Biometric Data Retention Policy

1. Purpose of This Policy

Extropolis Corp. (“NeuralSpeaker,” “we,” “us”) publishes this Biometric Data Retention Policy to satisfy the publicly available written policy requirement under the Illinois Biometric Information Privacy Act (BIPA), 740 ILCS 14/15(a), and to provide equivalent disclosure under the Texas Capture or Use of Biometric Identifier Act (CUBI), Tex. Bus. & Com. Code Chapter 503.

This policy describes the types of biometric data NeuralSpeaker may collect, the purposes for which it is collected, the retention period, and the process by which biometric data is permanently destroyed.

2. What Biometric Data We Collect

When a user consents to Personalized Voice Model Training (optional consent, not required for basic transcription), NeuralSpeaker may collect:

• Voice recordings — raw audio files of the user’s speech, stored in Cloudflare R2 cloud storage.
• Personalized voice model — a mathematical representation of the user’s vocal characteristics (voiceprint / biometric template), derived from voice recordings and stored in Cloudflare R2. This model may constitute a “biometric identifier” under BIPA and CUBI.

Transcription text derived from voice recordings is not considered a biometric identifier and is handled separately under our Privacy Policy.

3. Purpose of Collection

Biometric data is collected solely for the following purpose:

• To train a personalized AI speech model that improves transcription accuracy and text-to-speech output for the individual user.
• No other purpose. We do not use biometric data for advertising, cross-user model training, or any secondary purpose beyond personalizing the user’s own assistive speech experience.

4. Retention Schedule

NeuralSpeaker internal SLA: Biometric data will be destroyed within 7 days of any of the following trigger events, whichever occurs earliest:

• Account deletion request from the user
• Withdrawal of model training consent (via Settings → Privacy → Privacy & Consent)
• Statutory BIPA deadline (3 years from last interaction)
• Statutory CUBI deadline (1 year from last interaction)
• Purpose fulfillment (user no longer uses the personalized model)

5. Destruction Method

Biometric data is permanently destroyed by:

1. Permanently deleting all audio files and voice model files from Cloudflare R2 object storage (irreversible delete operation with no recovery path).
2. Removing associated metadata from Supabase database records.
3. Recording the destruction event and timestamp in the internal biometric_retention_schedule compliance table.

Encrypted backup copies are purged within 90 days of the primary deletion as part of the standard backup rotation schedule.

6. No Sale of Biometric Data

NeuralSpeaker will never sell, lease, trade, or otherwise profit from any user’s biometric identifiers or biometric information, as required by BIPA 740 ILCS 14/15(c) and CUBI Tex. Bus. & Com. Code § 503.001(b).

7. Disclosure to Third Parties

Biometric data is transmitted to the following data processors solely to provide the service. No processor is authorized to use biometric data for any purpose other than performing services for NeuralSpeaker:

• Cloudflare, Inc. (R2) — stores raw audio files and voice models at rest.
• Modal Labs, Inc. — processes audio transiently during transcription inference and model training. Data is not retained on Modal infrastructure after the task completes.

8. Requesting Destruction

To request immediate destruction of your biometric data before the statutory deadline:

• Via the app: Settings → Privacy → Delete My Data, or withdraw model training consent at Settings → Privacy → Privacy & Consent.
• Via email: [email protected]. We will process verified deletion requests within 7 days.

9. Contact

Questions about this policy:

Extropolis Corp.
Email: [email protected]