Nordic Energy Services, LLC (the “Company”) has instituted the following Biometric Information Privacy Policy (the “Policy”) as of June 4, 2025. This Policy applies to all Company locations both within and outside Illinois:
Biometric Data Defined
As used in this Policy, biometric data includes “biometric identifiers” and “biometric information” as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996.
“Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.
Purpose for Collection of Biometric Data
Company and its third-party verification, facial recognition software, and voice comparison vendors (“Vendors”) may collect and store voiceprints, retina or iris scans, and scans of face geometry for the purpose of verifying the identities of its third-party sales agents and customers to aid in preventing fraudulent enrollments.
Disclosure and Authorization
To the extent that the Company and/or its Vendors collect, capture, otherwise obtain, store, and retain biometric data relating to any individual, the Company must first:
- Inform the individual in writing that the Company and its Vendors are collecting, capturing, otherwise obtaining, storing, retaining, and using the individual’s biometric data, and that the Company is or may be providing such biometric data to Vendors.
- Inform the individual in writing of the specific purpose and length of time for which the individual’s biometric data is being collected, stored, and used; and
- Receive a written release signed by the individual (or his or her legally authorized representative) authorizing the Company and its Vendors to collect, store, retain and use the individual’s biometric data for the specific purposes disclosed by the Company.
The Company and its Vendors will not sell, lease, trade, or otherwise profit from the aforementioned biometric data; provided, however, the Company’s Vendors may be paid for products or services used by the Company that utilizes such biometric data and may pay its third-party salespeople who submit such biometric data for their subsequent performance of services.
Disclosure
The Company will not disclose or disseminate any biometric data to anyone other than its Vendors providing products and services using biometric data without/unless:
- First obtaining written consent to such disclosure or dissemination;
- The disclosed data completes a financial transaction requested or authorized by the individual;
- Disclosure is required by state or federal law or municipal ordinance; or
- Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
Retention Schedule
The Company shall retain biometric data only until, and shall request that its Vendors permanently destroy such data within a reasonable time when, the first of the following occurs:
- The initial purpose for collecting or obtaining such biometric data has been satisfied; or
- Within 3 years of the last interaction with the Company by the individual.
Data Storage
The Company shall use a reasonable standard of care as used in the industry to store, transmit and protect from disclosure any biometric data collected. Such storage, transmission, and protection from disclosure shall also be performed in a manner that is the same as or more protective than the manner in which Company stores, transmits and protects from disclosure other confidential and sensitive information.
Consent
Each third-party salesperson must execute a copy of the Consent Form attached to this Policy for the collection, use, and retention of their biometric data as described herein as a prerequisite to performing or continuing to perform any services for the Company.
Each consumer must have executed the written authorization as part of their enrollment process, which references and attaches this Policy, for the collection, use, and retention of their biometric data as described herein.
