Biometric Information Privacy Policy

This Biometric Information Privacy Policy describes how Quigley Oats, LLC collects and uses certain Biometric Information, defined as all personal information you provide when registering to join as a member of one of our properties (websites), including ‘facial recognition’ that digitally captures the unique features of your face to aid in identifying you for subsequent use of Services we provide.

Please carefully review this Biometric Information Privacy Policy prior to consenting to our collection and use of your Biometric Information. Please note that once you agree to “allow” use of your webcam, your permission has been granted for us to collect and process your personal Biometric Information as part of our identity verification process, it may not be rescinded or revoked where it is required to complete the transaction for which it was collected, or to complete the verification Services from that point on.

Additionally, by consenting to the collection and use of your Biometric Information you acknowledge that you have been read and agree to be bound by the Terms of Use and the Privacy Policy. References to “properties” means websites owned by Quigley Oats, LLC that bear the Quigley brand.

1. What is Biometric Information?

Biometric Information is that information you voluntarily provide to us when registering to join as a member of one of our properties (websites), an includes ‘voice recognition’ that digitally captures the unique tonal qualities of your voice, as well as ‘facial recognition’ that digitally captures the unique features of your facial characteristics, either or both of which we will use to identify you. Common examples of biometric information may include facial recognition, fingerprints, voiceprints, scans of a hand, scans of the iris or retina recognition, etc. As used in this policy, Biometric Information includes any “biometric identifiers” or “biometric information” as defined under applicable law.

2. What Biometric Information Do We Collect?

We collect and preserve information that you provide to us when you register and ask to become a member of our site. We also collect and preserve a digital copy of your facial geometry using our “Facial Recognition” log-in. We also collect and preserve digital recordings of your voice when you use any feature on our website that records a voice. Use of the services provided by Quigley Oats, LLC through one of its properties requires you to provide all of that information that we will then use to identify you to help protect our other members. Other services, such as those requiring a NIST 800-63A IAL2 credential (eg, the Internal Revenue Service (IRS), Office of Veterans Affairs (VA), certain state unemployment or labor departments) may require a higher level of assurance to verify your identity. When you sign up for an applicable Quigley Oats, LLC service, we collect facial biometrics at the time you initially log In which is required if you want to gain complete access to all our services. As long as you are a member of one of our properties, that digital image of your face will be retained in our databases for use when you return and log-in, or when you engage in a financial transaction. We may also require you to upload an image of identification document(s) issued by a governmental entity or accredited educational institution that contain(s) a photographic image of your face. You could also provide a “selfie” photograph using your mobile or other device. We use such images to create an electronic facial geometric ‘print’ (a faceprint) that we use for purposes of identity verification, and to prevent the creation of multiple accounts in a fraudulent manner.

3. How Do We Use Your Biometric Information?

We use your Biometric Information only as follows:

• To verify your identity when you join one of our properties as a member to use our Services;
• To authenticate use of your account and our Services for financial transactions;
• To prevent fraudulent uses of our dating services or the creation of multiple accounts; and
• To comply with legal obligations or comply with a request from law enforcement or government entities where not prohibited by law.

4. Do We Share or Disclose Your Biometric Information?

Quigley Oats, LLC will only share your Biometric Information in the following circumstances:

• with our other Quigley properties (websites) you join for dating purposes;
• as required with third parties where permitted by law to enforce our Terms of Use,
• to comply with legal obligations, to cooperate with law enforcement agencies concerning conduct or activity that we reasonably believe may violate federal, state, or local law when required by a subpoena, warrant, or other court ordered legal action, and to prevent harm, loss or injury to others.
• to third-party service providers that perform functions on our behalf. These service providers are limited to using the Biometric Information to assist us in providing our Services, and must maintain any Biometric Information we share in a secure fashion.

5. Do We Sell Your Biometric Information?

Quigley Oats, LLC will not sell, rent, trade or transfer your Biometric Information. Your Biometric Information will only be used by Quigley Oats, LLC to verify your identity in accordance with the guidelines published by the National Institute for Standards and Technology or as required for the prevention of fraud, and in accordance with the purposes set forth elsewhere in this document and our properties. In fulfilling our Services to you, Quigley Oats, LLC will transfer your Biometric Information to a third-party only when required by a subpoena, warrant, or other court ordered legal action.

6. How Long Does Quigley Oats, LLC Retain My Biometric Information?

Quigley Oats, LLC may retain your Biometric Information for up to thirty-six months (3 years) beyond the date you terminate your membership. Quigley Oats, LLC collects and processes your Biometric Information in order to verify your identity, protect your personal data, and to help prevent fraud. Biometric Information is retained in line with Quigley Oats, LLC’s obligations to our members, other Quigley properties, our business partners, and with specific retention periods determined by the first partner with whom a user first verifies their identity (e.g., IRS, Dept. of Veterans Affairs, a state workforce agency, etc). Certain partners may require this information to be purged within twenty-four (24) hours following a successful verification, other partners may require a longer retention period, but under no circumstances will Quigley Oats, LLC retain this information for longer than thirty-six (36) months beyond the date you terminate your membership, absent a subpoena, warrant, or other legally compelling justification to retain it longer.

