Biometric Data Policy
Last updated: October 25, 2026 · Version 1.1
This policy explains how urCircl handles biometric data when you verify your identity. It supplements our Privacy Policy. "urCircl" means Raqs Enterprise LLC, a Pennsylvania limited liability company doing business as urCircl.
1. What we collect
To verify your identity, our provider Stripe, Inc. (through Stripe Identity) scans your government photo ID and captures a selfie, and uses facial-recognition technology to create a facial-geometry scan from the selfie and confirm it matches the ID. That facial geometry is a "biometric identifier" under laws including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), the Washington My Health My Data Act, and the Colorado and Connecticut privacy acts. We collect it only if you give consent on the screen shown before verification begins.
2. Why we collect it
The only purpose is to confirm that you are the person shown on the government ID you submit — i.e. to establish that a "verified" label on your account reflects a real identity check. We do not use biometric data for advertising, profiling, tracking, training models, or any purpose other than this identity check.
3. Who handles it
The biometric identifier is collected and processed by Stripe, Inc. (Stripe Identity) on urCircl's behalf, under a contract that limits Stripe to performing the verification. urCircl itself does not receive or store your ID images or your facial geometry; urCircl receives only the result of the check (pass/fail and basic ID fields such as name and date of birth).
4. How long we keep it (retention & destruction)
Stripe retains the biometric identifier (the facial-geometry data used for the match) for no longer than one year, or until you revoke your consent, whichever is earlier. The ID images and the non-biometric data extracted from them are retained by Stripe for up to three years under the retention period urCircl has configured in Stripe. When you delete your account or your verification, urCircl triggers Stripe's redaction of that verification data, which Stripe completes within a few days. These periods are within the maximum permitted by BIPA (destroyed when the purpose is satisfied or within 3 years of your last interaction, whichever is first). This paragraph is our retention and destruction schedule.
5. We never sell or profit from it
urCircl and Stripe do not sell, lease, trade, or otherwise profit from your biometric identifier. We do not disclose it to anyone except: (a) Stripe, to complete the identity verification you request; and (b) as required by state or federal law, municipal ordinance, or a valid warrant or subpoena — the grounds BIPA §15(d) permits. We never disclose it to lenders, borrowers, or other users.
6. Your consent, and declining
We ask for your written consent before any biometric identifier is collected, and we keep a record of the version you consented to and when. Identity verification is required to sign an agreement, but it is your choice: you may decline, and still use urCircl's record-only features. If you decline after previously consenting, you may withdraw consent and delete your data (Section 7).
7. Access and deletion
You can delete your verification data at any time from Account Settings, which triggers Stripe's redaction of the associated biometric identifier and ID data (Stripe completes redaction within a few days). Deleting it removes your "verified" status; you can verify again later if you choose. You may also email privacy@urcircl.com to exercise access or deletion rights, or privacy@stripe.com to ask Stripe to stop using your biometric data.
8. Security
Biometric data is encrypted in transit and at rest and is handled under urCircl's information security program (our Written Information Security Program / GLBA Safeguards policy). We use the same or a higher standard of care than we use for other confidential information, and never a lower one.
9. State-specific notices
Illinois (BIPA): we provide this written notice, obtain your written release before collection, and follow the retention/destruction schedule in Section 4; we do not sell or profit from your biometric identifiers. Texas (CUBI) and Washington: we obtain consent before capture and destroy the identifier within the time above. Colorado and Connecticut: biometric data is "sensitive data"; we process it only with your consent and only for the identity-verification purpose described here. Connecticut (SB 4): we disclose plainly that this verification uses facial-recognition technology to perform a one-time 1:1 match of your selfie to your ID; it is not used for surveillance, for identification in other photos, or to profile you.
10. Changes and contact
If we materially change this policy we will notify you and, where required, ask for renewed consent. Questions or requests: privacy@urcircl.com, or Raqs Enterprise LLC, c/o Republic Registered Agent LLC, 239 4th Ave, Ste 1401, Pittsburgh, PA 15222.