Biometric Data Policy

Biometric Data Policy Written policy, retention schedule and consent — LABAU Concierge Drivers

STATUS DRAFT FOR REVIEW BY KING & JURGENS LLC. Biometric privacy law is state-

specific and carries statutory penalties and, in some states, a private right of action. This policy must be reviewed against New York law and against the law of any state in which a LABAU driver resides before any biometric verification is enabled.

Effective date: ______________________ This Biometric Data Policy describes how LABAU Holdings, Inc. (“LABAU”) uses biometric verification in the LABAU Concierge Driver application, what is and is not collected, how long anything is kept, and how it is destroyed. It is made publicly available and is provided to every driver before activation.

1. Why LABAU Uses Biometric Verification LABAU delivers high-value goods — fine jewelry, watches and luxury apparel — into the homes and hotel suites of its members. Every delivery is recorded under a chain of custody that establishes who held an item at every point between the merchant counter and the member’s door. Biometric verification is how LABAU confirms that the person holding a member’s purchase is the vetted driver assigned to it, and not someone in possession of that driver’s phone. It is used at three moments: when a driver goes on duty, at collection from the merchant, and at delivery to the member. It is a security control for the protection of members, merchants and drivers alike. It is not used for timekeeping, productivity monitoring, performance evaluation, or any purpose other than identity confirmation at those three moments.

2. What Is and Is Not Collected THE CENTRAL POINT LABAU does not collect, capture, receive, store or possess a biometric

template, scan, image or any other biometric identifier. Verification is performed entirely on the driver’s LABAU-issued device by the device manufacturer’s own biometric system. LABAU receives only the result.

ELEM ENT

LABAU POSITION

Biometric template or scan

Never transmitted to or stored by LABAU. It remains in the secure hardware enclave of the device and is never accessible to any application, including the LABAU driver application.

Facial image or fingerprint

Never captured, transmitted or stored by LABAU.

image Verification result

Collected. A pass or fail value returned by the device operating system.

Verification metadata

Collected. Timestamp, GPS coordinates, device identifier, associated order reference.

Purpose of collection

Confirming the identity of the assigned driver at each chain-of-custody moment.

Disclosure to third parties

None, except where required by law or valid legal process, or where necessary to investigate a loss involving a specific delivery.

Sale, lease, trade or profit

Never. LABAU does not and will not sell, lease, trade or otherwise profit from biometric information or verification data.

Where a driver’s device or jurisdiction makes biometric verification unavailable, LABAU provides a nonbiometric alternative — a device passcode combined with a one-time code sent to the driver’s registered number — that produces an equivalent chain-of-custody record.

3. Retention and Destruction Schedule Because LABAU holds no biometric identifiers, this schedule governs the verification results and metadata that LABAU does hold.

DATA

RETENTION

DESTRUCTION

Verification result and metadata,

Retained for the period required to resolve

Permanently deleted at the end of

forming part of a delivery record

disputes, returns and insurance claims

that period

relating to that delivery, and in any event no longer than the period stated in the LABAU data retention schedule Verification records not attached to a

Retained no longer than thirty (30) days

Permanently deleted

On termination of the driver relationship,

Permanently deleted no later than

retained only for the period required by

one (1) year after the relationship

law or to resolve an open claim

ends, or when the initial purpose

completed delivery All driver verification data

has been satisfied, whichever occurs first

Destruction is permanent and irreversible. Deleted records are not archived, and no backup copy is retained beyond the routine backup cycle, after which it is overwritten.

4. Consent No driver is enrolled in biometric verification without first receiving this policy and providing written consent. Consent is obtained at onboarding, before activation, and is recorded in the driver’s file. A driver may decline biometric verification and use the non-biometric alternative described in Section 2. A driver may withdraw consent at any time by written notice, after which LABAU will transition that driver to the alternative method and delete existing verification records in accordance with Section 3. Consent is not a condition of engagement in any jurisdiction where making it so would be unlawful.

5. Safeguards · Verification results and metadata are encrypted in transit at TLS 1.3 and at rest at AES-256 · Access is restricted by role and every access is recorded in an immutable audit log · Driver devices are LABAU-issued, supervised, enrolled in mobile device management and remotely lockable and wipeable · LABAU applies at least the same standard of care to this data as to its own most sensitive confidential information, and no less than the reasonable standard of care applicable to its industry · Service providers with any access are bound by written obligations no less protective than this policy

6. Driver Rights Every LABAU Concierge Driver may: receive a copy of this policy at any time; be told what verification data LABAU holds about them; request correction of inaccurate metadata; withdraw consent and move to the non-biometric alternative; and request deletion of verification records not required for an open claim or by law. Requests are made to LABAU at the contact details below and are actioned within thirty (30) days.

7. Legal Framework LABAU operates in New York City. Several states regulate biometric information, including through statutory penalties and, in Illinois, a private right of action. Because LABAU drivers may reside outside New York, this policy is drafted to a standard intended to be consistent with the stricter of those regimes. Specific items for confirmation with counsel before biometric verification is enabled:

· Whether device-native verification that never transmits a template constitutes collection or possession of a biometric identifier under New York law and under the law of any state where a driver resides · Whether New York City’s biometric identifier provisions applicable to commercial establishments reach any part of LABAU’s operation, including merchant-sited devices · The form and record of driver consent required in each applicable jurisdiction · Whether this policy must be publicly posted, and where · Whether any member-facing biometric feature, if introduced, would carry materially different obligations

8. Changes LABAU may update this policy. Material changes will be notified to affected drivers at least thirty (30) days before taking effect. The effective date above records the last revision.

9. Contact LABAU Holdings, Inc. kristina@labauholdings.com · labau.com · New York, New York

Driver Consent I have received and read the LABAU Biometric Data Policy. I understand what is and is not collected, how long verification records are kept, and how they are destroyed. I understand that I may decline biometric verification and use the alternative method, and that I may withdraw consent at any time.

☐ I consent to biometric verification as described in this policy. ☐ I decline and elect the non-biometric alternative. Driver signature: __________________________________ Printed name: __________________________________ Date: ____________________________

LABAU HOLDINGS, INC. Signature: __________________________________ Printed Name: Kristina Charles

Title: Founder & Chief Executive Officer Date: ____________________________