Biometric and Memorial Data Policy

Version 1.1 · Effective August 17, 2026

A fingerprint is not an ordinary piece of data. When it belongs to someone who has died, it is often the last physical trace a family has. We treat it that way.

This policy explains what we collect, why we collect it, who may handle it, how long we keep it, and what you can ask us to do. It sits alongside our Privacy Policy, which covers our broader privacy practices.

1. What this policy covers

Biometric and Memorial Data means memorial material collected, preserved, submitted, or used through Persona, including:

fingerprint and handprint scans and images;
physical impressions and the molds made from them;
handwriting samples and signatures; and
photographs submitted for an authorized memorial purpose.

This policy also covers records directly associated with that material, including authorization records and the link between an eligible fingerprint record and a Persona PIN.

Biometric and Memorial Data may be preserved through an authorized Memorial Provider even when no jewelry purchase is made at the time of collection. If a product is later ordered, eligible preserved material may also be used to personalize and fulfill that authorized order.

2. Data belonging to someone who has died

Most of the Biometric and Memorial Data we hold relates to a person who has died. We want to be straightforward about the legal position: laws written to protect biometric data were primarily written with living people in mind, and the treatment of information relating to someone who has died may differ depending on the law and jurisdiction.

We do not treat that uncertainty as a reason to offer less protection. Every protection described in this policy applies to all Biometric and Memorial Data we hold, regardless of how a particular law would classify a specific record.

3. Authorization comes first

We collect or accept Biometric and Memorial Data only through an authorized process.

If you submit memorial material directly to Persona, you must complete any affirmative consent or authorization step required by the submission workflow and confirm that you have authority to provide the material for the stated purpose.

Where a Memorial Provider collects material on our behalf, it may do so only if Persona has authorized that Memorial Provider under a written arrangement with us.

Before fingerprint capture occurs, we require a signed Persona Family Fingerprint Authorization, or equivalent auditable evidence of authorization, through an approved electronic or written process.

The person providing the authorization must represent that they have lawful authority to authorize the collection and preservation of the material. The Memorial Provider is responsible for determining under its own professional procedures and applicable obligations whether the required authorization has been completed by an appropriate person.

The Memorial Provider must separately confirm that the required authorization is in place before fingerprint capture may proceed. A family signature or authorization record by itself does not authorize the Memorial Provider to bypass that confirmation requirement.

Persona relies on the Memorial Provider's confirmation as an operational requirement for access to the fingerprint capture workflow. Persona does not, through that workflow, independently determine family hierarchy or adjudicate competing claims about who should act for the person whose material is being preserved.

Nothing in this process replaces a requirement imposed by applicable law. Where applicable law requires authorization from the subject or a legally authorized representative, that requirement still applies.

Electronic authorization records may be maintained through a Persona approved electronic workflow. Where authorization is completed on paper, the Memorial Provider may be required to retain the signed authorization in its controlled records while Persona retains only the evidence reasonably necessary to document the authorization and confirmation.

We do not instruct, encourage, or permit a Memorial Provider to capture or submit a fingerprint or other biometric material without the required authorization and confirmation. If you believe material relating to your family was collected without proper authorization, contact us at info@personajewels.com and we will review the matter.

4. What we use it for, and what we never use it for

We use Biometric and Memorial Data only as reasonably necessary to:

create and maintain an authorized memorial preservation record;
associate an eligible fingerprint record with its Persona PIN and issuing Memorial Provider location;
preserve the material for a possible future authorized Persona Jewelry order;
design, craft, engrave, finish, inspect, repair, remake, or complete an authorized product if one is ordered;
respond to questions and requests relating to the memorial record or an associated order; and
maintain authorization, security, transaction, warranty, fraud prevention, dispute, and legal records that we are permitted or required to maintain.

A jewelry purchase is not required to create an authorized memorial preservation record.

We never use Biometric and Memorial Data for marketing or advertising, to build profiles, for unrelated identification, or to train artificial intelligence or machine learning models. We do not sell, rent, license, lease, barter, trade, or otherwise profit from Biometric and Memorial Data.

