Intellicheck Privacy Policy

Last Revised: 8-18-2021

PLEASE READ THIS POLICY CAREFULLY

This privacy policy (“Policy”) describes how Intellicheck, Inc. ("Intellicheck," "we," "us," or
"our,") collects, uses, and stores information in connection with (a) visitors to our websites, (b)
use of our software applications, products, and services, and (c) customer accounts (each a
“Service” and collectively the "Services"). BY CLICKING "I ACCEPT," ACCESSING OR
USING THE SERVICES, REGISTERING AN ACCOUNT, OR SUBMITTING
INFORMATION TO THE SERVICES, YOU SIGNIFY YOUR CONSENT TO THE
PRACTICES DESCRIBED BELOW, INCLUDING THE COLLECTION, USE, AND
DISCLOSURE OR YOUR PERSONAL INFORMATION, AS APPLICABLE. IF YOU DO
NOT CONSENT TO THE TERMS OF THIS POLICY, (1) DO NOT ACCESS OR USE THE
SERVICES OR CREATE AN ACCOUNT, AND (2) IF YOU HAVE ACCESSED OR USED
THE SERVICES, CREATED AN ACCOUNT, OR BELIEVE WE HAVE COLLECTED
INFORMATION ABOUT YOU, CONTACT US IMMEDIATELY AT THE ADDRESS SET
FORTH IN SECTION 13 BELOW.

a) Applicability.

This Policy applies to the information you provide to Intellicheck in connection with your use of
the Services. We have no control over, and no responsibility or liability for, any third party's
collection, use, disclosure, or retention of the Personal Information that you provide to a third
party, and that collection, use, disclosure, and retention is not subject to this Policy.

If you are an individual whose driver's license or government-issued identification card has been
scanned using the Services, the person, organization, or entity who used the Services to execute
the scan is under legal obligations, which limit the information that person, organization, or
entity can collect about you. You should contact that person, organization, or entity directly if
you have questions about its collection, use, or storage of your information.

2. Information Collection Practices.

c) General

The Services collect information that identifies, relates to, describes, references, is reasonably
capable of being associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer, household, or device ("Personal Information"). Personal Information does
not include:

 Publicly available information from government records; or

 Deidentified or aggregated consumer information.

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When you visit a web site without registering, you can browse without submitting personally
identifiable information about yourself. If you register for an account within a Service or to
access a Service, we will collect some Personal Information from you, including your full name,
username, email address, and a password that you select. When you interact with the Services,
we also receive and store certain additional types of information which, in general, do not
directly identify you. This Section of the Policy outlines the various ways that information is
collected from the Services. Please fully review this Policy before you use the Services or submit
information to us.

d) Information Automatically Collected

The Services may automatically collect certain information from users through the use of
"cookies," locally shared objects, or other technologies (see Section 5 below). In general,
information automatically collected does not directly identify you and the information may
include, but is not limited to: browser type; other browser history; platform type; device's MAC
address or MSISDN or other unique device identifier; information about your device operating
system; number of clicks; landing pages; cookie information; the amount of time spent on
particular pages; the time and date when you downloaded the our software applications or access
or use the Services; the frequency with which your device attempts to contact our servers, time,
and date of those attempts. We collect this information for the purposes described in this Policy,
including to better understand our customer base and to improve the quality of our Services. We
may use this information for any lawful purpose, including, for example, to improve the
performance of the Services or to develop updates.

e) Information That You Manually Provide.

Account Holders. It is your choice whether to provide Personal Information to Intellicheck by

which you may be personally identifiable, such as your first name, last name, email address,
postal mailing address, company or organization affiliation, phone number and other contact
information. The Personal Information we collect on or through Services includes but is not
limited to information that you provide when creating your user's account ("Account") and may
include information provided by the company or organization to which you are affiliated. It is
your responsibility not to provide Personal Information about yourself that could be misused by
others.

