Privacy | BioTone

BioTone Corporation (“BioTone,” “we,” “us,” or “our”) respects your privacy. This Privacy Notice (“Notice”) describes the processing of Personal Information (defined below) that is provided, collected, or disclosed while providing our products or services to you (“Services”) and on our website, mobile application, and other online platforms that link to this Notice (collectively, the “Platform”). It also describes rights you may have under applicable laws. Please read this Notice carefully to understand our policies and practices regarding your Personal Information and how we will treat it.

Before enrolling in the Services, you may be required to confirm your location, and you are responsible for providing accurate information regarding your location. The current store-distributed mobile app is for adults aged 18 or older in the United States. Enrollment is not available in Illinois, Texas, Washington, the European Union, the European Economic Area, or the United Kingdom.

Personal Information We Collect

“Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The categories of Personal Information we collect may include:

Contact Information – If you submit an inquiry, register for an account, or provide information on or through our Platform or Services, we may collect your contact information including your name, mailing address, email address, and phone number.
Commercial Information – If you submit an inquiry or provide information on our Platform, we may collect commercial information including information about Services you have shown interest in.
Usage Information – When you use our Platform, we may automatically record information, including your Internet Protocol address (IP address), device and operating system information, app version, timestamps, and information regarding your interaction with our Platform. If enabled by an organization and permitted by you, the Services may also collect approximate location information.
Communication Information – We may collect Personal Information contained within your communications with us via email, social media, telephone, or otherwise, and in certain cases we may use third-party service providers to do so.
Biometric and Biometric-Related Information – When you enroll in or use biometric verification, we may collect or generate biometric identifiers and information, including information derived from your physical, biological, or behavioral characteristics. We may also collect information used to verify your presence or confirm that a biometric sample is authentic. For more information about how we process biometric information, please see the Biometric Information section below.
Account Information – If you create an account or use the Services through an organization, we may collect account identifiers such as your username, organization affiliation, user role or permissions, and related account information.

Our website contact form also collects your organization, inquiry details, selected interests, and referral information such as campaign tags and landing page. The receiving service records the request’s IP address and browser information. The website stores your appearance preference in your browser. External font and media providers receive technical request information when your browser loads those resources.

How We Collect Personal Information

Directly From You – We collect Personal Information that you provide to us directly, for example, when you create an account, enroll biometric factors, respond to a verification request, contact us, request information, or otherwise use our Platform or Services.
From Third Parties – We may collect Personal Information from third parties, including organizations that invite or authorize you to use the Services, business and integration partners, enterprise identity systems, cloud, hosted API, and edge infrastructure providers, app stores and mobile platform providers, data analytics providers, and other service providers. Where a Living Key implementation is used, this may also include separate key holders or infrastructure providers supporting that architecture.

How We Use Personal Information

To the extent permitted by applicable law, we use Personal Information:

To provide our Platform and Services, including providing biometric verification and related functionality, maintaining accounts, supporting customer and organizational use of the Services, providing customer service, maintaining business records, and providing similar services.
To optimize, improve, and maintain our Services, including understanding how users interact with our Services, gauging user interest in certain Services or Platform functionality, and troubleshooting problems.
For internal research and development, such as testing, verifying, and improving the quality of our Services or developing new ones. We do not use your Personal Information to train or improve models used in our products unless you separately consent to that use. Where a separate research-upload feature is offered, any upload of biometric captures for benchmarking or model improvement will be subject to separate notice and consent and may be disabled by default in production or release builds.
For marketing and advertising, including sending you messages, notices, newsletters, surveys, promotions, or event invitations about our own Services that may be of interest to you. We do not use biometric identifiers or biometric information for advertising. You can unsubscribe from marketing emails or text messages by following the instructions included in the communication or by contacting us at contact@biotonebiometrics.com.
For communicating with you, such as responding to your questions and comments or notifying you of changes to our Platform or Services.
For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.