5. Memorial Providers: what an authorized one may do

Some fingerprints reach Persona through funeral homes or other authorized memorial professionals. In this policy, we refer to an organization authorized by Persona to perform this role as a Memorial Provider.

Only a Memorial Provider we have authorized under a written arrangement with us may handle Biometric and Memorial Data on our behalf.

Where a Memorial Provider is authorized, a member of its staff whom we have approved may capture a fingerprint and handle the resulting Persona record, but only within these limits:

only after the authorization described in Section 3 has been completed;
only after the Memorial Provider has confirmed the required authorization before capture;
only for records belonging to that Memorial Provider's assigned location, and not another location;
only inside the Persona tools and workflows we provide or expressly authorize;
only for the authorized preservation of the memorial record and related administration; and
if the family later chooses to order an eligible Persona Jewelry product, only as necessary to support that authorized order.

No Memorial Provider receives Biometric and Memorial Data for its own independent purposes.

Beyond the authorized handling described above, a Memorial Provider may receive information necessary to administer its Persona records and, where a later purchase creates partner attribution, appropriate order attribution and commission information.

We do not provide Biometric and Memorial Data to a Memorial Provider for another independent purpose unless you expressly direct us to do so and the disclosure is permitted by applicable law.

6. What an authorized Memorial Provider may never do

We require every Memorial Provider we authorize, and every member of its staff we approve, not to:

export, download, copy, or otherwise remove memorial material except through a Persona function expressly provided for the authorized record and purpose;
screenshot, photograph, or independently reproduce memorial material;
store memorial material on a personal phone, personal computer, or other personal device;
store memorial material in a personal or consumer cloud account;
maintain an unauthorized separate archive, copy, or backup of memorial material;
share login credentials or permit another person to use its authorized access;
access records assigned to another Memorial Provider location;
disclose Biometric and Memorial Data to anyone Persona has not authorized; or
capture or submit the fingerprint of a living person through Persona's Memorial Provider tools, including for demonstration or training.

Fingerprint images, impressions, molds, and other memorial material may be handled only through the systems and procedures Persona has authorized for the applicable purpose.

This restriction does not prevent a Memorial Provider from retaining a Persona Family Fingerprint Authorization, or equivalent auditable authorization record, where the approved authorization process requires the Memorial Provider to retain that record in its controlled files.

These are requirements Persona imposes on its Memorial Providers. A Memorial Provider that violates them may have its access or authorization suspended or withdrawn.

Where a Memorial Provider's authorization ends, we may require it to confirm that Persona related records or materials in its possession have been securely returned, destroyed, or otherwise handled as required by the applicable agreement and approved procedures.

7. Who else sees it

Outside the authorized Memorial Provider handling described in Section 5, Biometric and Memorial Data may be disclosed only as reasonably necessary to:

technology, infrastructure, storage, security, and other service providers that operate or support the systems used to securely receive, transmit, store, or manage the material, subject to appropriate restrictions;
our production team and manufacturing partners, where a product has been ordered and only to the extent necessary to create, inspect, repair, remake, or complete that product;
logistics providers, where an authorized physical impression or mold must be transported; and
legal authorities, where disclosure is required by law, legal process, or another lawful basis.

We do not share Biometric and Memorial Data with advertisers, data brokers, or analytics providers for advertising, profiling, or unrelated analytics purposes.

8. Keeping it safe

Access inside Persona is limited to people who require the information for an authorized purpose. Memorial Provider access is restricted to approved users, assigned locations, and Persona authorized workflows.

We maintain technical, administrative, and organizational safeguards designed to protect Biometric and Memorial Data and documented procedures governing how it may be handled.

No system is perfectly secure, and we will not tell you otherwise. If a security incident affects Biometric and Memorial Data, we will investigate and provide notifications where required by applicable law.

9. How long we keep it

We keep Biometric and Memorial Data only as long as reasonably necessary for its authorized purpose. The table below establishes outside limits, not periods we aim to reach.

