Privacy

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Effective Date: June 2023

Effective Date: June 2023

BIOMETRIC INFORMATION PRIVACY POLICY AND CONSENT

Scope and Overview

This policy outlines how RVA Financial, its vendors, and/or the licensor of the RVA Financial’s consumer verification software processes biometric data collected from you for identity verification and fraud prevention purposes.

Biometric Data Defined

As used in this policy, biometric data includes “biometric identifiers” and “biometric information”. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. As the term is used in this policy, the selfie photograph you upload to the software for use in the biometric algorithm is considered a “biometric identifier.” “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.

Disclosure and Authorization Policy

To the extent that RVA Financial, its vendors, and/or the licensor of the RVA Financial’s consumer verification software collect, capture, or otherwise obtain biometric data relating to a consumer, RVA Financial must first:

Inform each consumer that RVA Financial, its vendors, and/or the licensor of the RVA Financial’s consumer verification software are collecting, capturing, or

otherwise obtaining the employee’s biometric data, and that the RVA Financial is providing such biometric data to its vendors and the licensor of the RVA Financial’s consumer verification software;

Inform the consumer of the specific purpose and length of time for which the

consumer’s biometric data is being collected, stored, and used; and

Receive consent by the consumer authorizing RVA Financial, its vendors, and/or RVA Financial’s consumer verification software to collect, store, and use the consumer’s biometric data for the specific purposes disclosed by the RVA Financial, and for RVA Financial to provide such biometric data to its vendors and the licensor of the RVA Financial’s consumer verification software.

RVA Financial, its vendors, and/or the licensor of the RVA Financial’s consumer verification software will not sell, lease, trade, or otherwise profit from

employees’ biometric data; provided, however, that the RVA Financial’s vendors and the licensor of the RVA Financial’s consumer verification software may be paid for products or services used by RVA Financial that utilize such biometric data.

This policy is intended to comply with all federal, state, and local laws.

Purpose for the Collection of Biometric Data

RVA Financial, its vendors, and/or the licensor of RVA Financial’s consumer verification software collect, store, and use biometric data solely for identity verification and fraud prevention purposes.

Disclosure

RVA Financial will not disclose or disseminate any biometric data to anyone other than its vendors and the licensor of the RVA Financial’s consumer verification software providing products and services using biometric data without/unless:

First obtaining consumer consent to such disclosure or dissemination;

The disclosed data completes a financial transaction requested or authorized by the consumer;

Disclosure is required by law or ordinance; or

Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Security

RVA Financial shall use a commercially reasonable standard of care to store, transmit and protect from disclosure any biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which RVA Financial stores, transmits and protects from disclosure other confidential and sensitive information, including personal

information that can be used to uniquely identify an individual or an individual’s account

or property, such as genetic markers, genetic testing information, account numbers,

PINs, driver’s license numbers and social security numbers.

Retention

RVA Financial shall retain consumer biometric data only until, and shall request that its vendors and the licensor of RVA Financial’s consumer verification software permanently destroy such data when, the first of the following occurs:

The initial purpose for collecting or obtaining such biometric data has been satisfied, such as verification of consumer identity;

Request of consumer to destroy the biometric data; or

Within 30 days of consumer’s provisioning of biometric data.

Contact Information

If you have any questions about our use, storage, or security of your biometric data you can contact us at: service@rvafinancial.com.

BIOMETRIC INFORMATION CONSUMER CONSENT

As outlined in the “Biometric Information Privacy Policy”, I understand and consent to the collection, use, retention, storage, and/or disclosure or re-disclosure of data or images from biometric verification technology by RVA Financial, its vendors, and/or the licensor of the RVA Financial’s consumer verification software. I acknowledge that I have been given a copy of the Policy, or that the Policy has been made accessible to me, and I have had an opportunity to review it and request any additional information concerning the RVA Financial’s procedures and safeguards for collecting, maintaining, using, disclosing, sharing, storing, and/or destroying this data.