Biometric Login Notice & Consent

Saconde & Saconde, LLC — Biometric Login Notice and Consent — Effective Date: July 11, 2026

Saconde & Saconde, LLC
Effective Date: July 11, 2026
Company Name: Saconde & Saconde, LLC
Principal Place of Business: New York, New York, United States
Website: www.saconde.com
Mobile Applications: Saconde mobile applications, including applications made available for iOS, Android, or other supported platforms
Retail/Showroom Location: 521 W 26th St, Floor 5, New York, NY 10001
Contact: hello@saconde.com

1. PURPOSE OF THIS NOTICE

This Biometric Login Notice and Consent (“Notice”) explains how Saconde & Saconde, LLC, doing business as Saconde (“Saconde,” “Company,” “we,” “us,” or “our”), enables optional biometric authentication features in connection with:

This Notice is intended to provide advance notice and obtain consent where required under applicable biometric privacy, consumer privacy, data protection, and security laws.

Biometric login is optional. You may ordinarily access your Saconde account through another available authentication method, such as a password, passcode, one-time verification code, passkey, or other approved method.

This Notice should be read together with Saconde’s:

2. IMPORTANT DISTINCTION: DEVICE BIOMETRICS AND SACONDE-COLLECTED BIOMETRICS

2.1 Device-Native Biometric Authentication

Saconde may allow you to use biometric authentication technology already available on your device, including:

For standard device-native biometric login, your device manufacturer or operating-system provider performs the biometric comparison locally on your device.

Saconde is generally informed only whether authentication succeeded or failed. Saconde does not intend to receive, collect, access, possess, store, or control the underlying fingerprint image, facial image used by the device’s biometric system, face map, iris scan, voiceprint, or raw biometric template maintained by your device.

Saconde may receive or maintain limited non-biometric information associated with this process, such as:

These records are not intended to contain your raw biometric identifier.

2.2 Saconde or Third-Party Biometric Collection

In limited circumstances, Saconde or an authorized service provider may offer or require a separate identity-verification, account-recovery, fraud-prevention, high-value transaction, workplace-access, or security process that may involve:

Saconde will not treat your acceptance of this biometric-login Notice as consent to a materially different biometric identity-verification process unless this Notice clearly describes that process.

When a separate process collects or generates biometric identifiers or biometric information, Saconde will provide an additional notice and obtain any consent required by applicable law before collection or processing.

3. DEFINITIONS

For purposes of this Notice:

3.1 “Biometric Identifier”

“Biometric Identifier” means a biological, physiological, or behavioral characteristic, or data generated from the automated measurement of such a characteristic, that is used or intended to identify or authenticate a specific individual.

Depending on applicable law, this may include:

3.2 “Biometric Information”

“Biometric Information” means information based on, derived from, or generated from a Biometric Identifier and used or intended to identify or authenticate an individual, regardless of how the information is captured, converted, stored, or shared.

3.3 “Biometric Data”

“Biometric Data” collectively means Biometric Identifiers and Biometric Information, except where applicable law defines these terms differently.

Biometric Data generally does not include:

4. BIOMETRIC LOGIN IS VOLUNTARY

Enabling biometric login is voluntary unless a particular security-sensitive service cannot reasonably be provided without biometric verification and applicable law permits Saconde to require it.

You may decline to enable biometric login and use another available login method.

Saconde will not unlawfully:

Certain high-risk activities, including account recovery, changes to payment or payout instructions, high-value transactions, suspected fraud, access to restricted systems, or identity verification required by law, may require enhanced authentication. When biometric processing is necessary for such a function, Saconde will provide an appropriate notice and, where required, a reasonable alternative.

5. INFORMATION THAT MAY BE PROCESSED

Depending on the biometric feature you use, the information processed may include:

5.1 Device-Native Authentication

For device-native authentication, the device may process a fingerprint, facial characteristic, iris pattern, voice characteristic, or other biometric credential stored or enrolled on the device.

