Biometric Data Policy

Version 2026-11 · Effective November 2, 2026

ShiftThru is a time clock, scheduling and team chat service run by Next Infra LLC ("ShiftThru", "we", "us"). Businesses that use ShiftThru ("employers") can choose to let their employees clock in with face scan on a ShiftThru kiosk. This policy explains what biometric data face scan uses, why, how it is protected, how long it is kept and when it is destroyed. It is written to meet the Illinois Biometric Information Privacy Act (740 ILCS 14, "BIPA") and similar laws in other states.

1. What biometric data we handle

When an employee sets up face scan, the kiosk's camera measures the shape of their face and turns it into a face template: a list of numbers that describes facial geometry. Under BIPA this is a "biometric identifier" and "biometric information" (together, "biometric data").

• We do not keep photos or video. The camera image is processed on the kiosk device itself and is not uploaded or stored.
• Only the face template is sent to our servers, over an encrypted connection.
• We do not collect fingerprints, voiceprints, retina or iris scans, or hand geometry.

2. Why we use it

Face templates are used for one purpose only: to confirm an employee's identity when they clock in, clock out, or start or end a break at their employer's kiosk, which helps prevent one person from clocking in for another. They are not used for marketing, profiling, surveillance, or any other purpose.

3. Consent comes first

No face template is created until the employee has given written consent. Before setting up face scan, the kiosk shows the employee, in writing:

• that biometric data (a face template) will be collected and stored;
• the specific purpose it is used for;
• how long it will be kept and when it will be destroyed;
• that face scan is optional, and that saying no changes nothing else about their job or how they clock in.

The employee signs by typing their full name and tapping I agree, or chooses No thanks, I'll use my PIN. We keep a record of each choice: the exact wording shown and its language, the typed name, date and time, the kiosk device, and the version of this policy. The employer can view and print these signed consent records at any time. The record of consent is kept even after the face data itself is destroyed. If this policy changes in a way that matters, employees are asked to consent again.

4. How long we keep it, and when it is destroyed

A face template is permanently destroyed at the earliest of these:

1. the employee withdraws their consent;
2. the employee no longer works for that employer (the employer deactivates them in ShiftThru);
3. the employer turns off face scan and leaves it off for 30 days, or closes their ShiftThru account;
4. 3 years after the employee's last use of face scan.

Withdrawn consent, a person leaving (being deactivated), and a closed account are handled immediately and automatically. Face scan left off for 30 days, and 3 years since last use, are handled by an automatic check that runs every day. Destroyed means the template is erased from our live systems; encrypted backups roll off within our normal backup period and are never restored to use a destroyed template.

5. How we protect it

• Face templates are encrypted at rest with a key kept separately from the database, and encrypted in transit.
• Each employer's data is kept separate. Templates can only be used by that employer's own kiosks, and the same face cannot be enrolled for two different employees.
• Kiosks must be set up with a key from the employer, and the employer can switch off any kiosk at any time.
• Access inside ShiftThru is limited to systems and people who need it to run the service.
• We protect biometric data with at least the same care we use for other confidential and sensitive information, consistent with reasonable industry standards.

6. We never sell it, and rarely share it

We do not sell, lease, trade, or otherwise profit from biometric data. We do not disclose it to anyone except:

• the service providers that host ShiftThru for us (for example, our database host), only to store and process it on our behalf, under confidentiality and security obligations;
• when the employee (or their legal representative) consents to the disclosure;
• when required by law, a valid warrant or subpoena, or to complete a financial transaction the employee requested.

We will not share biometric data with an employer's other vendors, advertisers, or data brokers.

7. Employee choices and rights

• Say no. Face scan is always optional. Employees can clock in with their employee ID and PIN instead.
• Change your mind. To withdraw consent, tell your manager. Your face template is destroyed as soon as it is withdrawn in ShiftThru.
• Ask questions or request deletion. Ask your employer, or email us at info@shiftthru.com.

8. Employers' responsibilities

ShiftThru provides face scan as a tool. Each employer that turns it on decides whether to use it and is responsible for meeting the biometric laws that apply to their workplace. Before turning on face scan, an employer agrees to:

• make this policy (or its own policy that is at least as protective) available to employees;
• let employees choose ID and PIN instead, without any penalty;
• use ShiftThru's built-in written consent, or collect equivalent written consent, before any employee enrolls;
• deactivate employees in ShiftThru promptly when they leave, so their data is destroyed;
• follow any additional notice or consent rules in their state or city.

9. Other states

Several other places also regulate biometric data, including Texas, Washington, Colorado and New York City. This policy's consent, purpose, retention and destruction rules apply to every ShiftThru customer, wherever they are.

10. Changes to this policy

If we change this policy, we will post the new version here with a new version number and date. If a change affects how biometric data is used or kept, employees will be asked to consent to the new version before face scan continues for them.

Contact

Next Infra LLC (ShiftThru), Brandon, Florida, USA · info@shiftthru.com