New WinCup Holdings, Inc. and WinCup Plastics, Inc. (including their respective parents, affiliates, subsidiaries, and related entities, hereafter “WinCup”) have developed this policy to inform our Team Members of the nature of the potential biometric information that it may collect, receive, use, store, capture or otherwise obtain, as well as the purpose for which the information is obtained and the retention and destruction procedures in place for biometric information. WinCup’s technology may collect, receive, obtain, store and use an image of an individual’s finger derived or extracted from a mathematical formula/algorithm from such image. Though it may or may not be subject to the Illinois Biometric Information Privacy Act (“BIPA”), 740 ILCS 14/1, et seq, WinCup nevertheless, elects to provide this policy out of an abundance of caution pursuant to and in accordance with Illinois law.

Please read this policy carefully to understand the nature of the biometric information which may be collected or transmitted by WinCup, as well as the retention and destruction practices for such information.

WinCup uses biometric time clocks (“Time Clocks”) to simplify and protect the integrity of the time clocking process. Prior to using the Time Clocks, Team Member’s finger or fingers are scanned to create a template that represents the points along the unique features and minutia found in Team Member’s finger scan pattern. To clock in and out, a Team Member must place his/her finger on the Time Clock’s sensor. The reader will then compare the Team Member’s finger scan to the templates held on file. If the Team Member’s finger scan matches the templates held on file, the Team Member will successfully clock in or out.

The Time Clocks DO NOT store an image of the actual fingerprint; the templates reflect only limited information gleaned from the finger scan. The template files cannot be reverse-engineered to reproduce a fingerprint because the reader does not save the necessary information. The finger scan templates are not suitable for law enforcement fingerprint matching. In addition, the reader does not create or save the type of image file required by the Integrated Automated Fingerprint Identification System, the national fingerprint and criminal history system maintained by the Federal Bureau of Investigation Criminal Justice Information Services Division.

The finger scan templates will be shared with Paycom, which provides WinCup with payroll services, including time and attendance tracking software. These templates will be shared with Paycom solely for the purpose of tracking Team Members’ time and attendance for payroll purposes.

The finger scan templates will be stored on the Time Clock and by Paycom for as long as a Team Member is an active Team Member of WinCup. Once a Team Member is no longer an active employee (e.g. on leave, terminated, inactive) of WinCup, the Team Member’s fingerscan template is permanently deleted from the Paycom system and WinCup will permanently clear the template from the Time Clock hardware.

WinCup reserves the right to amend this Biometric Time Clocks Policy at any time.