Biometric Data Retention and Destruction Policy

Effective Date: September 1, 2025

Entity: Atlas Truck Center

Atlas Truck Center (the "Company") utilizes a video surveillance and facility management system equipped with Artificial Intelligence (AI) recognition technology. This system is used to enhance the security of our semi-truck parking lot, protect customer assets in our repair shop, and manage authorized access to our premises. In the course of these operations, the Company may collect "biometric identifiers" and "biometric information" (collectively, "Biometric Data").

• Biometric Identifier: Includes retina or iris scans, fingerprints, voiceprints, or scans of hand or face geometry. Our system specifically utilizes scans of face geometry and/or automated license plate recognition (LPR) data.
• Biometric Information: Any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.

The Company will retain Biometric Data only until the first of the following events occurs:

1. The initial purpose for collecting or obtaining such Biometric Data has been satisfied (e.g., a driver is no longer authorized to access the lot, or an insurance claim regarding a specific incident has been resolved); or
2. Three (3) years have passed since the individual’s last interaction with the Company’s facility or systems.

Once the retention period expires, the Company shall permanently destroy the Biometric Data.

• Electronic Data: Data will be purged and overwritten from our local servers and cloud-based storage using industry-standard data deletion protocols to ensure the information is irrecoverable.
• System Backups: Any data contained in system backups will be deleted during the next standard backup rotation cycle, not to exceed 90 days from the primary deletion date.

The Company stores and protects Biometric Data using a reasonable standard of care within the trucking and security industries. This includes encryption of data both at rest and in transit.

• Prohibition on Profit: The Company does not sell, lease, trade, or otherwise profit from any Biometric Data collected.
• Limited Disclosure: The Company will not disclose Biometric Data unless:
  • The subject (or their authorized representative) provides written consent;
  • The disclosure is required to complete a financial transaction requested by the subject;
  • The disclosure is required by state/federal law or a valid warrant/subpoena.

This policy is made available to the public and all employees/contractors. For questions regarding this policy, please contact the Property Manager at our Harvey, IL office.