Mitty Biometric Data Policy

This is the publicly available written policy of Mitty LLC ("Mitty," "we," "us") concerning biometric identifiers and biometric information, published in accordance with the Illinois Biometric Information Privacy Act (740 ILCS 14/15(a)), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code § 503.001), Washington's biometric privacy law (RCW 19.375), and comparable laws.

It supplements our Privacy Policy and Terms of Service.

---

1. What this covers

Certain optional Mitty features — recognizing the same person across your media library, grouping media by who appears in it, and helping you find footage of a specific person — analyze faces appearing in your photos and videos. To do this, Mitty may create a mathematical representation of facial geometry, sometimes called a "faceprint" or "face template."

Where those representations constitute a biometric identifier or biometric information under applicable law, this policy governs them. We refer to them together as "Biometric Data."

2. Consent: these features are off until you turn them on

We do not collect, capture, purchase, receive through trade, or otherwise obtain Biometric Data unless you first give us your separate, express, written consent. Before any collection begins, we present an in-app disclosure that states:

1. That Mitty will collect, capture, or store Biometric Data
2. The specific purpose for the collection
3. The length of time it will be collected, stored, and used
4. That your media may contain other people, and that you are responsible for any consent the law requires from them

You must affirmatively agree before the feature activates. Declining costs you nothing else — every other feature of Mitty remains fully available, at the same price.

3. Purpose — and the limits we place on ourselves

We use Biometric Data solely to provide and improve the organizing, searching, grouping, and media-selection features you have enabled.

We do not:

• Use Biometric Data to identify people who are not in your own library, or to identify strangers
• Use Biometric Data for authentication or identity verification
• Use Biometric Data for advertising, marketing, or profiling
• Use Biometric Data to build profiles of individuals
• Use Biometric Data to train or improve artificial intelligence models, regardless of your other AI-training settings
• Sell, lease, trade, or otherwise profit from Biometric Data

4. Disclosure

We do not disclose, redisclose, or otherwise disseminate Biometric Data except:

• To service providers who process it on our behalf, under contract, for the purposes above, and who are prohibited from using it for any other purpose
• When you direct us to
• When required by a warrant, subpoena, or other valid legal process
• When required by federal, state, or local law

We never disclose Biometric Data to advertising networks, analytics providers, data brokers, or information resellers.

5. Retention and destruction schedule

We permanently destroy Biometric Data at the earliest of:

1. When the initial purpose for collecting it has been satisfied
2. When you turn the feature off, delete the associated media, or delete your account
3. When you withdraw consent or request deletion
4. Three (3) years after your last interaction with Mitty

Destruction occurs within 30 days of the triggering event, including from backups within 90 days, except where a law, warrant, or subpoena requires us to retain it.

Where Biometric Data is created and stored only on your device, deleting the app destroys it.

6. Storage and protection

We store and transmit Biometric Data using the reasonable standard of care within our industry, and in a manner at least as protective as we use for other confidential and sensitive information. This includes encryption in transit and at rest, access controls limiting access to personnel who require it, and monitoring.

7. Your rights

You may at any time:

• Withdraw consent — turn the feature off in the app's settings
• Request deletion — delete your media or account in the app, or email us
• Request access — ask what Biometric Data we hold about you
• Ask questions about this policy

Contact Mitty@mitty.film. We respond within the time applicable law requires.

If you appear in someone else's media and believe Mitty holds Biometric Data about you, email Mitty@mitty.film and we will work with you to locate and delete it.

8. Minors

Face recognition features are available only to users 18 and older. We do not knowingly collect Biometric Data from anyone under 18.

9. Changes

We may update this policy. Material changes will be posted with a revised effective date before they take effect, and where the law requires it, we will obtain fresh consent rather than apply a new use to previously collected Biometric Data.

10. Contact

Mitty LLC, a Wyoming limited liability company · 30 N Gould St Ste N, Sheridan, WY 82801, USA · Mitty@mitty.film · (415) 689-3757