Biometric Data Retention and Destruction

This is our written policy for keeping and destroying biometric information, published because Illinois’ Biometric Information Privacy Act requires it to be public and separate rather than buried in a longer document. It applies to everyone, not only to people in Illinois; where a stricter rule applies where you live, the stricter one wins. Section 4 of the Privacy Policy explains the same processing in context, and nothing here replaces it.

1. What we process, and what we do not

A session is a live video conversation, so a camera reads your face and a microphone hears your voice. To hold that conversation and to tell you anything useful about how you came across, our video provider Tavus processes your facial geometry and your voice while the session is running. In Illinois, Texas and Washington, and in some other places, that processing is regulated as biometric information.

We do not generate or store a biometric identifier or template of any kind. There is no faceprint, no voiceprint, and no mathematical representation of you that could be matched against anybody else or against any database. We do not use any of this to identify you, and we do not compare you to another person.

What we do keep is the recording of the session, the transcript, and prose notes about your delivery, meaning pacing, composure, eye contact and body language, stored as text. We are conscious that a recording of your face and voice is, in some jurisdictions, capable of being treated as biometric information in its own right. That is why it is covered by the schedule below rather than argued out of it.

2. Why we process it

Two purposes, and no others: running your session, and generating your feedback. It is not used for identification, for marketing, for training a facial-recognition system, or for any decision about you beyond the practice feedback you asked for.

We ask for your explicit, separate consent before your first session and we record that you gave it, with the version of the policy in force at the time. You are not required to consent, but the service genuinely cannot run without it, because there is no version of a live video interview that does not involve a camera reading your face.

3. Retention schedule

Everything below is destroyed at the earlier of the date given and the point at which the purpose in section 2 has been satisfied. Illinois’ outer limit is three years from your last interaction with us; we measure the 3 years from the session itself, which is at or before that limit in every case.

4. How destruction actually happens

• On schedule. Recordings expire under a storage lifecycle rule, not because someone remembers to run a script. Deletion is the default behaviour of the system rather than a task on a list.
• When you close your account. Deactivating from your profile starts a 30-day grace period during which you can change your mind. After it expires the account cannot be reactivated and your session content is deleted, including the recordings, and we ask Tavus to delete its own copies.
• When you ask. Email privacy@whitecoatprep.com and we will delete an individual recording, or all of them, without closing your account. Deleting a recording does not delete the feedback built from it, so your progress record survives unless you ask us to remove that too.
• Permanently. Destruction means the file is gone, including stored earlier versions of it, not that it is hidden from you while we keep a copy.

5. Licensing, and where it does not operate

We are not going to make you a blanket promise never to profit from this, because there is one route by which we can, and you are entitled to read it here rather than find it in another document. Section 5 of the Privacy Policy describes an optional licensing programme: if, and only if, you separately opt in, your recording may be licensed to a third party and we are paid for it. It is off unless you switch it on, it is not bundled into accepting the Terms, it is not a condition of using the service or of any price you pay, and you can withdraw it. Everything else on this page applies to a licensed copy too, and the licence requires the other party to delete it within 30 days of us withdrawing the record.

Illinois is different, and it is a hard exclusion rather than a stricter default. BIPA prohibits selling, leasing, trading or otherwise profiting from biometric identifiers and biometric information outright, so the licensing programme does not operate in Illinois at all, regardless of what anyone has opted in to. That is enforced as an exclusion in code rather than as a preference someone could tick past.

Separately from licensing, we do not disclose your biometric information to anyone except the providers who make the session work, named in section 3 of the Privacy Policy, and then only for the purposes in section 2 above. We do not hand it to anyone else for their own purposes without your separate consent, and never where the law prohibits it.

6. Withdrawing consent

You can withdraw at any time by deactivating your account from your profile or by emailing privacy@whitecoatprep.com, and that is the only mechanism there is. Because a session cannot run without this processing, withdrawal is the end of the account rather than a checkbox beside it, and we would rather name the real door than describe one that is not there. Withdrawing stops any future processing; it does not undo sessions you have already completed, though you can ask us to delete their results.

7. Changes to this policy

If we change how long we keep any of this, or how it is destroyed, we will publish the change here and give registered users at least 14 days’ notice by email or in-product message before it takes effect. The effective date at the top of this page is the version in force.