Biometric Data Policy & Notice

1. Purpose

Phenom and its affiliates (“Phenom”) have adopted this Biometric Data Policy and Notice (this "Policy") to govern the treatment of Phenom's and our customers' job applicants' Biometric Data in the United States of America.

2. Definitions

"Biometric Data" means collectively all Biometric Identifiers and Biometric Information. 

"Biometric Identifier" means unique physical characteristics like retina or iris scans, fingerprints, voiceprints, and scans of hand or face geometry.

"Biometric Information" means information, regardless of how it is captured, converted, stored, or shared, that is based on a Biometric Identifier used to identify an individual.

"Fraud Detection Agent" is a Phenom product aimed at protecting hiring integrity by surfacing for manual human review signals of identity mismatch, AI-assisted responses, behavioral anomalies, document/profile tampering from post-application through post-interview or other indicators of fraudulent candidate behavior. 

3. Biometric Data Collection and Use

When Phenom’s Fraud Detection Agent is being used, either by Phenom in its own recruitment activities or by Phenom’s customers, Phenom collects, stores, and uses voiceprints (recordings and analyses of an individual's voice) and scans of facial geometry (still images of an individual's face) for the purposes of verifying the identity and identifying fraudulent candidate behavior. 

4. Biometric Data Disclosures

Phenom may disclose Biometric Data to its third-party vendors and/or licensees to facilitate our provision of the Fraud Detection Agent. 

Phenom only discloses an individual’s Biometric Data if:

• The individual or the individual's legally authorized representative consents to the disclosure;

• The disclosure is required or allowed by applicable law or regulation; or

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

Phenom does not sell, lease, trade, or otherwise profit from Biometric Data. 

5. Biometric Data Retention and Destruction Guidelines 

In circumstances where Phenom retains Biometric Data, Phenom will only retain such Biometric Data until the initial purpose for collecting or obtaining such Biometric Data has been satisfied or within three years of collection, whichever occurs first, unless a longer retention period is required or permitted by law.

Phenom will destroy or dispose of Biometric Data as required by applicable law. 

6. Biometric Data Security

Phenom uses commercially reasonable organizational, technical, and administrative methods designed to protect Biometric Data within its organization. 

For any questions, please contact: legal@phenom.com.

Last Updated:  Mar 6, 2026