Information that you provide to Intellicheck may be collected in the following ways.
i) Registration and Login. Certain Services require you to register for an account with
us. When you register for an Account, you will be asked to provide some personally
identifiable information, such as your full name, email address, and a user name and
password that you select. When you register an Account and log in to a Service, you
must provide your current, complete, and accurate information. It is your
responsibility to keep your information up to date. We are not responsible for any
problems, interruptions in access, or liability that may arise if you do not give us
complete and accurate information or if you fail to update your information so that it
is current.
ii) Payment Data. We will collect data necessary to process your payment if you make
purchases on our websites or through our Services. However, we generally do not

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 view or store credit card holder information, as credit card processing is handled by
third parties.
iii) Correspondence. If you send us personal correspondence, such as emails or letters,
contact us via telephone or through our website, or if other users or third parties send
us information about your use of the Services, we may save the information in a
profile specific to you. We also collect feedback, questions and information that you
provide to us for customer support, surveys and testimonials. We will collect and use
any data files you send to us for troubleshooting and improving our Services. When
you contact us, phone conversations or chat sessions with our representatives may be
monitored and recorded in order to improve our Services, and facilitate the processing
and resolution of your request or complaint.

Individuals Subject to Scans. If you are an individual whose driver's license or government-
issued identification card has been scanned using the Services, the Personal Information we
collect about you is limited to the information related to or presented on your driver’s license or
government-issued identification card and the results of validating your driver’s license or
government-issued identification card. It is your choice whether to provide information relating
to your driver’s license or government-issued identification card to Intellicheck.

f) Information From Other Sources

We may obtain both Personal Information and non-personal information about you from our
business partners, your employer, our customers, our contractors, our suppliers, and other third
parties and add it to our account information or other information we have collected. We and
third parties we engage may combine information we collect from you over time and across our
Services with information obtained from other sources. This helps us improve the information’s
overall accuracy and completeness, and also helps us better tailor our interactions with you.

g) Information Collected in the Past Year

In particular, we have collected the following categories of Personal Information from users in
the last twelve (12) months, using the various methods described above.

Category Examples Collected

A. Identifiers. A real name, alias, postal address, unique personal identifier,
online identifier, Internet Protocol address, email address,
YES
account name, Social Security number, driver’s license
number, passport number, or other similar identifiers.

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Category Examples Collected
B. Personal A name, signature, Social Security number, physical
Information characteristics or description, address, telephone number,
categories listed in passport number, driver’s license or state identification card
the California number, insurance policy number, education, employment,
Customer Records employment history, bank account number, credit card
YES
statute (Cal. Civ. number, debit card number, or any other financial
Code § 1798.80(e)). information, medical information, or health insurance
information.
Some Personal Information included in this category may
overlap with other categories.
C. Protected Age (40 years or older), race, color, ancestry, national origin,
classification citizenship, religion or creed, marital status, medical
characteristics condition, physical or mental disability, sex (including
under California or gender, gender identity, gender expression, pregnancy or YES
federal law. childbirth and related medical conditions), sexual orientation,
veteran or military status, genetic information (including
familial genetic information).
D. Commercial Records of personal property, products or services purchased,
information. obtained, or considered, or other purchasing or consuming YES
histories or tendencies.
E. Biometric Genetic, physiological, behavioral, and biological
information. characteristics, or activity patterns used to extract a template
or other identifier or identifying information, such as,
YES
fingerprints, faceprints, and voiceprints, iris or retina scans,
keystroke, gait, or other physical patterns, and sleep, health,
or exercise data.
F. Internet or other Browsing history, search history, information on a
similar network consumer’s interaction with a website, application, or YES
activity. advertisement.
G. Geolocation Physical location or movements.
NO
data.
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar
NO
information.
I. Professional or Current or past job history or performance evaluations.
employment-related NO
information.
J. Non-public Education records directly related to a student maintained by
education an educational institution or party acting on its behalf, such as
information (per the grades, transcripts, class lists, student schedules, student
Family Educational identification codes, student financial information, or student
NO
Rights and Privacy disciplinary records.
Act (20 U.S.C.
Section 1232g, 34
C.F.R. Part 99)).

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Category Examples Collected
K. Inferences drawn Profile reflecting a person’s preferences, characteristics,
from other Personal psychological trends, predispositions, behavior, attitudes, NO
Information. intelligence, abilities, and aptitudes.

