Biometric Information Privacy Policy

Goldmax Carrier Inc. (“Goldmax,” “we,” “us,” or “our”) uses biometric-enabled timekeeping technology provided by TimeTrak Systems, Inc., including TimeTrakGo, for the limited purpose of accurately recording the working hours of certain independent contractors and supporting accurate payment for services performed.

Goldmax is committed to protecting biometric information and complying with applicable biometric privacy laws, including the Illinois Biometric Information Privacy Act, 740 ILCS 14/1 et seq. (“BIPA”).

1. Biometric Information We May Collect

Depending on the TimeTrakGo device or system configuration being used, the system may collect information derived from an individual's face or fingerprint for purposes of verifying the individual's identity when clocking in or clocking out.

The system may create a biometric template or other mathematical representation derived from the biometric identifier. Goldmax does not use biometric information for surveillance, marketing, advertising, or any unrelated purpose.

2. Purpose of Collection

Goldmax uses biometric information solely for legitimate timekeeping and payment-related purposes, including:

• Verifying the identity of a contractor when clocking in or clocking out;
• Accurately recording hours worked;
• Preventing inaccurate or unauthorized time entries;
• Maintaining reliable timekeeping records; and
• Calculating and verifying payments for services performed.

Biometric information will not be used for any purpose unrelated to these functions unless permitted by law and appropriate consent has been obtained.

3. Notice and Consent

Before Goldmax collects, captures, obtains, or otherwise uses an individual's biometric identifier or biometric information, Goldmax will provide the individual with written notice describing the collection and its purpose and will obtain any written consent or release required by applicable law.

Participation in biometric timekeeping will be handled in accordance with applicable legal requirements.

4. Disclosure of Biometric Information

Goldmax does not sell, lease, trade, or otherwise profit from an individual's biometric identifiers or biometric information.

Goldmax will not disclose or disseminate biometric information except:

• To TimeTrak Systems, Inc. and service providers involved in operating, maintaining, securing, or supporting the TimeTrakGo timekeeping system;
• When the individual has provided consent to the disclosure;
• When disclosure is required by federal, state, or local law; or
• When disclosure is required pursuant to a valid warrant, subpoena, or other lawful court order.

Biometric information is not provided to customers, brokers, advertisers, data brokers, or other third parties for marketing or commercial resale.

5. Biometric Information Retention Schedule

Goldmax retains biometric information only for as long as reasonably necessary to accomplish the purpose for which it was collected.

The purpose for collecting a contractor's biometric information is considered satisfied when the contractor no longer uses TimeTrakGo for Goldmax timekeeping purposes and any related timekeeping and payment processing for that contractor has been completed.

At that time, Goldmax will initiate the permanent deletion of the contractor's biometric information from systems under Goldmax's control and, where applicable, instruct TimeTrak Systems, Inc. to discontinue retention of the contractor's biometric information.

In all cases, Goldmax's retention and destruction practices are intended to ensure that biometric identifiers and biometric information are permanently destroyed no later than required by applicable law, including BIPA's requirement that such information be destroyed when the initial purpose for collecting or obtaining the information has been satisfied or within three (3) years of the individual's last interaction with Goldmax, whichever occurs first.

6. TimeTrakGo Data Retention

Goldmax uses TimeTrak Systems, Inc. as its biometric timekeeping technology provider.

According to TimeTrak's current Biometric Data Privacy Policy, when biometric technology is used, the system may generate an encrypted biometric template used to recognize an individual. TimeTrak states that original high-resolution biometric images are not permanently stored by the device after creation of the biometric template.

When Goldmax determines that biometric information is no longer required, Goldmax will use the available TimeTrak tools and procedures to initiate deletion and, when applicable, notify TimeTrak of the discontinuation of biometric services for the individual.

TimeTrak currently states that it may retain biometric data for up to ninety-three (93) days after receiving notice from a customer regarding discontinuation of the applicable TimeTrak products or services, after which TimeTrak will permanently destroy the biometric data in its possession unless retention is required pursuant to a valid warrant, subpoena, or other legal obligation.

Goldmax will periodically review TimeTrak's policies and procedures to ensure that its own biometric retention practices remain consistent with applicable law.

7. Storage and Protection

Goldmax will use a reasonable standard of care to store, transmit, and protect biometric identifiers and biometric information from unauthorized disclosure or access.

Biometric information will be stored, transmitted, and protected using safeguards that are the same as or more protective than those used by Goldmax to protect other confidential and sensitive information.

Where TimeTrakGo hosts or processes biometric information on Goldmax's behalf, Goldmax relies on the security measures maintained by TimeTrak Systems, Inc. for the applicable service.

8. Permanent Destruction

When biometric information reaches the end of the applicable retention period, Goldmax will take reasonable steps to permanently destroy biometric identifiers and biometric information within Goldmax's possession or control and will initiate appropriate deletion procedures with TimeTrak or other service providers possessing the information on Goldmax's behalf.

Goldmax will comply with its established retention schedule and destruction procedures unless retention is otherwise required or permitted by applicable law, court order, warrant, or subpoena.

9. Policy Updates

Goldmax may update this Biometric Information Privacy Policy from time to time to reflect changes in applicable law, technology, service providers, or company practices.

The current version of this policy will be made publicly available on Goldmax's website.

10. Contact

Questions regarding this Biometric Information Privacy Policy or Goldmax's collection, use, retention, or destruction of biometric information may be directed to:

Goldmax Carrier Inc.
Elmhurst, Illinois
compliance@goldmaxcarrier.com / (630) 616-4114