Iron Lock — Biometric Data Notice & Consent
Effective date: July 1, 2026 Provided by: Revivo Project Inc., dba Iron Lock — 1303 E Warner Avenue, Santa Ana, CA 92705, USA — info@shopironlock.com
This Biometric Data Notice & Consent ("Notice") explains how fingerprint functionality works on Iron Lock smart safes and is provided to satisfy applicable biometric-privacy laws, including the Illinois Biometric Information Privacy Act (BIPA, 740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (CUBI), Washington's biometric law (RCW 19.375), and, for applicable users, the GDPR (Article 9). It supplements our Privacy Policy. This Notice is publicly available at the URL where our Privacy Policy is posted, and is presented in the app before any fingerprint is enrolled.
This Notice is provided for transparency and is not legal advice.
1. The key point first
Iron Lock does not collect, receive, store, or have access to your fingerprint or any fingerprint template. When you enroll a fingerprint, the scan is captured and converted into a mathematical template entirely on your safe's on-device fingerprint sensor. That template never leaves the sensor — it is never sent to the Iron Lock app, our servers, the cloud, or any third party, and we cannot see, copy, export, or reconstruct it.
2. What enrollment actually does
To enroll a fingerprint, you place the same finger on the safe's sensor several times so the sensor can build a reliable template. The Iron Lock app only:
- tells the safe to start or stop enrollment,
- shows you the progress, and
- lets you assign a slot number and a text label you choose (for example, "Slot 2 — Right Thumb").
The slot number and label are not biometric information and cannot identify you or recreate a fingerprint. They simply let you manage which enrolled fingerprints belong to which person.
3. Purpose
The sole purpose of fingerprint functionality is to let you unlock your safe with your fingerprint. We do not use any biometric data for identification across users, marketing, profiling, analytics, or any purpose other than operating the safe — and again, we never hold the biometric data in the first place.
4. No sale, lease, trade, or disclosure
We do not, and cannot, sell, lease, trade, disclose, redisclose, or otherwise profit from your fingerprint or any biometric identifier or biometric information, because we never possess it. The slot reference and label are never sold or shared for any third party's own purposes.
5. Retention and destruction schedule
- Fingerprint template (on the safe): retained on the sensor only until you delete that fingerprint in the app or perform a factory reset of the safe, at which point the sensor erases it.
- Slot reference and label (in your account): deleted when you remove the fingerprint, remove the associated member, or delete your account.
- Outer limit: in no event is any biometric-related reference retained longer than necessary to provide the Services or, where a law such as BIPA imposes an outer bound, beyond 3 years after your last interaction with us, whichever is earlier. Where a shorter statutory bound applies (for example, Texas CUBI's requirement to destroy a biometric identifier within a reasonable time and no later than 1 year after the purpose for collecting it expires), we honor the shorter period.
Because we hold no biometric template, there is no biometric template on our side to schedule for destruction; the only destruction we control is of the non-biometric slot reference, on the schedule above.
6. How to delete a fingerprint
In the app, open the member or fingerprint manager, select the fingerprint slot, and choose delete. This removes the slot reference from your account and instructs the safe to erase the template from the sensor. A factory reset of the safe also erases all enrolled templates from the sensor.
7. It's optional — alternatives
Fingerprint unlock is always optional. You can use your safe with a numeric access code (PIN) or the mechanical backup key instead. You may decline fingerprint enrollment and still use all other features.
8. Enrolling someone else's fingerprint
If you enroll another person's fingerprint (for example, a family member, guest, cleaner, or employee), you represent that, before enrolling them, you showed that person this Notice and obtained their permission — and, where a law such as BIPA requires it, their written consent. Where the person is a minor, you represent that you are their parent or legal guardian, or otherwise authorized to consent on their behalf, and that consent for a minor's fingerprint is given by that guardian. Each person whose fingerprint is enrolled is entitled to the protections described here. You are responsible for meeting these obligations and, as described in the Iron Lock Terms of Service, for indemnifying Iron Lock against claims arising from a failure to do so.
9. Security
Fingerprint templates are protected by remaining on the safe's dedicated sensor hardware and never traversing the network. As with any physical security product, no system is infallible; please also follow the general security guidance in our Privacy Policy and Terms.
10. Your rights and contact
You may ask questions, withdraw consent, or request deletion at any time by using the in-app controls or emailing info@shopironlock.com. Withdrawing consent and deleting your enrolled fingerprints does not affect PIN or mechanical-key access.
11. Consent and written release
By tapping "I Agree & Enroll Fingerprint," you acknowledge that you have read and understood this Notice, and you provide your informed consent and, where applicable, your written release authorizing:
- the capture and storage of your fingerprint on the safe's on-device sensor only, and
- Iron Lock's handling of the non-biometric slot reference and label as described above,
for the purpose of operating your safe, for the term of your use of the fingerprint feature and the retention period described in Section 5. You understand that Iron Lock never receives your fingerprint or fingerprint template, that enrollment is optional, and that you may withdraw consent and delete your fingerprint at any time. You agree that your affirmative action to accept this Notice — checking the consent box and/or tapping "I Agree & Enroll Fingerprint" — constitutes your electronic signature and written release for purposes of BIPA and other applicable laws.
If you do not agree, tap Cancel — you can still use your PIN or mechanical key.
On-screen version (exact in-app copy)
Set up fingerprint unlock
Your fingerprint is stored only on your safe's sensor. It is never sent to the Iron Lock app, our servers, or anyone else — we never see it and can't recover it.
We only save a slot number and the label you choose (like "Right Thumb") so you can manage your fingerprints. You can delete a fingerprint anytime, which erases it from the safe. Fingerprint unlock is optional — you can always use your PIN or your key.
By tapping "I Agree & Enroll Fingerprint," you consent to enrolling your fingerprint on the safe and agree this is your electronic signature for biometric-consent laws. See the full Biometric Notice and Privacy Policy.
[ I Agree & Enroll Fingerprint ] [ Cancel ]
Links: Biometric Notice · Privacy Policy
Implementation requirements (must ship before any enrollment is offered):
- This must be a separate, affirmative opt-in screen shown before the first fingerprint is enrolled — not pre-checked, not bundled into a general "I accept the Terms" checkbox.
- Log a timestamped consent event (who consented, which account, version of this Notice) when the user taps "I Agree & Enroll Fingerprint."
- Re-prompt if this Notice materially changes.
- The "Biometric Notice" and "Privacy Policy" links must open the live hosted documents.