Saconde generally receives only:

5.2 Separate Identity-Verification Services

Where expressly disclosed in an additional notice, Saconde or its service provider may collect or generate:

Saconde will limit collection to information reasonably necessary and proportionate to the disclosed purpose.

6. PURPOSES OF BIOMETRIC PROCESSING

Saconde may use biometric authentication or related information only for disclosed and legally permitted purposes, including:

Saconde will not use Biometric Data for:

7. NOTICE OF COLLECTION AND TERM

Where Saconde directly collects or controls Biometric Data, you are informed that Saconde or its authorized service provider may collect, capture, receive, obtain, process, convert, generate, use, disclose, store, or otherwise possess the categories of Biometric Data described in this Notice.

The information may be collected when you:

Saconde will retain Biometric Data only for the period reasonably necessary to complete the disclosed purpose, subject to the retention limits stated in Saconde’s Biometric Retention and Destruction Policy.

Unless a shorter period is required by law, Saconde’s default outside retention limit for Biometric Data directly possessed by Saconde is the earlier of:

  1. the date the initial purpose for collecting or obtaining the Biometric Data has been satisfied;
  2. three years after your last interaction with Saconde;
  3. three years after the termination of an employment or contractor relationship, where applicable;
  4. the date your valid deletion request is completed;
  5. the date consent is withdrawn, where processing cannot lawfully continue without consent; or
  6. another deadline required by applicable law.

Saconde may retain information longer when reasonably necessary to comply with a legal obligation, preserve evidence, investigate fraud or security incidents, resolve a dispute, enforce an agreement, or establish, exercise, or defend legal claims, provided that the information is segregated or restricted where reasonably practicable and destroyed when the exception no longer applies.

8. DISCLOSURE TO SERVICE PROVIDERS

Saconde may disclose limited information associated with biometric authentication to service providers that assist with:

Where a service provider receives Biometric Data, Saconde will require the provider, as appropriate, to:

9. NO SALE OR PROFITING FROM BIOMETRIC DATA

Saconde does not sell, lease, trade, or otherwise profit from a transaction involving Biometric Data.

Saconde will not exchange Biometric Data for money or another thing of value.

Saconde will not disclose, redisclose, or disseminate Biometric Data except:

Biometric Data will not be treated as an asset available for unrestricted transfer in a merger, acquisition, bankruptcy, or sale of business. Any permitted successor must remain subject to applicable law and the commitments in effect when the information was collected, unless additional notice and consent are legally obtained.

10. SECURITY

Saconde will protect any Biometric Data in its possession using a reasonable standard of care within its industry and in a manner that is at least as protective as the manner in which Saconde protects other confidential and sensitive information.

Safeguards may include:

No system is completely secure, and Saconde cannot guarantee that unauthorized access, loss, misuse, or disclosure will never occur.

11. YOUR CHOICES AND RIGHTS

Depending on your location and applicable law, you may have the right to:

Because Saconde generally does not receive the underlying biometric measurement used for device-native login, Saconde may have no raw biometric record to access, correct, or delete. You may need to manage the biometrics enrolled on your device through the device’s settings.

12. HOW TO DISABLE BIOMETRIC LOGIN

You may disable Saconde biometric login by:

Disabling biometric login does not automatically delete information maintained by your device manufacturer or operating-system provider. You should consult your device settings and the provider’s privacy materials.

After biometric login is disabled, you may be required to authenticate using another approved method.

13. HOW TO SUBMIT A PRIVACY REQUEST

You may submit a request by:

Your request should identify:

Saconde may verify your identity before acting on a request. Verification information will be used only for verification, security, fraud prevention, and legal compliance.

An authorized agent may submit a request where permitted by law. Saconde may require proof of authorization and may verify the request directly with you.

Saconde will respond within the period required by applicable law. Where an appeal right applies, instructions for submitting an appeal will be included in the response.

14. WITHDRAWAL OF CONSENT

You may withdraw your consent to optional biometric login at any time by disabling the feature or contacting Saconde.