For Quigley Oats, LLC members who are residents of Illinois, in accordance with Illinois state law Quigley Oats, LLC will retain Biometric Information only until the occurrence of the first of the following: (a) The initial purpose for collecting or obtaining such Biometric Information has been satisfied; or (b) Three (3) years following your last interaction with Quigley Oats, LLC’s.

7. What Does Quigley Oats, LLC do with my Biometric Information?

One of the most important features of all Quigley Oats, LLC properties (our websites) is the safety and protection of our members through our member identity confirmation process. We believe ours are the safest dating sites on earth, where all members of our properties can feel more comfortable as they interact with other members. Most of our properties that are intended for heterosexuals are especially protective of members who identify as female. On our LGBTQ+ sites, we provide the same level of protection for all genders. To work toward better ensuring the safety of our members, we require sufficient proof that a member is who they claim to be. To that end, for those who become members and want to engage in the full use of our services, we require you to use our Facial Recognition (FR) software. A digital photograph of your face allows us to obtain from you a reasonable likeness of your facial features that begins the process of individualizing you from all other members. That FR is used each time you log in to our website, and is instrumental in protecting you against others accessing your personal information and biographical data. Your identity is further confirmed through (1) a secondary government issued driver’s license or other government or state issued ID that contains a photograph of your face and current residential information; (2) use of standard electronic ‘cookies’ that verify the location of your IP address / residence address / geopolitical GPS positioning / or zip code you provide with your profile; (3) your unique Username that ‘connects’ each of these to you. If there is any discrepancy, your membership is flagged until your identification can be sufficiently verified. Quigley Oats, LLC reserves the right to retain any and all such images and other personal information as needed even after your membership ends to comply with our legal obligations, including warrants, subpoenas or other court orders, to help prevent fraud, and to ensure that your identifying information is available in the event a member of the opposite sex files a legal claim of a civil or criminal nature that alleges to involve you as an adverse party. NONE of your biometric data is provided to any person or entity except the single Quigley property where your membership is.

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), residents of California are entitled to additional rights and disclosures regarding their Personal information, including Biometric Information. Please see our Notice to California Residents for additional details regarding these disclosures and how to exercise your rights.

8. Can I refuse to provide My Biometric Information?

Yes, you may refuse to consent to our collection of your Biometric Information as well as the use of our Facial Recognition software. However, if you refuse to consent, we will not be able to verify your identity at the required level of assurance to protect other members, and you will therefore not be able to use all of our Services. You will have access to the website and links in the header and footer, and you will be able to set up your own personal profile. That means you can complete the questionnaire for use in your personal Bio, you can upload a video and five photos to your public profile, and even populate your Private Vaults with private photos and videos. Other members will be able to see your profile image and username, access your public profile and bio, and can subscribe to either of your Private Vaults from which you will be able to gain a financial benefit. You will be able to see the profile photos and usernames of other members on The Wheel, but you will NOT be able to contact any of them. You will not be able to search for members using any search criteria, you will not be able to send flirts to other members, nor may other members send you flirts to which you can reply. No communication is permitted from you with any other member. Essentially, you will be “seen but not heard”. We do this because the safety and security of our members is one of our main priorities, and that means being able to identify our members with a reasonable degree of accuracy.

Alternate pathways to verification may be available. Quigley Oats, LLC may provide an alternate pathway for you to verify your identity. Instead of providing consent for the collection and use of your Biometric Information, you may be presented with the option to speak with one of our Trusted Referees on a recorded video that will capture and retain your facial images and voiceprints. Providing a valid photo ID will also be required. This alternate method of verification satisfies the NIST 800-63A IAL2 requirements. You may then use our facial recognition log-in and will then be given full access to our website.

9. What Kind of Storage and Security Do You Use With My Biometric Information?

We are committed to protecting your information. We have adopted technical, administrative, and physical security procedures to help protect your information from loss, misuse, unauthorized access, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure.

We employ appropriate security safeguards. To safeguard certain sensitive information (such as Biometric Information and government-issued identification information), we implement security measures such as encryption, firewalls, and intrusion detection and prevention systems.

10. Changes

This Biometric Information Privacy Policy may be periodically updated. From time-to-time we may update this policy to reflect changes in our Personal Information practices or services, or adding new features or services. We will post a notice for users at the top of our Privacy Policy page to address any significant changes.

For further clarification, you may contact us via our “Contact Us” page on our website.

NOTE: SEE ALSO “Not Using FR = Limited use of website” doc