facial recognition is used during an interview (Md. Code, Lab. & Empl. § 3-717). The hiring company remains responsible for any additional notice or consent that its own obligations require.
4. Purposes
We use biometric data only to (a) support the integrity of skills assessments, by noting for a human reviewer when a candidate’s face is not visible, more than one face appears, or the candidate looks away for a sustained time; and (b) verify a candidate’s identity when the hiring company requires it.
We do not use biometric data for any other purpose, including marketing, advertising, profiling, emotion or personality analysis, monitoring employees, or identifying people in recordings.
5. No sale or profit
AceHR does not sell, lease, trade or otherwise profit from biometric data, and our agreements do not permit our service providers to do so.
6. Disclosure
AceHR does not receive or hold biometric data, so it does not disclose any. Candidates provide their ID images and selfie directly to the identity provider (Persona, or Stripe where an assessment uses it) in its hosted flow, with their consent, and hiring companies receive only the verification result, never biometric data.
If AceHR ever held biometric data, it would disclose it only with the individual’s consent, to complete a transaction the individual requested or authorized, when required by federal, state or local law, or in response to a valid warrant or subpoena.
7. Retention schedule and destruction guidelines
Biometric data is kept only as long as needed for the purpose for which it was collected. It is permanently destroyed when that initial purpose has been satisfied, and never later than the earliest of:
- 45 days after we determine that keeping it is no longer necessary, adequate or relevant to that purpose (Colorado);
- one year after the purpose for collecting it expires (Texas);
- 24 months after the individual’s last interaction with AceHR or the hiring company through the Services (Colorado); and
- 3 years after the individual’s last interaction with AceHR or the hiring company through the Services (Illinois).
| Data | When the purpose is satisfied | How it is destroyed |
|---|---|---|
| Facial measurements from on-device analysis, and the frame copies analyzed | As each frame is analyzed, in real time during the assessment. | Held only in the browser’s memory and discarded immediately. They are never stored or transmitted. |
| ID images, selfie and face-match data held by the identity provider (Persona, or Stripe) | When the provider has returned the verification result and the hiring company has completed its identity review for that assessment. | AceHR requests that the provider permanently delete (redact) the verification within the deadlines above. The provider may keep limited records where the law requires it. |
Records that are not biometric data, such as the signed release, the verification result and event observations, stay with the assessment record under the hiring company’s retention settings. We review at least once a year whether any biometric data is still needed. If a valid warrant, subpoena or legal hold requires us to keep data, we keep it only as long as required. Individuals may ask us to arrange deletion sooner, as described below.
8. Storage, protection and security incidents
We protect biometric data using a reasonable standard of care for our industry, and in a manner at least as protective as the way we protect other confidential and sensitive information. On-device analysis runs in an isolated browser worker using model files served by AceHR, and its results never leave the device except as event observations. Identity verification data is held by the identity provider (Persona, or Stripe where an assessment uses it) in its own systems, and AceHR does not receive it. Connections are encrypted in transit, and verification results are available only to authorized reviewers at the hiring company.
If a security incident may compromise biometric data, we will investigate and contain it and notify affected individuals, customers and regulators as the law requires.
9. Hiring company responsibilities
Hiring companies decide whether to enable proctoring and identity verification. They must enable these features only where lawful, give any additional notices and obtain any additional consents their own obligations require, offer accommodations and alternatives, and never use AceHR or its outputs to collect biometric data for any other purpose.
10. Your choices and requests
You may decline the release and request a human alternative instead. To ask a question, request information, or ask us to arrange earlier deletion of identity verification data, email acehrassociatesinc@gmail.com with the subject “Biometric request” and the name of the hiring company. We will respond and coordinate with the hiring company and the identity provider. Your other privacy rights are described in our Privacy Policy.
11. Changes
We will update this policy if our biometric practices change, and we will obtain any new release the law requires before collecting biometric data for a new purpose.