Brilliant Earth Biometric Data Privacy and Retention Policy

Last Updated: November 3, 2025

Brilliant Earth, LLC (“Brilliant Earth”, “we”, “our” or “us”) has instituted the following Biometric Data Privacy and Retention Policy (“Policy”) related to Biometric Data that may be collected and stored as described in this Policy.

Biometric Data Defined

“Biometric Data” includes, but is not limited to, “biometric identifiers” and “biometric information” as defined in all applicable laws or regulations governing the collection, possession or use of biometric data, biometric information, or biometric identifiers. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, that is based on an individual’s biometric identifier.

Collection of Biometric Data

Where required by law, Brilliant Earth, including through its vendors, will obtain written consent to collect, retain, and use Biometric Data prior to collection of such data.

Biometric Data may be collected via the Virtual Try On features provided on Brilliant Earth’s website. Biometric Data will be used solely to provide such Virtual Try On features, including to superimpose a resizable rendering of the jewelry viewed through the feature to help users visualize how our jewelry may look on the user, and to allow the user to share a copy of the photo with others.

Disclosures of Biometric Data

Brilliant Earth and its vendors will not disclose, sell, lease, trade, or otherwise profit from your Biometric Data; provided, however, Brilliant Earth’s vendors may be paid for products or services used by Brilliant Earth that collect and utilize such Biometric Data. Any authorized vendors that receive Biometric Data from Brilliant Earth or are provided access to Biometric Data by Brilliant Earth are obligated to maintain the confidentiality and security of such Biometric Data.

Brilliant Earth will not disclose or disseminate a user’s Biometric Data to any person or entity other than Brilliant Earth’s personnel and/or its vendors with a need-to-know of such data without/unless:

a. first having the user’s written consent to such disclosures or dissemination;

b. disclosure is required by a municipal ordinance or local, state, or federal law; or

c. disclosure is required by a valid warrant or subpoena issued by a court of competent jurisdiction.

Biometric Data Storage

Brilliant Earth and its vendors shall use a reasonable standard of care to store, transmit and protect from disclosure any Biometric Data collected, and shall store, transmit, and protect from disclosure all Biometric Data in a manner that is the same as or more protective than the manner in which Brilliant Earth stores, transmits, and protects other personal information that can be used to uniquely identify an individual or an individual’s account or property, such as account numbers, PINs, driver’s license numbers, and social security numbers.

Biometric Data Retention and Destruction

 Brilliant Earth will destroy or cause the destruction of a user’s Biometric Data (in the possession of Brilliant Earth or its vendors) within thirty (30) days of satisfying the initial purpose for collecting or obtaining such Biometric Data or three (3) years of collection or the initial purpose for collecting or obtaining such identifiers or information has been satisfied, whichever occurs first; provided, however, that the foregoing may not apply if Brilliant Earth is required or permitted by law to retain the Biometric Data for a longer period of time. The initial purposes for collection end when a user last interacts with the Virtual Try On features.