1. Purpose


Tropical Sun Corp. d/b/a Clips4Sale ("Clips4Sale") has adopted this biometric data policy and notice (this "Policy") to govern the treatment of our users' Biometric Data. Protecting the confidentiality and integrity of Biometric Data is a critical responsibility that must be taken seriously. Compliance with this Policy is mandatory.


2. Scope


This Policy applies to all Clips4Sale employees, agents, and representatives, including any contractor or third-party service provider to Clips4Sale ("Third-Party Service Provider") who have access to Biometric Data for Clips4Sale. This Policy applies to all Biometric Data collected, maintained, transmitted, stored, retained, or otherwise used by Clips4Sale regardless of the media on which that information is stored and whether relating to users.


3. Definitions


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


"Biometric Identifiers" means:


  • Retina or iris scans.
  • Fingerprints.
  • Voiceprints.
  • 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. Biometric Data does not include information derived from items or procedures excluded under the definition of Biometric Identifiers.


4. Retention Schedule


In circumstances where Clips4Sale retains Biometric Data, Clips4Sale will permanently destroy or cause to be permanently destroyed an individual's Biometric Data within one year of collection.


5. Biometric Data Collection


Clips4Sale and its partners and providers collect, store, and use scans of face geometry for purposes of age verification in those jurisdictions that require mandatory age verification. Before collecting Biometric Data from any individual, Clips4Sale will obtain the individual's written consent to the collection.


6. Biometric Data Disclosures


Subject to individual consent, Clips4Sale may disclose an individual's Biometric Data to its third-party vendors or licensors to facilitate age verification in those jurisdictions that require mandatory age verification.


Clips4Sale prohibits any further disclosure or re-disclosure of Biometric Data unless:


  • The individual or the individual's legally authorized representative consents to the disclosure;
  • The disclosure is required by law or regulation; or
  • The disclosure is required under a valid warrant or subpoena issued by a court of competent jurisdiction.

Clips4Sale does not sell, lease, trade, or otherwise profit from Biometric Data.