How We Disclose Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose your Personal Information with your consent or in the following circumstances:

Employees and Other Personnel – We may share Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
Service Providers – We disclose Personal Information to service providers that support our business and Services, including cloud and website hosting providers, mobile platform providers, security providers, analytics providers, customer support providers, and other technology providers. Where a Living Key implementation is used, this may include separate key holders or infrastructure providers supporting that architecture.
Organizations and Business Partners – We may disclose Personal Information to organizations that you choose to interact with through the Services and to business and integration partners that help provide or support the Services. The Personal Information disclosed may include account or organization information, verification results, and related transaction or activity information.
Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of BioTone, its employees and clients, or the public against harm.
Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.
Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Biometric Information

Collection and Use

When you enroll in or use our biometric verification Services, we collect or generate biometric identifiers and biometric information, including biometric templates or other information derived from your physical or behavioral characteristics. We use this information to provide identity verification, authentication, fraud prevention, liveness or presence detection, and related security functionality.

In the current store-distributed mobile app, raw biometric images and recordings are processed on your device to generate biometric templates or other derived information used for verification. Temporary capture files are used during processing, and the app attempts to delete them after processing and when you leave the capture screen. Raw captures are not uploaded through the app’s research-upload feature, which is disabled in production builds. Separate research and website demonstration features may upload images you choose to submit, as described in their own notice and consent.

BioTone uses a technology called Living Key to protect biometric templates. In the current mobile implementation, encrypted biometric templates are stored on your device. Shares of the encryption key are held by your device and separate key holders. The distributed shares protect the encryption key; they are not fragments of the biometric template itself. Verification requires participation of the applicable Living Key components.

We do not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. We do not use biometric identifiers or biometric information for advertising. We will not disclose or otherwise disseminate biometric identifiers or biometric information except with your consent or as otherwise permitted or required by applicable law.

This September 29 clarification describes existing data practices and does not enable new processing. Version 1.0.12 (27) retains the September 22, 2026 in-app consent notice and records consent under that notice; this website update does not mean that you have given new consent.

Face and Eye Information in the Mobile App

In BioTone Biometrics version 1.0.12 (27), the app does not collect TrueDepth depth maps or ARKit face-tracking geometry; its face and eye processing uses ordinary color camera images. BioTone processes ordinary color (RGB) camera images of your face and eye region on your device. This processing includes detecting a face, estimating head position and eye openness, checking your presence and responses to verification challenges, and generating and comparing eye-region biometric descriptors. We use this information for enrollment, identity verification, presence checks, and related security functionality. Eye-region templates are encrypted and stored on your device, with the Living Key services participating in protection of the encryption key as described above.

Some information derived from this processing leaves your device. BioTone’s hosted service receives verification records that can include each signal’s pass or fail outcome, comparison distance and threshold, combined verification score, failure details, subject and session identifiers, and device and client context. We use these records to provide the verification service, support authentication records, and troubleshoot failures. Organizations you use the Services with may receive verification results and related activity information as described under “How We Disclose Personal Information.”

We use Bugsnag as a crash and diagnostic service provider. Diagnostic reports can include error information, user identifiers and technical context, together with diagnostic breadcrumbs recording verification steps, pass or fail outcomes, comparison distances and thresholds, and whether a step is a liveness check. Sampled camera diagnostics can include frame dimensions, the number of detected faces, and, when available, an estimated iris radius, the iris-detection source, and a pupil-detected indicator. These diagnostic fields describe processing and results; they are not raw camera images or biometric templates.

Temporary face and eye capture files are subject to the on-device processing and attempted deletion practices described above. The app’s research-upload feature is disabled in production builds. This does not prevent the transmission of verification records or diagnostic information described here. Retention and deletion of local templates, hosted verification records, diagnostic information, and organization records are described under “Security and Retention” and “How Long We Keep Your Personal Information.”

