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Visitors to have the option of storing their facial information on the site in order to facilitate the ability to virtually try on eyewear.  This Notice provides certain information regarding this virtual try on (VTO) feature.  Neither Zenni nor its vendors collect biometric identifiers or biometric information as defined by the Illinois Biometric Information Privacy Act (740 ILCS 14/10).  However, in the interest of transparency, Zenni nonetheless is publishing this notice so that its customers may be aware of how the facial information is retained and destroyed.

Biometric Data Retention and Destruction

Zenni engages a third-party vendor that has developed, and manages, the software used for the VTO feature. The third-party vendor makes this information available to Zenni. Because our customers often appreciate being able to preserve their information on Zenni’s site to allow easier access the VTO feature each time they return to the site, Zenni will store a user’s facial information for the earlier of (a) three (3) years from the last time you used the VTO feature or (b) within thirty (30) days of when you send us a request to delete your facial information to  notifying us that you want us to delete your facial information.

There are certain circumstances that may prevent Zenni from destroying a user’s facial information in line with Zenni’s retention and destruction policies. For example, if Zenni receives a warrant or subpoena issued by a court of competent jurisdiction, or is otherwise required to retain users’ facial information to comply with applicable law, Zenni will retain the user’s facial information for the period of time that is required to ensure compliance with such warrant, subpoena, or applicable law.