Biometric Data Policy
Effective date: November 10, 2026 · Last updated: November 10, 2026
This policy explains how Tassel, LLC (“Tassel,” “we,” “us”) collects, uses, stores and destroys biometric data in Tassel’s photo matching feature. It applies to all users, wherever they live.
What we collect
When a graduate chooses to use photo matching, we collect a selfie and use it to create a facial template: a set of mathematical measurements of the graduate’s face. The facial template is biometric data. Photo matching does not collect fingerprints, voiceprints, retina or iris scans, or any other biometric identifier.
Why we collect it
We use facial templates for one purpose only: to find the graduate in their institution’s ceremony photos and deliver those photos to them. We do not use biometric data for any other purpose, including marketing, profiling or training AI models.
Consent
Photo matching is optional and available only when the graduate’s institution uses Tassel’s photos feature. Before we collect any biometric data, we tell the graduate in writing what we collect, why, and how long we keep it, and the graduate must agree by electronic signature. Graduates who don’t agree can still browse ceremony photos themselves. Photo matching is not offered to students in K-12 schools.
How it works
- The selfie is used only to create the graduate’s facial template, and is deleted immediately afterward.
- Ceremony photos are compared only against templates from graduates who have agreed. We don’t store facial data for anyone else who appears in ceremony photos.
- Facial recognition is processed on our behalf by a third-party cloud service provider in the United States, under a contract that prohibits it from using the data for any other purpose.
Retention and destruction
We permanently delete each facial template as soon as the graduate’s ceremony photos have been matched and delivered to their gallery, and in all cases no later than 90 days after the graduate’s ceremony. We also delete it sooner if the graduate withdraws consent or the institution’s contract with Tassel ends. Deletion is permanent and covers both Tassel’s systems and our service provider’s. Matched photos stay in the graduate’s gallery; they are not biometric data.
Withdrawing consent
Graduates can withdraw consent at any time by emailing [email protected]. We’ll delete any facial template we still hold within 10 business days and confirm by email.
No sale or other disclosure
We never sell, lease, trade or otherwise profit from biometric data. We don’t disclose it to anyone except our service provider, solely to provide photo matching, or when required by law, subpoena or court order.
Security
We protect biometric data with safeguards at least as strong as those we use for our other confidential information, including encryption in transit and at rest, restricted access and logging.
State laws
This policy is designed to meet the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, Washington’s biometric identifier law, Colorado’s biometric data requirements, and similar laws. We apply the same protections to all users.
Changes
If we change this policy, we’ll update the date above. We won’t use biometric data for a new purpose without new consent.
Contact
Tassel, LLC · 2261 Market Street, STE 85432, San Francisco, CA 94114 · [email protected]