Notice and Consent

Where required by applicable law, before collecting, storing, or capturing biometric identifiers or biometric information, we will inform you that such information is being collected, stored, or captured, identify the specific purpose and length of time for which it will be collected, stored, and used, and obtain any written release or other consent required by applicable law.

Security and Retention

We store, transmit, and protect biometric identifiers and biometric information using a reasonable standard of care and in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other confidential and sensitive information.

The following controls apply to BioTone Biometrics version 1.0.12 (27), the replacement build prepared for App Review. In that version, use Home → Reset my data to withdraw biometric consent and delete the active profile’s local biometric templates and device-held key material. This does not delete all profiles or your account: profile contact metadata and a nonsecret deletion-request receipt are retained. Local withdrawal does not depend on successful remote revocation. Home → Privacy and deletion requests shows the request status and reference, provides an email contact, and allows a retry for the same organization. Remote deletion requests are recorded for follow-up. Accepting a request or marking its workflow status completed does not itself erase all related remote records or backups and is not, by itself, confirmation that every copy has been deleted. Benjamin Portman personally handles BioTone privacy and deletion requests through contact@biotonebiometrics.com. Uninstalling the app alone is not a reliable way to remove information stored in the device’s secure storage. Local deletion does not by itself confirm deletion of remote shares, account records, or backups. You can request deletion of information held by BioTone by contacting contact@biotonebiometrics.com.

These practices are subject to applicable legal retention and destruction requirements. Where required by applicable law, BioTone will destroy biometric identifiers and biometric information when the purpose for collection has been satisfied or within another applicable statutory period, including, as applicable, no later than one year after the purpose expires or three years after your last interaction with BioTone.

Research Use

Separate research or testing programs may involve different biometric data practices from those described above. If you voluntarily participate in such a program, BioTone may collect, upload, retain, or use raw biometric captures for research, testing, benchmarking, or product development purposes. We will provide additional information about the applicable program and obtain your separate consent before collecting or using biometric information for these purposes. Any biometric information collected through a research or testing program will be retained and deleted as described in the applicable research notice or consent.

How Long We Keep Your Personal Information

We retain Personal Information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Notice, comply with our legal obligations, resolve disputes, and enforce our agreements. The retention period depends on the type of Personal Information and the purpose for which it is processed. Our current retention practices include:

Raw Biometric Captures – In the current store-distributed mobile app, temporary raw biometric images and recordings are used during on-device processing. The app attempts to delete these files after processing and when you leave the capture screen. Separate research or demonstration uploads are governed by the notice and consent presented for that feature.
Living Key Shares and Biometric Template Information – In version 1.0.12 (27), “Reset my data” removes the active profile’s local biometric templates and device-held key material; profile contact metadata and a nonsecret request receipt remain. Remote deletion requires communication with the corresponding service. Contact us to request deletion of information held by BioTone. The biometric destruction requirements described above apply where required by law.
Hosted Verification Records – Verification records, including face- and eye-related outcomes, scores, identifiers, and device or session context, are retained for the service, security, troubleshooting, and recordkeeping purposes described in this Notice, subject to applicable deletion rights and legal obligations. Resetting local biometric data does not automatically delete these hosted records. Contact us to request deletion of information held by BioTone.
Account and Contact Information – We retain account and contact information while your profile remains active or as otherwise necessary to provide the Services, respond to inquiries, and fulfill the purposes described in this Notice, subject to applicable deletion rights and legal obligations.
Crash and Diagnostic Information – Crash reports and diagnostic information, including the face- and eye-related diagnostic fields described above, may be retained by Bugsnag and other applicable service providers in accordance with their retention periods and our configuration of those services. Contact us to request deletion of information held by BioTone or processed on our behalf.
Consent Records – We may retain records of your consent, including information identifying the version of the applicable notice, policy, or consent presented to you, for as long as reasonably necessary to document compliance with applicable law.
Organization Records – If you use the Services through an employer or other organization, that organization may independently retain authentication records, audit logs, or other Personal Information in accordance with its own policies and legal obligations. Deleting information from your device or BioTone’s systems does not necessarily delete information independently maintained by that organization.