8. Use of Information.

Account Holders. We may use directly or indirectly information collected on the Services,
which may include information gathered about you, for various purposes. In general, we use
Personal Information we collect to pursue our mission and operations, including the management
of the Services and your Account. This may include storing information in connection with your
Account profile so that we can recognize you when you access your Account and determine if
you are using the Services in accordance with the terms of your subscription or your affiliated
company or organization’s subscription. We may also use your Personal Information to operate,
maintain, and improve the Services (including providing you a more personal experience);
communicate with you; provide you information about products and services (including products
and services of third parties); resolve complaints and disputes; collect fees owed; detect and
protect against errors, fraud, and criminal activity; assist law enforcement; enforce this Policy
and any terms related to our Services; an any other purposes described in this Policy or that we
describe to you at the time of collection.

You understand, consent and agree that we may collect, transmit, process, maintain, store,
analyze, and otherwise use data about you and aggregate it with information from multiple users
for the purpose of improving and enhancing the quality and nature of services offered by
Intellicheck, or to market or publish general information and statistics. You also acknowledge
that we may collect, transmit, process, maintain, store, analyze and otherwise use data about you
that relates to your personal use of the Services or Account.

We may use your Personal Information to send you emails or other communications related to
your Account or the Services, or in response to your inquiries or requests. You may not opt-out
of receiving service-related messages that are not promotional in nature. We may also send you
marketing emails, surveys, or newsletters to notify you about products or services that may be of
interest to you. If you would like to stop receiving marketing emails from us, please click on the
unsubscribe link at the bottom of any marketing email you receive. If you opt-out, you will
continue to receive service-related emails.

We reserve the right, but do not undertake a duty, to notify you of court orders, subpoenas or
other legal process if allowed. If you do not want us to respond to legal process compelling us to
disclose your information, you need to seek a valid order permitting us to refuse to disclose it
and serve the order on us at least three (3) business days before the response deadline.

In general, unless otherwise required by law, we will retain your Personal Information only as
long as necessary for the uses described in this Section. We do not undertake retention
obligations through this Policy. We may dispose of information in our discretion without notice,
subject to applicable law.

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Individuals Subject to Scans. If you are an individual whose driver's license or government-
issued identification card has been scanned using the Services, we may use your Personal
Information to provide the Services, including but not limited to, validating your driver’s license
or government-issued identification card, providing details presented on your driver’s license or
government-issued identification card to the person, organization, or entity who used the
Services to execute the scan, and communicating the results of such validation to the person,
organization, or entity who used the Services to execute the scan.

Once a scan of your driver’s license or government-issued identification card is executed using
the Services, we create a temporary copy of such document submitted for scanning and the
results of validating your driver’s license or government-issued identification, which we delete
once the validation is completed. Generally, we do not permanently store a copy of your driver’s
license or government-issued identification card that you submit for scanning except in the
following circumstances:
a) If we have problems validating your driver’s license or government-issued identification
card, we will retain your information for as long as it is required to perform diagnostics,
trouble-shoot the error, rectify the error, or to make improvements to the Services;
If the person, organization, or entity who used the Services to execute the scan requests
that we retain your information, we will do so for as long as it is required to perform
diagnostics, trouble-shoot the error, rectify the error, or to make improvements to the
Services; or
b) We may retain the general information relating to your driver’s license or government-
issued identification card, including but not limited to the following information: date and
time of the executed scan, details regarding the issuer of the identification document,
authenticity and type of identification document, date of issue and date of expiration, and
format and rotation of the identification document. In general, we will retain such
information indefinitely, or as long as legally required or allowed.

9. Information Sharing.

a) General

When we disclose Personal Information to a third party, we enter into a contract that describes
the purpose of the disclosure and requires the recipient to keep that Personal Information
confidential and use it only for performance of the contract, and not for any other purpose. We
disclose your information, including any Personal Information, in the circumstances described
below.

We will not sell or rent any of your Personal Information to third parties for marketing purposes.
However, we may disclose your information to any affiliated entity or organization and to
service providers and the company or organization with which you are affiliated. We may also
share non-identifying information with third parties for any lawful purposes, including analyzing
trends, research, Services administration, tracing users’ movements around the Services, and to
improve our business, products, and Services. Use of information by affiliated entities and

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organizations will be subject to this Policy or an agreement that is at least as restrictive as this
Policy.

In some cases, we may disclose your information as required by law: if we believe that
disclosure is needed to protect our rights; to government regulators; to law enforcement
authorities; in connection with any judicial proceeding, court order, subpoena, or legal process
served on us or the Services; and to respond to a physical threat to you or another person.

