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STARK EM LLC BIOMETRIC DATA POLICY

Last updated: August 19, 2026

This document (this “Policy”) sets forth the policy and procedures of Stark EM, LLC (“Stark”) with respect to the collection, use, and retention of biometric data through facial verification or other software (the “Software”).

Biometric Data Defined

As used in this Policy, biometric data includes “biometric identifiers” and “biometric information.” “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.

Stark’s Collection & Use of Biometric Data

Stark will collect, retain, and use biometric data for the purpose of verifying the identity of individuals in connection with and/or as a condition to their performing services for one or more Stark customers (each, a “Customer”), as well as for access to certain locations in connection with such services, safety and security, timekeeping, and fraud prevention purposes. Both Stark and the applicable Customer may have access to such biometric data. To the extent required by law, Stark will obtain your informed consent before collecting, using, or retaining your biometric data.

Safeguarding & Storage

In circumstances where Stark retains biometric data, Stark will use a reasonable standard of care to store, transmit, and protect it from disclosure. Storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which Stark stores, transmits, and protects from disclosure other confidential and sensitive information used to uniquely identify an individual. Stark is committed to protecting such biometric data and has adopted technical, administrative, and physical security procedures to help protect such biometric data from loss, misuse, unauthorized access, and alteration, including encryption, firewalls, and intrusion detection and prevention systems. Please note that no data transmission or storage can be guaranteed to be 100% secure.

Retention & Destruction

Stark will permanently destroy any biometric data, and will request that the applicable Customer permanently destroy any biometric data, when the initial purpose for collecting or obtaining the data has been satisfied, or within a reasonable period following the individual’s last interaction with the Software, whichever occurs first, unless a longer period is permitted under applicable law or regulation.

This Policy may be periodically updated. From time-to-time Stark may update this Policy to reflect new features or changes in its practices or procedures. Stark will post a notice for users at the top of this Policy addressing any significant changes. If you have any questions about this Policy, please contact us at please contact us at https://www.starkrfid.com/contact/.