We may retain Personal Information for a longer period where required or permitted by applicable law.

Website Ad Measurement

Website measurement update: October 20, 2026. We use campaign parameters to understand which ads lead to SDK inquiries. These parameters and the original landing path are retained in this browser tab for up to 30 minutes and included with an inquiry you send to BioTone. They are separate from the biometric processing described above.

Google Ads measurement is optional. Google’s tag loads only after you select “Allow measurement.” When allowed, Google may receive ad-click identifiers, cookie identifiers, the page address, IP address and browser information, and an event indicating that an SDK inquiry succeeded. We do not send your name, organization, email, form answers or biometric data in the conversion event. Enhanced conversions and personalized advertising are disabled.

You can decline without affecting the form, or change your choice using “Ad measurement choices” in the website footer. We remember the choice for up to 180 days. We honor a browser’s Global Privacy Control by declining this optional measurement. Withdrawing permission stops new conversion events and clears this site’s advertising cookies; it does not delete information Google previously received. See how Google uses information from partner sites.

Third-Party Links and Services

We are not responsible for the privacy practices of third-party websites, applications, or services linked to or accessible through our Platform, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy policy.

International Use

If you access or use our Platform from outside the United States, please note that your Personal Information may be processed and stored in the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Notice.

How We Protect Personal Information

We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.

Exercising Your Privacy Rights

Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws, subject to certain exceptions:

Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
Deletion – The right to delete your Personal Information that we have collected or obtained.
Correction – The right to request that we correct any inaccuracies in your Personal Information.
Opt Out of Certain Processing – The right to opt out of certain processing of your Personal Information, including processing for targeted advertising, the sale of Personal Information, or certain profiling. We do not sell Personal Information or use or disclose it for targeted advertising, so we do not offer an option to opt out of those activities. Disclosures to service providers and organizations are described above.
Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right, depending on your location, to consent or opt out of (a) this automated decision-making or (b) any profiling in furtherance of decisions that produce legal or similarly significant effects. The Services generate verification results that an organization may use in access or approval decisions. The organization controls its own access policies and decisions. Contact us about BioTone’s processing, and contact the organization about its decisions or available review process.
Lodge a Complaint – The right to lodge a complaint with a regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

In addition to any rights available to you under applicable law, you have certain choices regarding how you use the Services. You may decline device permissions or choose not to enroll certain biometric factors, although doing so may prevent certain features or verification functionality from working. In version 1.0.12 (27), you may withdraw biometric consent and delete the active profile’s local biometric templates and device-held key material as described above. You may also leave an organization you previously joined through the Services, where that functionality is available. Contact us to request deletion of other information held by BioTone.

Deleting information from your device or uninstalling the app does not necessarily delete Personal Information independently maintained by an organization with which you used the Services, such as records of prior authentication activity. You should contact the applicable organization regarding information it maintains.

To exercise any of the privacy rights afforded to you under applicable data protection laws, please email us at contact@biotonebiometrics.com.

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, should you choose not to provide certain Personal Information, we may be unable to provide some, or all, of our Services to you.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. We may need to verify your identity before fulfilling certain requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making certain requests on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

Children’s Privacy

The current store-distributed mobile app is intended for adults aged 18 or older. We do not knowingly collect or solicit Personal Information from children. If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you believe we might have information from or about a child, please contact us at contact@biotonebiometrics.com.

Changes to this Notice

Please note that we may modify or update this Notice from time to time, so please review it periodically. If we make material changes to how we treat Personal Information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Notice will apply when the updated Notice is made available through our Platform. You are responsible for periodically visiting this Notice to check for any changes.

Contact Us

If you have any questions about our practices or this Notice, please contact us at contact@biotonebiometrics.com.