Biometric and Memorial Data Policy

Version 1.0 · Effective July 27, 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, who touches it, how long we keep it, and what you can ask us to do. It sits alongside our Privacy Policy, which covers everything else.

1. What this policy covers

Biometric and Memorial Data means the material we use to make your piece:

  • fingerprint and handprint scans and images;
  • physical impressions and the molds made from them;
  • handwriting samples and signatures; and
  • photographs submitted as part of a memorial piece.

It also covers the records that go with them — the authorization for a collection, and the link between a fingerprint record and a Persona PIN.

2. Data belonging to someone who has died

Most of what 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 mostly written with living people in mind, and it is not settled everywhere whether they apply to the data of someone who has died.

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 it.

We collect Biometric and Memorial Data only with consent.

If you submit material yourself, submitting it is your consent, and you confirm you have the legal authority to provide it.

Where a funeral home collects material for us, it may do so only if we have authorized it under a written arrangement with us. As a condition of that authorization, we require it to obtain a signed Persona Family Fingerprint Authorization — or equivalent auditable evidence of consent — from the legally authorized next-of-kin before collecting anything on our behalf, and to keep that record.

We do not instruct, encourage or permit any funeral home to collect a fingerprint or other biometric material without that consent. If you believe material relating to your family was collected without authorization, contact us at info@personajewels.com and we will investigate.

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

We use Biometric and Memorial Data only to:

  • design, craft, engrave and finish the products ordered;
  • confirm the quality of what we produced, and repair, remake or reorder it;
  • respond to your questions about your order; and
  • keep the records the law requires us to keep.

We never use it for marketing or advertising, to build profiles, to train any artificial- intelligence or machine-learning model, or to identify anyone. We do not sell, rent, license, lease, barter or otherwise disclose it for value.

5. Funeral homes — what an authorized one may do

Some fingerprints may reach us through a funeral home. Being honest about what that involves matters more than a simpler-sounding promise.

Only a funeral home we have authorized under a written arrangement with us may handle memorial material on our behalf. Where a funeral home is authorized, a member of its staff whom we have approved may capture a fingerprint and handle the resulting record — and only within these limits:

  • only after the written consent described in Section 3;
  • only for records belonging to that funeral home's own location, and not any other location's;
  • only inside the tools and workflows we provide and authorize; and
  • only for the purpose of getting the family's order made.

No funeral home receives Biometric and Memorial Data for its own purposes. Beyond the handling described above, what an authorized funeral home receives is order attribution and commission information — not memorial material.

We do not give your Biometric and Memorial Data to a funeral home for any other reason unless you expressly ask us to.

6. What an authorized funeral home may never do

We require every funeral home we authorize, and every member of its staff we approve, not to:

  • export, download or copy memorial material outside the tools we provide;
  • screenshot or photograph it;
  • store it on a personal phone, laptop or other personal device;
  • store it in a personal or consumer cloud account;
  • keep its own separate archive, copy or backup of it;
  • share login credentials, or let anyone use its access;
  • disclose it to anyone we have not approved;
  • transfer it to a competing memorial or jewelry provider; or
  • capture or submit the fingerprint of a living person through the tools we provide, including for demonstration or training.

Fingerprint images, impressions, molds and other production memorial material must never be exported, independently archived, or moved into a funeral home's own systems. This does not prevent an authorized funeral home from keeping the Persona Family Fingerprint Authorization, or equivalent auditable authorization record, in its own controlled records — Section 9 requires it to. These are requirements we impose, and a funeral home that breaches them can have its authorization suspended or withdrawn.

Where an authorization ends, or a funeral home stops working with us, we may require it to confirm in writing that it has destroyed or returned what it held.

7. Who else sees it

Outside the situation in Section 5, Biometric and Memorial Data is shared only with:

  • our production team and manufacturing partners, to the extent needed to make your piece, under confidentiality obligations and on a need-to-know basis;
  • logistics providers, where a physical impression or mold has to be moved; and
  • legal authorities, where we are legally required to disclose, or where disclosure is necessary to protect someone's safety.

We do not share it with advertisers, data brokers, or analytics providers.

8. Keeping it safe

Access inside Persona is limited to the people who need it to do their job, under written confidentiality obligations, and we maintain documented procedures for handling this material.

No system is perfectly secure, and we will not tell you otherwise. If a breach affects your Biometric and Memorial Data, we will notify you and the relevant authorities as the law requires.

9. How long we keep it

We keep this material only as long as we actually need it. The table below sets the outside limits — not a period 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 — and sooner than that once the purpose we collected it for has ended, or once we have carried out a valid deletion or withdrawal request
Physical impressions and molds Until your order's quality is confirmed, plus 90 days — or, if you ask us to keep them for possible reorders, up to the same maximum of three years after your last related interaction with us
The signed Persona Family Fingerprint Authorization, or the minimal auditable evidence of consent, that we hold Five years, measured from the later of the date of the authorization or the last order that relied on it — so we can show that a collection was properly authorized
The copy an authorized funeral home holds The same five years, kept as a controlled record, after which it must destroy it securely

When you ask us to delete, or withdraw your consent, we aim to have it carried out within 90 days. That is how long the work takes to complete across our systems. It is not a period for which we keep your material — the limits above still apply, and we do not wait 90 days to begin.

We keep something for longer only where a litigation hold, a legal obligation, or another documented lawful requirement applies. If that happens, we tell you what we kept and why, where legally permitted.

These periods are the standard we set for ourselves. They describe how we operate. They are not a statement about what any particular law requires, and a shorter period required by law always takes precedence over the table above.

10. Your choices

You can ask us to:

  • tell you what Biometric and Memorial Data we hold about your order;
  • correct information that is wrong;
  • delete the material we hold; and
  • withdraw consent for us to hold or use it.

Withdrawing consent before production begins means we stop, cancel the affected order and refund it in full.

After production has begun, we stop using the material for anything new as soon as we practically can, but we may not be able to undo work already done, and a refund is not automatic. What happens to the material after that is governed by Section 9 and applicable law: fingerprint and memorial material is kept only as long as it is needed and never beyond the maximum periods set there, and the authorization or auditable evidence of consent stays subject to the five-year period. Records showing that an order happened, and that a deletion was carried out, are kept — we do not erase that history.

To make a request, email info@personajewels.com with the subject line "Biometric Data Request" and your order number. We will verify your identity — and your legal authority, if you are acting for someone who has died — before we act. We aim to complete a valid request within 90 days, and we will respond within the time the applicable law allows.

Some requests may be limited by material we are required to keep for legal reasons. If that applies, we will tell you what we kept and why, where legally permitted.

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 Privacy Rights Act.

Which of those laws applies to a particular record depends on where you live and whose data it is, and not all of them apply to everything we hold. We apply this policy to all Biometric and Memorial Data we hold regardless, because we think that is the right way to handle it — not because we are asserting that every law applies to every record.

12. Changes to this policy

We may update this policy. Material changes are posted here with an updated version number and date. Where a change materially affects how we collect or use Biometric and Memorial Data, we will seek your renewed consent rather than relying on the posting alone.

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

13. Contact

Persona Jewelry, a brand of Tempus Luxury, LLC 133 NE 2nd Avenue, Unit 2013, Miami, FL 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