Biometric Data Retention and Destruction Policy

This Biometric Data Retention and Destruction Policy (the “Policy”) describes how Wake Inc. (“Wake,” “we,” “us,” or “our”) retains and destroys biometric identifiers, biometric information, biometric data, and similar regulated biometric information that Wake collects, captures, receives, obtains, stores, or possesses in connection with contributor recordings and related data.

It sits alongside the Privacy Policy, which describes how Wake handles personal information generally, and the Contributor Agreement, under which contributors provide the consents and releases this Policy refers to.

For purposes of this Policy, “Biometric Data” means information derived from physical, biological, physiological, or behavioral characteristics, including facial features or geometry, voice characteristics or voiceprints, body geometry, gait, pose, movement patterns, or similar characteristics, but only to the extent such information constitutes a biometric identifier, biometric information, biometric data, or a similar regulated category under applicable law.

Ordinary photographs, video, or audio recordings are not treated as regulated biometric identifiers merely because they contain a person's image or voice, unless applicable law provides otherwise or regulated Biometric Data is derived from those recordings.

Wake may process Biometric Data for purposes including:

• creating, curating, annotating, validating, quality-controlling, and licensing datasets;
• researching, developing, training, fine-tuning, testing, evaluating, benchmarking, improving, and deploying artificial-intelligence, machine-learning, computer-vision, robotics, speech, and multimodal systems;
• generating annotations, embeddings, pose or movement estimates, feature representations, or other derived data;
• confirming compliance with collection requirements and detecting duplicate, fraudulent, unsafe, manipulated, or nonconforming submissions; and
• complying with legal obligations, enforcing agreements, and protecting Wake, contributors, participants, customers, and Wake's services.

Wake may disclose or transfer Biometric Data to its affiliates, service providers, contractors, customers, research partners, and other authorized recipients only for purposes consistent with the applicable Contributor Agreement, participant release, collection task, and applicable law. Wake will not sell, lease, trade, or otherwise disclose Biometric Data in a manner prohibited by applicable law.

Wake will retain Biometric Data only for as long as reasonably necessary to satisfy the purpose or purposes for which the data was collected, to complete an applicable collection task or dataset obligation, to maintain lawful records, to resolve disputes or enforce agreements, or as otherwise permitted or required by applicable law.

Where the Illinois Biometric Information Privacy Act applies, Wake's policy is to permanently destroy the applicable biometric identifiers and biometric information when the initial purpose for collecting or obtaining them has been satisfied or within three (3) years of the individual's last interaction with Wake, whichever occurs first, unless a different period is permitted or required by applicable law.

If another applicable law requires a shorter retention period, Wake will follow the shorter period. An applicable collection task may also specify a shorter retention period.

When retention is no longer permitted or necessary, Wake will use reasonable measures designed to permanently delete, destroy, or render unreadable the applicable Biometric Data in Wake's possession or control, taking into account the nature of the systems in which it is stored and any legally required backup, security, or audit processes.

Deletion from Wake's systems does not necessarily require deletion of information lawfully provided to a third-party recipient before the deletion obligation arose, or removal of information already incorporated into a trained model, unless applicable law requires such deletion, recall, or model-related remediation.

Wake will use reasonable administrative, technical, and organizational safeguards appropriate to the sensitivity of the data. Where applicable law imposes a specific standard for storage, transmission, or protection of Biometric Data, Wake will apply that standard.

Wake will not purchase, receive through trade, or otherwise obtain Biometric Data in violation of applicable law. Wake will not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information where applicable law prohibits such conduct. This restriction does not prevent Wake from receiving compensation for lawful services, datasets, licenses, or other deliverables that include or are derived from contributor content where permitted by law.

Individuals may contact Wake at legal@wake.inc regarding this Policy or to exercise rights available under applicable law. Wake may need to verify the requester's identity and authority before acting on a request.

Wake may update this Policy to reflect changes in law, technology, or processing practices. Where applicable law requires notice or renewed consent before a material change may apply to previously collected Biometric Data, Wake will provide that notice or obtain that consent before applying the change.