Further, if we ever file bankruptcy or engage in a business transition such as merger with another
company or if we sell or reorganize all or a part of the Services or our business or assets, we may
disclose your information, including to prospective or actual purchasers in connection with one
of these transactions.

If you are an individual whose driver's license or government-issued identification card has been
scanned using the Services, we will not generally disclose to third parties a copy of your driver’s
license or government-issued identification card that you submit for scanning or the results of
validating your driver’s license or government-issued identification card except as required by
law or in the context of bankruptcy or business transition (as described above) or in the following
circumstances:

a) We may share the scan of your driver’s license or government-issued identification card
or the results of validating your driver’s license or government-issued identification card
with the person, organization, or entity who used the Services to execute the scan; or
b) If we have problems validating your driver’s license or government-issued identification
card, we may provide the scan of your driver’s license or government-issued
identification card to a third party service provider for the purpose of performing
diagnostics, trouble-shooting the error, rectifying the error, or to making improvements to
the Services.

b) Disclosures of Personal Information in the Past Year

In the preceding twelve (12) months, we have disclosed the following categories of Personal
Information for a business purpose:
 Category A: Identifiers.
 Category B: California Customer Records personal information categories.
 Category C: Protected classification characteristics under California or federal law.
 Category D: Commercial information.
 Category F: Internet or other similar network activity.

We disclosed your Personal Information for a business purpose to the following categories of
third parties:
 The organization or entity who used the Services to process your information.
 Service providers.
 Affiliated companies.

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  Analytics providers.

3. Cookies, Locally Shared Objects and Similar Technologies.

Cookies, pixel tags, clear gifs, log file, web bugs, and locally shared objects are technologies that
install a small amount of information on your device or its software to permit an application to
recognize future visits using your device. We may place cookies, pixel tags, clear gifs, log file,
web bugs, locally shared objects, or similar technology in the Services or on your hardware or
device (including on its browser). These technologies may enhance the convenience and use of
the Services. For example, the information provided through cookies may be used to recognize
you as a previous user of the Services (so you do not have to enter your Personal Information
every time), offer personalized information for your use, and otherwise facilitate your experience
using the Services. Some cookies remain on your computer or device until you delete them.
Others, like session ID cookies, expire when you close your browser. If you choose to access or
use the Services, you may not be able to decline all tracking technologies. You may decline
cookies or other technologies through your device, browser or application settings, but this
decision may affect your ability to access or use certain features of the Services.

4. Steps To Keep Personal Information Secure.

Keeping secure the Personal Information that we collect is of great concern to us. We exercise
care in providing secure transmission of your information from your computer to our servers in
connection with the Services. Personal Information collected by, through, or in the Services is
stored in secure operating environments that are not available to the public. While Intellicheck
has mechanisms in place to safeguard your personal information once we receive it, no
transmission of data across servers over the Internet or any other public network can be
guaranteed to be 100% secure. When you provide information to the Services, you do so at your
own risk.

5. Persons Under the Age of 18.

The Services are intended for users that are 18 or older and are not directed to anyone under the
age of 18. We do not knowingly collect Personal Information from anyone under the age of 18.
If you become aware that a person under the age of 18 has provided us with personal information
without parental consent, please contact us by using the contact information at the bottom of this
Policy, and we will take steps to remove the information and terminate that person’s Account.

6. Accessing and Updating Your Personal Information.

If you would like to cancel your Account or update your Personal Information associated with
your Account, you may make such changes by logging into your Account and modifying the
applicable fields or contacting Intellicheck. If you do not want your information accessed or
stored as described in this Policy, you should not access, use, or register an Account with the
Services, and you should not access or use the Services.

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 7. Notice to Users Outside the United States.