Withdrawal does not affect processing that occurred lawfully before withdrawal.

If Saconde directly possesses Biometric Data and consent is the legal basis for continued processing, Saconde will stop the affected processing and delete the information within the period required by law, unless continued retention is authorized or required for:

15. MINORS

Saconde’s biometric-login feature is not intended to collect Biometric Data directly from children under 13.

Saconde will not knowingly collect Biometric Data from a child under 13 without verifiable parental consent where required.

For users under 18, Saconde may require:

Saconde will not knowingly sell or use a minor’s Biometric Data for targeted advertising or profiling.

16. EMPLOYEES, APPLICANTS, AND CONTRACTORS

Where Saconde uses biometric technology for employees, applicants, temporary workers, contractors, or other workforce members, Saconde will provide a separate workforce biometric notice where required.

Workforce biometric processing may not be used merely for convenience where applicable law requires the processing to be necessary for security, safety, fraud prevention, access control, or another legally permitted purpose.

No employee or contractor should be required to provide Biometric Data unless Saconde has:

17. STATE-SPECIFIC DISCLOSURES

The following provisions supplement the remainder of this Notice. Where a state-specific provision provides greater protection, that provision controls for residents or transactions covered by that law.

17.1 Illinois

For purposes of the Illinois Biometric Information Privacy Act:

  1. Saconde will inform the individual or the individual’s legally authorized representative in writing that a biometric identifier or biometric information is being collected or stored.
  2. Saconde will inform the individual in writing of the specific purpose and length of term for which the biometric identifier or biometric information is being collected, stored, and used.
  3. Saconde will obtain a written release before directly collecting or otherwise obtaining covered biometric identifiers or biometric information.
  4. An electronic signature, checkbox, click-through acceptance, or comparable legally valid electronic record may constitute a written release where permitted.
  5. Saconde will not sell, lease, trade, or otherwise profit from covered biometric identifiers or biometric information.
  6. Saconde will not disclose or disseminate covered biometric information except with consent, to complete a requested financial transaction, as required by law, or pursuant to a valid warrant or subpoena.
  7. Saconde will maintain a publicly available retention schedule and destruction guidelines.
  8. Saconde will permanently destroy covered information when the initial purpose for collection has been satisfied or within three years of the individual’s last interaction with Saconde, whichever occurs first, unless continued retention is legally required.
  9. Saconde will protect covered information using a reasonable standard of care and at least the same level of protection used for other confidential and sensitive information.

17.2 Texas

For purposes of Texas Business and Commerce Code Chapter 503:

  1. Saconde will inform an individual and obtain consent before capturing a biometric identifier for a commercial purpose.
  2. Saconde will not sell, lease, or otherwise disclose a biometric identifier for a commercial purpose except as authorized by the individual or permitted by law.
  3. Saconde will store, transmit, and protect biometric identifiers using reasonable care and in a manner that is the same as or more protective than the manner in which Saconde handles other confidential information.
  4. Saconde will destroy covered biometric identifiers within a reasonable time and no later than the first anniversary of the date the purpose for collecting the identifier expires, except where a longer period is permitted for valid employment-related security purposes or required by law.

17.3 Washington

For purposes of Washington’s biometric-identifier law:

  1. Saconde will provide notice and obtain consent before enrolling a biometric identifier in a database for a commercial purpose.
  2. Saconde will provide notice and obtain consent before materially changing the purpose for which an enrolled biometric identifier is used.
  3. Saconde will maintain a policy concerning retention and permanent deletion.
  4. Saconde will not use or disclose an enrolled biometric identifier in a manner materially inconsistent with the original terms under which it was collected without obtaining legally required consent.
  5. Saconde will not sell, lease, or otherwise disclose the identifier for a commercial purpose except as permitted by law.
  6. Saconde will use reasonable care to guard against unauthorized access and acquisition.

