Biometric Information Policy

Purpose

This Biometric Information Policy (“Policy”) defines the policy and procedures for collection, use, safeguarding, storage, retention, and destruction of biometric information collected by Fuji Food Products, Inc. (“Company”).

Biometric Information

As used in this Policy, “biometric information” means personal information stored by the Company about an individual’s physical characteristics that can be used to identify that person. By way of example, biometric information includes iris scan, fingerprints, voiceprints, or a scan of hand or face geometry. Biometric dates does not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color.

General Policy

The Company will protect and store biometric information in accordance with applicable standards and laws including, the Illinois Biometric Information Privacy Act.

The Company will not collect or otherwise obtain an individual’s biometric information without the prior written consent of the individual. The Company will inform the individual of the reason his or her biometric information is being collected and the length of time the information will be stored. A sample consent statement is included in this policy and will be tailored to fit the type of biometric information collected.

The Company will not sell, lease, trade, or otherwise profit from an individual’s biometric information.

The Company will not disclose biometric information unless (a) consent is obtained from the individual, (b) disclosure is necessary to complete a financial transaction requested or authorized by the individual, (c) disclosure is required by law, or (d) disclosure is required by subpoena.

Biometric information will be stored, transmitted, and protected from disclosure using a reasonable standard of care for the Company’s industry and in a manner that is the same or exceeds the standards used to protect other confidential information held by the Company. As used in this Policy, “other confidential information” means personal information that can be used to uniquely identify an individual or an individual’s account or property, including by way of example: a genetic marker, genetic testing information, a unique identifier number to locate an account or property, an account number, a PIN number, a pass code, a driver’s license number, or a social security number.

The Company will destroy biometric information when the initial purpose for obtaining or collecting the information has been fulfilled.
The Company may amend this Biometric Information Security Policy at any time.

A copy of this policy will be made publicly available at www.fujifood.com.

PROCEDURE

The Company collects, stores, and uses employee fingerprint data in conjunction with its time and payroll management software and in order to provide employees access to certain Company electronic devices such as IPads.

Before collecting an employee’s fingerprint data, the Company will obtain the consent of the employee.

The Company will store, transmit, and protect biometric information using the same standard of care and security controls it provides other confidential information in its possession.

The Company will permanently destroy an employee’s biometric information from the Company’s systems upon the employee’s termination from the Company.

If the Company begins collecting biometric information for any additional purpose, the Company will update this procedure.

SAMPLE CONSENT TO COLLECTION OF BIOMETRIC INFORMATION

The Company will collect, store, and use fingerprint data (“Biometric Information”) in order to verify your identity for time and payroll management software and to potentially provide you access to certain Company electronic devices such as IPads.

The Company will not disclose your Biometric Information without your consent unless the disclosure is required by law or by subpoena.

The Company will delete your Biometric Information from the Company’s systems when your employment with the Company ends.

A copy of the Company’s Biometric Information Policy is available upon request and is posted at www.fujifood.com.