What	How long
Fingerprint and handprint files, handwriting, signatures, and memorial photographs	No longer than three years after your last related interaction with us concerning the material, and sooner when the purpose for which the material was collected has ended or when we have carried out a valid deletion or withdrawal request, subject to any lawful requirement to retain information.
Physical impressions and molds	Until the authorized preservation or production purpose for holding them has been completed, plus 90 days. If you ask us to retain them for possible future product creation or an authorized reorder, they may be retained up to the same maximum of three years after your last related interaction with us.
The signed Persona Family Fingerprint Authorization, or minimal auditable evidence of authorization, that Persona holds	Five years, measured from the later of the date of authorization or the last order that relied on that authorization. If no order relies on the authorization, the five year period is measured from the date of authorization.
An authorization or controlled authorization record held by an authorized Memorial Provider	Where the approved workflow requires the Memorial Provider to retain the record, the same five years, after which it must securely destroy the record unless a longer period is lawfully required.

When you ask us to delete material, or withdraw your consent where withdrawal is available, we aim to have a valid request carried out within 90 days. That is the period in which the work may need to be completed across our systems. It is not a separate retention period. The limits above continue to apply, and we do not wait 90 days to begin processing a valid request.

We keep something for longer only where a litigation hold, legal obligation, valid legal process, or another documented lawful requirement applies. Where legally permitted, we will explain what we retained and why.

These periods are the standard we set for ourselves. They describe how we operate. They do not mean that every law requires the same period, and a shorter period required by applicable law takes precedence.

10. Your choices

You can ask us to:

tell you what eligible Biometric and Memorial Data we hold in relation to an authorized record;
correct information that is inaccurate;
delete eligible material we hold; and
withdraw consent where our continued use of the material is based on consent and withdrawal is available.

If no jewelry order has been placed, a valid withdrawal or deletion request generally means we stop using the memorial material for new purposes and process the eligible material under Section 9 and applicable law.

If an order has been placed but production has not begun, withdrawing the authorization needed to produce that order means we stop the affected production, cancel the affected order, and refund it in full.

After production has begun, we stop using the material for anything new as soon as reasonably practicable, but we may not be able to undo work already completed, and a refund is not automatic. Any refund or other order remedy is governed by the applicable order policies and law.

After a valid withdrawal or deletion request, Biometric and Memorial Data remains subject to the retention and deletion rules in Section 9. Authorization evidence and records showing that a transaction, authorization, or deletion occurred may be retained for the applicable record keeping period even after the underlying memorial material has been deleted.

To make a request, email info@personajewels.com with the subject line "Biometric Data Request." Include an order number, Persona PIN, or other relevant record reference if one is available.

We may need to verify your identity and, where a request concerns material relating to someone who has died, request information reasonably necessary to establish your authority to make the request. We aim to complete a valid request within 90 days, and we will respond within the period required by applicable law.

Some requests may be limited by information we are required or permitted to retain for legal, security, fraud prevention, dispute, authorization, or record keeping purposes. Where legally permitted, we will explain what we retained and why.

11. About the laws in this area

We have built these practices with reference to biometric and privacy laws including the Illinois Biometric Information Privacy Act and the California Consumer Privacy Act, as amended by the California Privacy Rights Act.

Which laws apply to a particular record depends on the circumstances, including the jurisdiction, the nature of the information, whose information it is, and how it is used. We apply this policy to all Biometric and Memorial Data we hold as an operational standard. We do not mean by doing so that every referenced law applies to every Persona record.

12. Changes to this policy

We may update this policy to reflect changes in our services, practices, technology, or legal requirements. Material changes will be posted here with an updated version number and date.

Where a change materially expands how we collect or use Biometric and Memorial Data, we will obtain additional consent or authorization where required rather than relying only on publication of the updated policy.

Where a change materially alters what we require of a Memorial Provider we have authorized, we give that Memorial Provider at least thirty (30) days' written notice, and the change does not take effect for that Memorial Provider until that period ends.

13. Contact

Persona Jewelry, a brand of Tempus Luxury, LLC
133 NE 2nd Avenue, Unit 2013
Miami, Florida 33132, United States
info@personajewels.com
Subject: "Biometric Data Request"
+1 (786) 550-0303

This policy is published at https://www.personajewels.com/pages/biometric-data-policy.