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Biometric Policy

Last updated: March 14, 2024

By using the Services, you consent to Keyo's collection, storage, and use of your Biometric Data in accordance with the terms of this Biometric Data Policy.

What is Biometric Data?

Biometric data is identifying information related to your biometric or physical characteristics that may be used to identify you. Examples of common forms of biometric data that you may use in your daily life include fingerprints, voiceprints, veins in your palm, facial recognition, and iris or retina recognition.

When Keyo talks about “Biometric Data”, we are referring to certain physical information we collect about you (such as your palm print or internal vein patterns in your hand) in order to identify you individually and provide you our resources and services through our Websites, applications, devices, and APIs (the “Services”).

How does Keyo collect your Biometric Data?

When you sign up for a Keyo account, you will provide certain Biometric Data at a Keyo kiosk. Keyo collects that Biometric Data and then encrypts and stores it on Keyo’s data servers, which Keyo will use to identify you when you want to use the Services. Keyo does not collect, capture, receive or otherwise obtain your Biometric Data without notifying you in writing in advance or without your consent or without the consent of your legally authorized representative. You may decline to provide your Biometric Data.

However, if you decline to provide Biometric Data, certain Services that require the use of such data will be unavailable to you. You may also experience a loss of functionality of some or all the Services that we provide.

Is your Biometric Data secure?

Keyo takes your Biometric Data security seriously. Keyo implements industry-standard data security technology to ensure that your Biometric Data is as secure as possible. We implement access controls and monitoring tools to ensure that only authorized personnel have access to sensitive data. Our commitment to safeguarding your information is reflected in our use of third-party secure data storage providers with a proven record of robust and reliable infrastructure adhering to industry-leading security standards. You can read our privacy policy here if you would like to see how we protect your Biometric Data.

How does Keyo use your Biometric Data?

To use the Services, for example when making a purchase at a point of sale, you will use an input device or kiosk designed to collect your Biometric Data, which will be encrypted and sent to Keyo. When you scan your palm at a device or kiosk, your scan will be compared with the Biometric Data you provided when you enrolled and signed up for your Keyo account. If it is a match, your transaction will be approved and your account will be charged for the purchase. Similarly, if you are seeking to access designated spaces through the Services, you will scan your palm at a device or kiosk to gain access to such spaces.

Will Keyo use your Biometric Data to enhance its services?

Keyo may use your Biometric Data to enhance its accuracy, services and products. This includes developing technologies and algorithms that work with images, video, and depth data. These technologies involve things like machine learning, algorithms, and other tools for things like focusing, color, contrast, classification, recognition, image processing, and immersive multi-media. By using Keyo's services, you agree to let Keyo use your Biometric Data for these purposes. You consent to such use of your Biometric Data, but Keyo does not sell, lease, or trade your Biometric Data to any third parties or derive any profit in such a manner.

Does Keyo share or sell your Biometric Data?

Keyo does not sell, lease, or trade your Biometric Data to any third parties or derive any profit in such a manner. Keyo may work with certain third parties to provide the Services to you, but only as necessary to provide you with such Services. Keyo has agreements with third parties that will receive your Biometric Data where the third party has a legitimate need to deliver the Services to you. These third parties are required to keep your Biometric Data secret and secure. We do not disclose, re-disclose or otherwise disseminate your Biometric Data without your request or consent or without the request or consent of your legally authorized representative. However, in certain specific instances, we may be compelled to disclose your Biometric Data in cases where such disclosure or re-disclosure is required by State or federal law, or municipal ordinance, or when required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

How long does Keyo keep your Biometric Data?

In order to deliver the Services to you, Keyo stores and uses your Biometric Data as long as you have an active account with Keyo. Your account is considered “active” so long as not more than one year has elapsed since your most recent access (unless you explicitly request an earlier closure of your account).

Occasionally your biometric data may not be readable or recognized when you scan your palm on a Keyo device. The attempted scan will be immediately discarded on those occasions and you will be required to scan your palm again.

How do I delete my Biometric Data from Keyo?

You may request that we delete your Biometric Data by notifying us at We reserve the right to maintain certain, limited non-biometric Personal Data that you provide for a period of up to five (5) years for purposes of maintaining legally required records for your various consents and authorizations.

What happens to your Biometric Data after you close your account?

After you close your account (or your account automatically closes, when it is deemed inactive), Keyo will keep your Biometric Data on file for a reasonable time of up to one year, for reasons including fraud prevention. Keyo will permanently destroy your Biometric Data on or before the one-year anniversary of the date that you cancel your account (or the one-year anniversary after the date that you last used your Keyo account). After your account is closed, you will need to re-enroll and provide your Biometric Data to Keyo again before you can use the Services.

If you consent to the terms in this Biometric Policy, you agree that the Federal E-Sign Act (the “Federal Act”) and the Illinois Uniform Electronic Transactions Act (UETA) controls with respect to any requirement of your consent in the form of a valid electronic signature.

You agree, understand, and give your consent by clicking the consent box to the Biometric Policy that your electronic signature is the legal equivalent of your manual/handwritten signature. You also give your consent to the use of your electronic signature.

In order to access and retain electronic communications, You will need a computer with an Internet connection; current “web browser” that includes 128-bit encryption with cookies enabled; a current version of Adobe Acrobat Reader to open documents in pdf format; a valid email address; and sufficient storage space to save past Communications or an installed printer to print them.


The Personal Information Protection Act, Arkansas Code §4-110-103(7) (2019 Amendment) includes Biometric Data which it defines as “Fingerprints; Faceprint; A retinal or iris scan; Hand geometry; Voiceprint analysis; Deoxyribonucleic acid (DNA); or Any other unique biological characteristics.”


Under the California Consumer Privacy Act (CCPA), Biometric Data is defined to include, among other things, physiological, biological or behavioral characteristics, including imagery of the hand, palm, and vein patterns from which identifying information can be extracted,


The Stop Hacks and Improve Electronic Data Security (SHIELD) Act (2019) provides that certain biometric information is private information and defines biometric information to include fingerprints, voiceprints, retina or iris images, or other unique physical characteristics.

You may contact Keyo, Inc. by emailing or by mail to:

Keyo, Inc.

111 North Wabash Avenue, Suite 100

Chicago, Illinois 60602

Last updated: March 14, 2024