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Biometric Data Consent & Privacy Notice

Updated: July 2026

1. How Verification Works

Here is what happens when you go through identity verification in the Curator feature, step by step: • Step 1, Document check. You submit a government-issued identity document. We read the details on it to confirm your name, date of birth, and nationality. • Step 2, Liveness check. We capture a short facial scan to confirm that the person submitting the document is a real, living person and matches the photo on the document. • Step 3, Verification result. Once we have confirmed your identity, your verification status is stored in your account. The raw facial image used for the liveness check is deleted as soon as the check completes, and in all cases within 24 hours. • Step 4, Ongoing record. A mathematical representation of your face (a facial template) is retained to allow re-verification if needed, for the duration of your account. It is stored securely and used for no other purpose. Your facial data is processed by InterLink and by a limited number of service providers who act under contract on our behalf, as described in Section 4. It is never sold and never shared for commercial purposes.

2. What Data We Collect

We collect three categories of personal data in connection with identity verification:

2.1 Identity Data

To verify who you are, we collect the following information directly from you:

• Full legal name, as it appears on your government-issued identification document.

• Date of birth.

• Nationality and country of residence.

• Government-issued identification document, including the document number, issuing country, and expiry date. We accept documents such as national identity cards, passports, and driver's licenses.

2.2 Biometric Data

Identity verification and certain in-app actions require the capture and processing of your facial data. We collect biometric data in two contexts:

• Initial verification (onboarding): When you first complete KYC, we capture a live facial scan to confirm that you are a real, living person and that your face matches the photo on your identity document. This is a one-time liveness check.

• Re-authentication: After your identity has been verified, certain sensitive actions within the app may require you to re-authenticate using your face. In these cases, your facial template retained from the initial verification is used for comparison. No new image is stored.

• In both cases, we collect:

• A live facial image or short video, captured during the session and used only for the immediate verification or re-authentication check. This raw image is deleted as soon as the check completes, and in all cases within 24 hours.

• A facial template, which is a mathematical representation derived from your facial image. This is not a photo, and it is designed so that it cannot practically be reconstructed into your facial image.

It is retained for the duration of your account to support re-authentication.

Facial scan data constitutes biometric data under applicable data protection laws and is subject to the additional protections described in Section 6.

2.3 Verification and Consent Records

We retain an operational record of the verification process:

• Verification timestamp: the date and time your identity verification was completed.

• Verification outcome: whether your verification passed, failed, or is pending.

• Consent record: the version of this Notice you agreed to and the date and time of your agreement, kept as proof of your consent.

3. How We Use Your Data

3.1 Purposes

Your KYC data is used only for the following purposes:

• To verify that you are a real, eligible person before granting you access to features within the InterLink application that require a verified identity.

• To keep the verification process secure and to detect and prevent fraud and abuse of the verification system.

• To comply with our obligations under applicable KYC and AML regulations.

We do not use your KYC or biometric data for advertising, for profiling, or for any form of analysis beyond identity confirmation and the security of the verification process.

3.2 Legal Basis

We process your personal data on the following legal bases:

• Consent. You provide explicit consent to the collection and processing of your biometric data when you initiate verification. You may withdraw this consent at any time, as described in Section 8.

• Contractual necessity. Processing of your identity data is necessary to give you access to Features that require a verified identity.

• Legal obligation. Certain processing and retention is required to comply with applicable KYC and AML regulations.

3.3 Automated Verification

The verification decision (pass or fail) is made by automated means. If your verification fails and you believe the result is wrong, you can request a manual review through the official support channels within the application. A person will review your case.

4. Who Can Access Your Data

Your KYC and biometric data is processed by InterLink and by a limited number of service providers who act on our behalf and under our instructions, such as providers of secure hosting and verification technology. Each provider is bound by contract to protect your data, to process it only for the purposes described in this Notice, and never to use it for their own purposes. We do not sell, license, or share your biometric data with any third party for commercial purposes, and we do not allow any third party to use it for advertising or profiling. We may disclose your data to competent government authorities where we are required to do so by applicable law, including KYC and AML regulations, or in response to a valid legal request. Where the law allows, we will limit any such disclosure to what is strictly required.

