Last Updated 2026-05-19 · Version biometric-v1-2026-05
Biometric Privacy Policy
This is the binding policy governing how Hole In One Contest Inc. collects, uses, retains, and destroys your biometric information. It satisfies our obligations under the Illinois BIPA, the Texas CUBI Act, the Washington biometric privacy statutes, the CCPA, and the GDPR.
What we collect
- Three face photos at enrollment: front, left 45°, right 45°.
- A mathematical embedding derived from those photos that we use to match you when you arrive at a contest tee.
- Face crops captured at the tee during a paid contest entry that you have booked, used only to confirm your identity for that entry.
Why we collect it
To attribute your shot to your paid entry, deliver your four personalized videos to your account, and route any contest winnings to your verified identity. Biometric data is never used for advertising or to identify you outside the contest context.
How long we keep it
- Raw enrollment photos: deleted within 24 hours of enrollment validation.
- Face embeddings: retained for three years from your last interaction with the service, then automatically destroyed.
- Tee-side face crops: matched crops linked to your booking are retained with your other entry records for seven years (financial-record requirements). Unmatched crops are discarded within 60 seconds of the match attempt.
Where it lives
All biometric data is encrypted at rest in AWS in the United States, with per-user KMS keys. Our edge devices (the cameras at your course) store no biometric data of any kind. Master databases are accessible only to a small number of named employees through hardware-key MFA and require VPN access.
Who else sees it
No third party. We do not sell, lease, license, or otherwise transfer your biometric data to anyone. AWS provides the underlying encrypted storage as our service provider under a Business Associate Agreement and Data Processing Agreement; AWS personnel cannot access decrypted biometric data.
Your rights
- Delete: Account → Biometric privacy → Delete my biometric data. Takes effect within 7 days; you will need to re-enroll before your next contest.
- Access: Request a copy of the biometric data we hold about you by emailing privacy@hiocontest.com.
- Correct: Re-enroll any time (Account → Re-enrollment).
- Object: You can deactivate your account at any time; we will purge biometric data within 30 days.
Bystanders
Our cameras stay fixed on the contest tee box. Faces of foursome partners or other golfers who do not have an active paid contest entry are not transmitted to our face-match service. Shareable versions of your videos automatically blur all non-shooter faces before publication.
Contact
privacy@hiocontest.com · Hole In One Contest Inc., 100 Pilot Drive, Pilot City, NY.
