Clear Showings LLC ("Clear Showings," "we," "us," or "our") provides consent-based identity verification used to confirm the identity of individuals prior to real estate showings. As part of this service, we may collect and process biometric data. This policy explains what biometric data we collect, why, how long we keep it, how we destroy it, and the rights and protections that apply. Clear Showings is organized and operates in North Carolina and voluntarily follows safeguards reflected in the Illinois Biometric Information Privacy Act, 740 ILCS 14 ("BIPA"), as best-practice benchmarks where appropriate. Clear Showings will also comply with any biometric privacy laws applicable to its collection, processing, retention, disclosure, or destruction of biometric data.
This policy supplements our Privacy Policy and applies specifically to biometric data.
1. What Biometric Data We Collect
In the course of an identity verification, we may collect and process:
- A scan of facial geometry generated from a self-captured photograph ("selfie"), used to confirm that the person presenting an identity document is the same person pictured on it (a "face match"); and
- Biometric information derived from that scan of facial geometry for the purpose of performing the face match. Together, these are referred to in this policy as "biometric data."
A photograph — including the selfie itself and any photograph of an identity document — is not, on its own, treated as a biometric identifier. The biometric data governed by this policy is the facial-geometry scan and any information derived from it. Photographs collected during verification are governed by the retention schedule in Section 4 and by our Privacy Policy.
2. Why We Collect It
We collect biometric data for a single, limited purpose: to verify, at the time of a real estate showing or related transaction, that the individual presenting an identity document is the genuine holder of that document.
We do not use biometric data for marketing, advertising, profiling, surveillance, training of unrelated systems, or any purpose other than the identity verification the individual has consented to.
3. Consent
We do not collect, capture, or store any individual's biometric data without first obtaining that individual's informed, written consent.
Before any biometric data is collected, each individual is presented with an electronic consent that:
- notifies them, in writing, that biometric data is being collected and stored;
- states the specific purpose for which it is collected and the length of time it will be stored and used;
- discloses the categories of information that will be shared with the requesting real estate professional upon completion of verification — the verification result and face-match scores, the selfie photograph, the portrait
extracted from the identity document, and PII-masked images of the identity document — and confirms that the facial-geometry scan itself is never shared with any party; and
- requires the individual's affirmative written authorization (a written release) before any collection occurs.
Each consent is recorded with a timestamp and the version of the consent disclosure presented. No verification proceeds until consent is captured. Consent records are retained for the duration of the individual's relationship with Clear Showings and for a minimum of three years thereafter, even after the underlying biometric data has been destroyed.
4. Retention Schedule
We retain data collected during verification only as long as necessary to fulfill the purpose for which it was collected, and never longer than the limits below:
- Facial-geometry scan and derived biometric information — automatically and permanently deleted no later than 30 days after the verification, or earlier upon a verified deletion request.
- Selfie photograph — deleted together with the biometric data, no later than 30 days after the verification.
- Unmasked identity-document images — permanently deleted within 7 days of capture.
- PII-masked identity-document display copies — retained with the verification record and deleted no later than 30 days after the verification, together with the selfie photograph.
- Non-biometric records, including consent records, deletion logs, customer activity records, and verification metadata that does not constitute or contain biometric data, may be retained for a longer period when reasonably necessary for legal compliance, dispute resolution, fraud prevention, security investigations, enforcement of agreements, or the establishment, exercise, or defense of legal claims.
In every case, biometric data is also subject to the destruction deadline required by applicable law, which is no later than the earlier of (a) the date the purpose for collection is satisfied, or (b) three (3) years after the individual's last interaction with Clear Showings. Where different periods apply, Clear Showings will follow the shorter period required by applicable law or stated in this Policy.
5. How We Destroy Biometric Data
When the applicable retention period ends, biometric data is permanently and irreversibly destroyed using commercially reasonable methods designed to render it unrecoverable. Destruction occurs automatically on the schedule described above without requiring any action by the individual, and each destruction is recorded in a timestamped destruction log. Destruction logs will document the completion and timing of destruction but will not contain the biometric data that was destroyed.
6. Disclosure and Our Use of a Processor
Identity verification is performed with the assistance of a third-party identity-verification provider that acts as our processor under a written data processing agreement. That provider processes biometric data only on our instructions and only for the purpose of performing the verification.
Upon completion of a verification, the requesting real estate professional receives a verification summary consisting of the individual's name, the verification result and face-match scores, the selfie photograph, the portrait extracted from the identity document, and PII-masked images of the identity document (and, where the applicable service tier includes screening, the Assessment, a yes/no AML/PEP watchlist match flag, and the other verification outcomes described in our Privacy Policy). Before collection occurs, the individual will be informed of each category of information included in the verification summary and whether that information will be displayed, retained, downloadable, or otherwise accessible to the requesting real estate professional. This disclosure is made with the individual's consent, obtained as described in Section 3, and to complete the verification the individual has requested. The verification summary never includes biometric data as defined in this policy: no facial-geometry scan, derived biometric information, or biometric template is ever displayed to, shared with, or accessible by the requesting professional or any other party.
We do not disclose, redisclose, or otherwise disseminate biometric data to any other party except:
- with the consent of the individual;
- to complete a transaction requested or authorized by the individual;
- where required by state or federal law or municipal ordinance; or
- pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
For clarity: where a verification session includes validation of a non-U.S. identity document against the issuing government's registry (Global ID Confirmation, as described in our Privacy Policy), that validation uses only data extracted from the presented document. No biometric data — no facial-geometry scan, derived biometric information, biometric template, or selfie photograph — is transmitted to any government registry or to any party outside our identity-verification processor. All face matching is performed exclusively between the selfie and the portrait on the presented identity document.
7. No Sale or Profit
We do not sell, lease, trade, or otherwise profit from any individual's biometric data. Any material change to this practice will be disclosed through an updated policy and will be subject to any notice, consent, or authorization required by applicable law.
8. Data Security
We store, transmit, and protect biometric data using the reasonable standard of care applicable to our industry, and in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other confidential and sensitive information. Our practices include data minimization, restricted access, encryption in transit and at rest, and prompt destruction under the schedule above.
9. Your Rights
Depending on your state of residence, you may have rights regarding your biometric data, including the right to know what we have collected, the right to withdraw consent, and the right to request deletion. Withdrawing consent will end any further biometric processing and, where applicable, will prevent completion of a verification that requires it.
To exercise any of these rights, contact us using the details below.
10. Changes to This Policy
We may update this policy from time to time. Material changes will be reflected by updating the "Last updated" date above and, where appropriate, by additional notice.
11. Contact
Clear Showings LLC
615 River Highway, Suite 1008 Mooresville, NC 28117
contact@clearshowings.com
This policy is made publicly available consistent with the standards of 740 ILCS 14/15(a), which Clear Showings voluntarily adopts.