We are headquartered in the United States. Except as stated in Section 11 below, the Services are
governed by United States law. If you are using any of our products or services from outside of
the United States, your information may be transferred to, stored and processed in the United
States where our servers are located. The United States might not have the same standard of legal
privacy protection as Europe. By using any of our products or services and/or communicating
with us via mail, email or telephone, you consent to your information being transferred to our
facilities in the United States and to the facilities of those third parties with whom we share it as
described in this Policy.

h) California Residents.

a) California Shine the Light Law

California Civil Code § 1798.83 permits users who are California residents to obtain from us
once a year, free of charge, a list of third parties to whom we have disclosed Personal
Information (if any) for direct marketing purposes in the preceding calendar year. If you are a
California resident and you wish to make such a request, please send an e-mail with “California
Privacy Rights” in the subject line to privacy@intellicheck.com or write us at Intellicheck, Inc.;
200 Broad Hollow Road; Melville, New York 11747.

b) California Minors

While the Services are not intended for anyone under the age of 18, if you are a California
resident who is under age 18 and you are unable to remove publicly-available content that you
have submitted to us, you may request removal by emailing us at privacy@intellicheck.com or
writing us at Intellicheck, Inc.; 200 Broad Hollow Road; Melville, New York 11747. When
requesting removal, you must specify the information you want removed and provide us with
specific information, such as the URL for each page where the information was entered, so that
we can find it. We are not required to remove any content or information that: (1) federal or state
law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that
you cannot be identified; (4) you do not follow our instructions for removing or requesting
removal; or (5) you received compensation or other consideration for providing the content or
information. Removal of your information from the Services do not ensure complete or
comprehensive removal of that information from our systems or the systems of our service
providers. We are not required to delete information posted by you; our obligations under
California law are satisfied so long as we anonymize the information or render it invisible to
other users and the public.

c) California Consumer Privacy Act (CCPA)

In addition to the disclosures made above, California residents are entitled to additional rights
under the CCPA. If you are a California resident, please see the Intellicheck Privacy Addendum
for California Residents for further information regarding your CCPA rights and how to exercise
them in relation to the Services.

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 d) Canada Residents.

The Services and our privacy practices are compliant with The Personal Information Protection
and Electronic Documents Act (“PIPEDA”) fair information principles. In addition to the
disclosures made above, we:
 Have appointed a privacy officer to monitor our compliance with PIPEDA.
 Only collect Personal Information for the uses described in Section 3 above.
 Only use and disclose Personal Information as described in Section 3 and 4 above.
 Take reasonable steps to verify the accuracy of the Personal Information we collect.
 Take appropriate safeguards to protect the Personal Information, as further described in
Section 6 above.
 Implement reasonable technical and organizational measures to safeguard Personal
Information and, to the extent we share your Personal Information with third parties who
process it on our behalf, we instruct the third parties to process and manage your Personal
Information in a manner consistent with Intellicheck standards and the standards of the
company or organization that has engaged us to provide services to it, as may be
applicable.
If you are a Canada resident, you have the right to request access to the existence, use and
disclosure of your Personal Information. Additionally, you have the right to challenge the
accuracy and completeness of the information and request to have it amended as appropriate.
Finally, you have the right to challenge Intellicheck’s compliance with the PIPEDA fair
information principles by contacting our privacy officer. To exercise your rights under this
Section, please send an e-mail to privacy@intellicheck.com or write us at Intellicheck, Inc.; 200
Broad Hollow Road; Melville, New York 11747.

5. Changes to Our Policy.

It is our practice to post any changes we make to our Policy on this page and update the “last
modified” date at the top of this document. The date the Policy was last revised is identified at
the top of the page. You should periodically visit our Policy to check for any changes.

6. Privacy Questions.

If you have questions or concerns about our privacy practices, please send an e-mail to
privacy@intellicheck.com or write us at Intellicheck, Inc.; 200 Broad Hollow Road; Melville,
New York 11747.

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Intellicheck Privacy Addendum for California Residents
Last Revised: 6-25-2020
This Privacy Addendum for California Residents (“Addendum”) supplements the information
contained in the Intellicheck Privacy Policy and applies solely to individuals who reside in the
State of California ("consumers" or "you"). We adopt this Addendum to comply with the
California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the
CCPA have the same meaning when used in this Addendum.

