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Biometric Data Policy and Notice

Effective date: 23 October 2026

1. Purpose

American Well Corporation, on behalf of itself and its affiliated provider groups that comprise Amwell Medical Group (collectively, “Amwell”) has adopted this Biometric Data Policy and Notice (this “Policy”) to govern the treatment of Biometric Data of job applicants, employees, and contractors. Protecting the confidentiality and integrity of Biometric Data is a critical responsibility that must be taken seriously at all times. Compliance with this Policy is mandatory.

2. Scope

This Policy applies to all employees, agents, and representatives, including any contractor or third-party identity verification service provider to Amwell (“ID verification provider”) who have access to Biometric Data. This Policy applies to all Biometric Data collected, maintained, transmitted, stored, retained, or otherwise used regardless of the media on which that information is stored and whether relating to job applicants, employees, or contractors.

3. Definitions

“Biometric Identifiers” means identifiers such as retina or iris scans, fingerprints, voiceprints, or scans of hand or face geometry. “Biometric Information” means information, regardless of how it is captured, converted, stored, or shared, that is based on a Biometric Identifier. “Biometric Data” means collectively all Biometric Identifiers and Biometric Information.

Amwell’s ID verification provider may require you to upload an image of your government issued or other identification document(s) as well as your photographic image or 'selfie' photograph. The ID verification provider will use these images to create or derive facial geometry or faceprint for identity proofing and for the detection and prevention of fraud (“Facial Biometrics”).  

4. Biometric Data Collection 

Amwell’s third-party ID verification provider may collect, store, and use Facial Biometrics for permitted purposes of verifying an individual’s identity, and detection and prevention of fraud. Before collecting Biometric Data from any individual, The ID verification provider will obtain the individual’s written consent to the collection, which may be provided electronically. 

Amwell does not actually receive, possess, or otherwise have access to your Biometric Data collected by the ID verification provider. The result of the identity verification process is not itself Biometric Data.

For more information about how the ID verification provider collects, uses, and discloses Biometric Data please read https://withpersona.com/legal/privacy-policy. 

5. Retention Schedule 

In circumstances where Amwell’s ID verification provider retains Biometric Data, the ID verification provider will permanently destroy an individual’s Biometric Data within three (3) years of collection or when the initial purpose for collecting or obtaining such identifiers or information has been satisfied.

The ID verification provider may retain Biometric Data for a longer period where required by a subpoena, warrant, or other legally compelling justification.

6. Biometric Data Security

Amwell and its ID Verification Provider shall use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic Biometric Data collected.

7. Biometric Data Disclosures

Subject to individual consent, Amwell’s ID Verification Provider may disclose an individual’s Biometric Data to its third-party vendors in order to facilitate job applicant identity verification.

Amwell prohibits any further disclosure or re-disclosure of Biometric Data unless:

  • The individual or the individual’s legally authorized representative consents to the disclosure;
  • The disclosure is required by applicable law or regulation; or
  • The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Amwell and its ID Verification Provider do not sell, lease, trade, or otherwise profit from Biometric Data.