U-Haul Biometric Information Privacy Policy

In accordance with the Illinois Biometric Information Privacy Act (740 ILCS 14/1 et seq.) and other similar laws and regulations, this biometric information privacy policy sets forth procedures of the U-Haul System (as defined in the U-Haul Privacy Policy) for our collection, use, disclosure, storage, and destruction of Biometric Information. This policy forms part of the U-Haul Privacy Policy.

Purpose

The U-Haul System uses biometric data to verify identification, enhance general security, and prevent fraud. Biometric data includes biometric identifiers and biometric information as defined below. We recognize the sensitivity of biometric data and take seriously our obligations to maintain confidentiality and protect the security of this information.

Definitions

"Biometric Identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. The U-Haul System uses a "scan of face geometry" taken from a selfie or headshot photo (see: Driver's License Photos FAQ). The U-Haul System does not collect the other forms of biometric identifiers. Biometric identifiers do 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.

"Biometric Information" means any information, regardless of how it is captured, converted, stored, or shared, based on an individual's biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.

The U-Haul System does not collect biometric data derived from commercial technology such as Face ID/Touch ID, Face Unlock/Fingerprint Unlock, or passkeys used to unlock an individual's device or to sign into an app.

Policy Implementation

  1. Consent
    An individual's biometric data will not be collected or otherwise obtained by the U-Haul System without prior consent of the individual. The consent will inform the individual of the reason(s) the Biometric Information is being collected.
  2. Disclosure
    We will not disclose or disseminate any biometric data to anyone other than our authorized vendors unless:
    1. Disclosure is required by state or federal law or municipal ordinance;
    2. The disclosed data completes a financial transaction requested or authorized by the customer;
    3. Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction; or
    4. The individual has consented in writing to such disclosure or dissemination.

    Neither the U-Haul System nor its vendors or licensor of our biometric software will sell, lease, trade, or otherwise profit from an individual's biometric data.

  3. Storage
    We will use a reasonable standard of care within our industry to store, transmit, and protect from unauthorized disclosure any biometric data collected. Storage, transmission, and protection from unauthorized disclosure shall be performed in a manner that is the same as or more protective than the way we store, transmit, and protect other confidential and sensitive information, including information that is used to uniquely identify an individual.
  4. Retention Schedule
    We will permanently destroy an individual's biometric data within 60 days of when the initial purpose for collecting or obtaining such biometric data has been satisfied.
History
The policy was enacted July 7, 2025.
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