1. Right to Access Specific Information and Data Portability Right.

You may have the right under the CCPA to request that we disclose certain information to you
about our collection and use of your Personal Information over the past twelve (12) months.
Once we receive and confirm your verifiable consumer request, we will disclose to you:
 The categories of Personal Information that we have collected about you.
 The categories of sources for the Personal Information that we have collected about you.
 Our business or commercial purpose for collecting or making available that Personal
Information.
 The categories of third parties with whom we share that Personal Information.
 The specific pieces of Personal Information that we have collected about you (also called
a data portability request).
 If we disclosed your Personal Information for a business purpose, the business purpose
for which such Personal Information was disclosed, and the Personal Information
categories that each category of recipient obtained.
 If applicable, (1) the categories of your Personal Information that we have made available
for valuable consideration; (2) the categories of third parties to whom such Personal
Information was made available; and (3) the category or categories of Personal
Information that we have made available to each category of third parties.

b) Right to Delete.

You may have the right under the CCPA to request that we delete any of your Personal
Information that we have collected from you and retained, subject to certain exceptions. Once we
receive and confirm your verifiable consumer request, we will delete (and direct our service
providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) or vendor(s) to:
 Complete the transaction for which we collected the Personal Information, provide a
good or service that you requested, take actions reasonably anticipated within the context
of our ongoing business relationship with you, or otherwise perform our contract with
you.
 Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.

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  Debug products to identify and repair errors that impair existing intended functionality.
 Exercise free speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law.
 Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
1546 et. seq.).
 Engage in public or peer-reviewed scientific, historical, or statistical research in the
public interest that adheres to all other applicable ethics and privacy laws, when the
information’s deletion may likely render impossible or seriously impair the research’s
achievement, if you previously provided informed consent.
 Enable solely internal uses that are reasonably aligned with consumer expectations based
on your relationship with us.
 Comply with a legal obligation or legal order.
 Make other internal and lawful uses of that information that are compatible with the
context in which you provided it.

c) Right to Opt-Out.

If you are 16 years of age or older, you may have the right under the CCPA to direct us not to
make your Personal Information available for valuable consideration at any time (the “right to
opt-out”). We do not make available the Personal Information of consumers we actually know
are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”)
from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a
consumer less than 13 years of age. Consumers who opt-in may opt-out at any time.

To exercise the right to opt-out or right to opt-in, you (or your authorized representative) may
submit a request to us by sending us an e-mail at privacy@intellicheck.com or writing us at
Intellicheck, Inc.; 200 Broad Hollow Road; Melville, New York 11747. Once you make an opt-
out request, we will wait at least twelve (12) months before asking you to reauthorize certain
information sharing practices. However, you may change your mind and opt back in at any time
by notifying us using the contact information set out above. We will only use Personal
Information provided in an opt-out request to review and comply with the request.

d) Exercising Your Rights.

To exercise the access, data portability, and deletion rights described above, please submit a
verifiable consumer request to us by either:

Calling us at +1-866-702-6069
Sending us an e-mail at privacy@intellicheck.com
Writing us at Intellicheck, Inc.; 200 Broad Hollow Road; Melville, New York 11747

Only you, or a person registered with the California Secretary of State that you authorize to act
on your behalf, may make a verifiable consumer request related to your Personal Information.
You may also make a verifiable consumer request on behalf of your minor child.

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You may only make such a request for access or data portability twice within a twelve (12)
month period. The verifiable consumer request must provide sufficient information that allows
us to reasonably verify you are the person about whom we collected Personal Information or an
authorized representative, and describe your request with sufficient detail that allows us to
properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify
your identity or authority to make the request and confirm the Personal Information relates to
you. Making a verifiable consumer request does not require you to create an account with us. We
will only use Personal Information provided in a verifiable consumer request to verify the
requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its
receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and
extension period in writing. We will deliver our written response electronically. Any disclosures
we provide will only cover the twelve (12) month period preceding the verifiable consumer
request’s receipt. The response we provide will also explain the reasons we cannot comply with a
request, if applicable. For data portability requests, we will select a format to provide your
Personal Information that is readily useable and should allow you to transmit the information
from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee,
we will tell you why we made that decision and provide you with a cost estimate before
completing your request.

e) Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted
by the CCPA, we will not:
 Deny you goods or services.
 Charge you different prices or rates for goods or services, including through granting
discounts or other benefits, or imposing penalties.
 Provide you a different level or quality of goods or services.
 Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in
different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will
reasonably relate to your Personal Information’s value and contain written terms that describe
the program’s material aspects. Participation in a financial incentive program requires your prior
opt in consent, which you may revoke at any time.

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