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Biometric Information Privacy Act Policy

Biometric Information Privacy Act Policy

Policy Purpose:
Sage, its affiliates, related entities, and managed businesses (“Company”) collect certain Biometric Data
(defined below) from associates. This document explains what information the Company collects, how
this information is used, how it is stored, safeguarded, retained, and disposed of.

Definitions:
Biometric timeclocks are computer-based systems that scan an associate's Biometric Data for purposes
of identification. The computer system extracts unique data points and creates a unique mathematical
representation used to verify the associate's identity.


Keyless entry systems provide secure access to areas of Company worksites by scanning an associate’s
Biometric Data for purposes of identification. The computer system extracts unique data points and
creates a unique mathematical representation used to verify the associate's identity.


Biometric Data, including biometric identifiers and biometric information, means a retina or iris scan,
fingerprint, voiceprint, or scan of hand or face geometry (or information derived therefrom), regardless
of how it is captured, converted, stored, or shared, which is used to identify an individual (collectively,
“Biometric Data”).


Purpose of Collection:
In furtherance of providing efficient and accurate payroll as well as provide secure access to areas of
Company worksites, the Company collects and stores your Biometric Data in connection with its
biometric time clocks and keyless entry systems.


Privacy of Biometric Data:
The Company may disclose your Biometric Data to the Company’s third party vendors for processing the
Company’s payroll or operation of keyless entry systems. The Company and its third party vendors will
not sell, lease, trade, or otherwise profit from your Biometric Data. The Company and its third party
vendors will not otherwise disclose, redisclose, or otherwise disseminate your Biometric Data unless
permitted by law.


Retention Schedule:
In the event of the separation of your employment with the Company and/or the Company ceases to
use biometric time clocks (or, if applicable, keyless entry systems), the Company will destroy the
relevant Biometric Data in its possession upon the separation of employment and/or the Company
ceasing to use biometric time clocks (or, if applicable keyless entry systems), whichever occurs first.

Data Storage:
At all times applicable to this policy, the Company will employ at least a reasonable standard of care
with respect to your Biometric Data, and in no event will the Company utilize a standard of care that is
less than the standard of care that the Company applies to other confidential or sensitive information.

 

A copy of this Policy is posted in the workplace and is available upon request.

The Company will consider reasonable accommodations to this Policy as required by law.