5. Where Your Data Is Stored

Your KYC and biometric data is stored on secure infrastructure. If you are located in a different country from where your data is stored, your data will be transferred to and processed in that location. Wherever your data is stored, it receives the same protections described in this Notice, and any cross-border transfer is carried out in accordance with the requirements of applicable data protection law.

6. Biometric Data: What We Guarantee

Because facial scan data is sensitive, we apply additional protections beyond our standard data practices: • Contract-bound processing: your facial data is processed only by InterLink and by service providers under contract as described in Section 4. No other party has access to it. • Never sold, never shared for commercial purposes: we do not sell, license, share, or transfer your biometric data to any third party for any commercial purpose. Disclosure happens only where the law requires it, as described in Section 4. • Raw image deleted quickly: the facial image captured during your liveness check is deleted as soon as the check completes, and in all cases within 24 hours. Only the derived facial template is retained. • Used for one thing: your facial template is used only to support identity verification and re-authentication within the InterLink application. Nothing else. • Explicit consent required: we collect your consent to biometric processing separately, at the point of initiating the liveness check. You cannot complete verification without providing this consent.

7. How Long We Keep Your Data

We keep your data for the minimum period necessary: • Identity documents and verification records: kept for the period required by applicable KYC and AML regulations, and in any case for at least five (5) years from the date of verification or the end of your relationship with InterLink, whichever is later. • Verification attempt records: kept for up to five (5) years for fraud prevention and regulatory compliance. • Consent records: kept for as long as we rely on your consent, plus the period needed to demonstrate compliance. When retention periods expire, data is securely and permanently deleted and cannot be reconstructed.

8. Your Rights and Choices

8.1 What You Can Do

You are always in control of your data. At any time, you can:

• Access your data. Request a copy of the KYC data we hold about you.

• Correct your data. Request correction of inaccurate or incomplete information.

• Delete your data. Request permanent deletion of your identity and biometric data, subject to legal retention obligations.

• Withdraw consent. Withdraw your consent to biometric processing at any time. Withdrawal does not affect processing already carried out.

• Restrict processing. Request that we limit processing of your data in certain circumstances.

• Complaint. Lodge a complaint with the data protection authority competent for you, which may be the authority in your country of residence, if you believe your data has been processed unlawfully.

8.2 How to Exercise Your Rights

Contact InterLink through the official support channels within the application. We will respond within thirty (30) days of receipt.

8.3 What Happens If You Delete or Withdraw

If you withdraw consent to biometric processing or request deletion of your biometric data, your verification status will be revoked and you will lose access to features that require a verified identity. You can complete verification again at any time by going through the process described in Section 1.

9. Security

We take the security of your KYC and biometric data seriously. Our measures include: • Encryption: of all personal data at rest and in transit. • Strict access controls: only authorized personnel with a direct operational need can access KYC data. • Secure deletion: applied upon expiry of retention periods. • Regular internal security reviews: covering all systems handling identity and biometric data. No system is completely secure. If a breach occurs that poses a high risk to your rights, we will notify you as required by applicable law.

10. Children

Users aged 18 or older may complete identity verification through the standard process described in this Notice. Users under 18 years of age may only proceed with identity verification and access to Features that require a verified identity if all of the following conditions are satisfied: • Verifiable consent has been provided by a parent or legal guardian, in a form accepted by InterLink at the time of verification. • Applicable law in the minor's country of residence permits such participation. We do not knowingly collect personal data from minors without the consent described above. Where applicable law does not permit minors to participate in identity verification or access related Features, access will be restricted regardless of parental consent. Users are responsible for ensuring their participation complies with the laws of their country of residence. InterLink reserves the right to limit or deny access to identity verification and related Features in jurisdictions where such participation is not permitted.

11. Updates to This Notice

We may update this Notice from time to time. If changes affect your rights, we will notify you in advance through the application. If an update materially changes how we collect or use your biometric data, we will ask for your explicit consent again before the change applies to you. Continued use alone is not treated as consent to changes in biometric processing. If you want to access a previous version of this Notice, contact us through official support channels.

12. Contact

For questions about this Notice or to exercise your data rights, contact us through the official support channels within the InterLink application.