Biometric Data Policy

Persona Jewelry is a brand of Tempus Luxury, LLC.

Last Updated: July 19, 2025

This Biometric Data Policy (“Policy”) describes how Tempus Luxury, LLC. d/b/a Persona Jewelry (“Persona Jewelry,” “we,” “us,” or “our”) collects, uses, stores, shares, safeguards, and deletes biometric information when you or an authorized representative submit it to personalize memorial jewelry and keepsakes. Biometric information is treated as “sensitive personal information” under applicable law and is handled separately from other personal data as outlined in our Privacy Policy.

Quick Navigation

1. Definitions
2. Collection & Consent
3. Purpose of Use
4. Storage & Security
5. Disclosure to Third Parties
6. Retention & Deletion
7. Legal Bases & Compliance
8. Your Rights & Choices
9. Breach Notification
10. Changes to This Policy
11. Contact Us

1 · Definitions

• Biometric Data – Any data derived from a human body that can identify or is associated with a specific individual, including but not limited to fingerprint images/3-D scans, handprints, handwriting samples, signatures, voice snippets, cremation-ash identifiers, or other memorial artifacts submitted for product personalization.
• Biometric Identifier – A direct representation of a biometric trait (e.g., raw fingerprint image).
• Biometric Information – Any data, regardless of how captured, converted, or stored, based on a Biometric Identifier and used to identify or associate with a person.

2 · Collection & Consent

• We collect Biometric Data only when you voluntarily upload, email, mail, or otherwise provide it, or when an authorized funeral home / next-of-kin submits it on your behalf.
• By providing Biometric Data, you (a) grant us permission to process it as described in this Policy; and (b) represent that you have lawful authority to share the data of any deceased or living individual depicted.
• Where required by law (e.g., Illinois BIPA), we obtain written consent at checkout or via electronic signature before collecting or storing Biometric Data.

3 · Purpose of Use

We use Biometric Data solely to:

• Design, craft, engrave, cast, or otherwise personalize ordered memorial jewelry and keepsakes;
• Provide product support, repairs, remakes, or reorder services (if you opt in for template retention);
• Verify order authenticity or resolve quality issues; and
• Comply with applicable legal obligations (e.g., consumer-protection, product-safety, or tax rules).

We do not use Biometric Data for automated decision-making, marketing profiling, or identification unrelated to your order.

4 · Storage & Security

• Digital Biometric files are stored in an encrypted environment in the United States, protected by industry-standard AES-256 encryption in transit and at rest.
• Physical molds or impressions are kept in a locked, access-controlled cabinet within our production facility.
• Access is limited to trained personnel who need the data to fulfill, repair, or remake your piece (“need-to-know” basis).
• We maintain written policies covering secure handling, employee confidentiality obligations, and disposal procedures.

5 · Disclosure to Third Parties

We disclose Biometric Data only to:

• Trusted Craft & Production Partners — under written agreements requiring the same level of protection and prohibiting secondary use;
• Shipping / Logistics Partners — solely for transporting physical impressions (no digital copies sent);
• Legal Authorities — when required by law, subpoena, or court order; and
• With Your Direction — e.g., when you request we transfer a mold to another jeweler.

We do not sell or otherwise monetize Biometric Data.

6 · Retention & Deletion

You may request earlier deletion at any time (see Section 8).

7 · Legal Bases & Compliance

• Consent (GDPR Art. 6(1)(a), CPRA §1798.121) — for collection and processing of Biometric Data.
• Contract (GDPR Art. 6(1)(b)) — to fulfill your custom-product order.
• Legal Obligation — to meet accounting, tax, or consumer-protection requirements.

Where U.S. state biometric laws apply (e.g., Illinois BIPA, Texas CUBI, Washington HB 1493), we adhere to notice, consent, retention, and destruction provisions. We also treat Biometric Data as “sensitive personal information” under the California CPRA.

8 · Your Rights & Choices

You may:

• Access — Request a copy of Biometric Data we hold.
• Delete/Destroy — Request prompt deletion of digital files and/or destruction of physical molds.
• Correct — Provide updated memorial material before production begins.
• Withdraw Consent — Withdraw processing consent prior to production (may cancel the order).

To exercise any right, email info@personajewels.com with the subject “Biometric Data Request” and include your order number. We will verify your identity (and authority if acting for a deceased loved one) before fulfilling the request.

9 · Breach Notification

If a security incident compromises Biometric Data, we will notify affected individuals and, where required, regulators within statutory timeframes (e.g., 72 hours under GDPR, reasonable time under BIPA).

10 · Changes to This Policy

We may update this Policy periodically. Material changes will be announced via banner on the Site or email, and we will seek renewed consent if mandated by law.

11 · Contact Us

Questions or concerns? Reach us at:

• Email: info@personajewels.com
• Mail: Tempus Luxury, LLC. d/b/a Persona Jewelry,