17.4 Colorado

For purposes of the Colorado Privacy Act’s biometric protections:

  1. Saconde will maintain a written policy establishing a retention schedule, incident-response procedures, deletion guidelines, and a process for responding to security incidents involving biometric data.
  2. Saconde will provide legally required disclosures and obtain consent before collecting or processing a biometric identifier.
  3. Consent will be freely given, specific, informed, and unambiguous, and will not be obtained through dark patterns.
  4. Saconde will not condition an unrelated good or service on consent to biometric processing unless the processing is necessary to provide that good or service.
  5. Saconde will not charge a different price or provide a different quality of service solely because a consumer exercises a biometric privacy right, except as permitted by law.
  6. Saconde will not purchase a biometric identifier except under circumstances expressly permitted by law.
  7. Saconde will provide reasonable methods for access, correction, deletion, withdrawal of consent, and appeals.
  8. Saconde will delete covered biometric identifiers by the earliest legally required date, subject to lawful exceptions.

17.5 California

Biometric information processed for the purpose of uniquely identifying a consumer may constitute sensitive personal information under California law.

Subject to applicable thresholds and exceptions, California consumers may have rights to:

Saconde does not sell or share Biometric Data for cross-context behavioral advertising.

Saconde will provide notice at or before collection and will limit collection, use, retention, and disclosure to what is reasonably necessary and proportionate for the disclosed purpose.

17.6 Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and Other Comprehensive Privacy-Law States

Where an applicable state privacy law treats biometric data used for unique identification as sensitive data, Saconde will obtain consent before processing when required.

Covered consumers may have rights to:

Saconde will conduct data-protection assessments where required for processing that presents a heightened risk of harm.

17.7 New York City

At any physical New York City retail location subject to the New York City Biometric Identifier Information Law, Saconde will post legally required clear and conspicuous signage near customer entrances when Saconde collects, retains, converts, stores, or shares customers’ biometric identifier information.

Saconde will not sell, lease, trade, share in exchange for value, or otherwise profit from the transaction of customer biometric identifier information.

Device-native login used remotely through the Saconde app should not be understood as authorizing Saconde to deploy biometric surveillance or customer-identification technology inside a retail location.

17.8 Other States and Localities

Saconde intends to apply this Notice as a nationwide baseline. Where another state or locality provides additional or more protective rights, Saconde will comply with the applicable requirement.

18. CONSENT

By affirmatively selecting “I Agree,” “Enable Biometric Login,” “Continue,” or a similar consent mechanism, you acknowledge and agree that:

  1. you have received and reviewed this Notice;
  2. you understand the nature and purpose of the biometric-login feature;
  3. biometric login is optional unless otherwise specifically disclosed;
  4. your device may process your fingerprint, face, iris, voice, or another biometric credential locally;
  5. for device-native login, Saconde generally receives only an authentication result, cryptographic assertion, or similar confirmation and does not intend to receive your raw biometric measurement;
  6. where Saconde or its service provider directly collects Biometric Data, you authorize the collection, processing, use, storage, and disclosure described in this Notice and any supplemental notice;
  7. you authorize the use of applicable information for authentication, account security, fraud prevention, identity verification, and other specifically disclosed purposes;
  8. you understand the applicable retention period and destruction process;
  9. you understand that Biometric Data will not be sold, leased, traded, or otherwise monetized;
  10. you understand how to disable biometric login and withdraw consent;
  11. you understand that another authentication method may be available;
  12. you consent to the electronic form of this Notice and consent record; and
  13. you represent that you are legally authorized to provide this consent.

19. CHANGES TO THIS NOTICE

Saconde may update this Notice to reflect changes in law, technology, or business practices.

Saconde will not use directly collected Biometric Data for a materially different purpose without providing additional notice and obtaining additional consent where required.

The “Last Updated” date identifies the most recent revision.

20. CONTACT

Questions or requests concerning biometric privacy may be directed to:

Saconde & Saconde, LLC
521 W 26th St, Floor 5
New York, NY 10001
United States

Email: hello@saconde.com
Website: www.saconde.com