Minno Biometric Data Retention and Destruction Policy
Version 2026-11-07 · Last updated 7 November 2026 · Published by Rook Industries, Inc.
This is the written policy that biometric privacy laws (including the Illinois Biometric Information Privacy Act, 740 ILCS 14/15(a)) require of anyone in possession of biometric identifiers or biometric information. It explains what Minno handles, how long it is kept, and how it is destroyed.
1. Scope
Minno is a face liveness and face comparison API that businesses ("customers") integrate into their own identity-verification products. Rook Industries, Inc. ("Rook") operates Minno as a vendor to those customers. This policy covers every biometric identifier or biometric information that passes through or is processed on behalf of Minno.
2. What is a biometric identifier here
A scan of face geometry, a face video or image captured for a liveness check, liveness signals derived from a face, a face comparison result, and any information based on them that is used to identify a person.
3. What Rook holds, and for how long
| Data | Who holds it | Retention | Destruction |
|---|---|---|---|
| Face video and liveness capture | Streamed from the end user's device directly to Amazon Rekognition Face Liveness. Not received or stored by Rook. | AWS retains session audit data for a short period to return results and for service integrity, then deletes under its terms. Rook has opted out of AWS using it to improve models. | By AWS under its documented deletion process. |
| Reference frame (one image) | Returned once to the customer if requested, through Rook, in memory only. Not stored by Rook. | Zero. Discarded as soon as the response is sent. | Memory released; never written to disk, database, log or backup. |
| ID portrait submitted for comparison | Passed by Rook to Amazon Rekognition CompareFaces in memory only. Not stored by Rook. | Zero. | Memory released; never written to disk, database, log or backup. |
| Face comparison result (match true/false, similarity score) | Rook | 13 months from the check, for billing reconciliation and dispute resolution. | Permanently deleted by scheduled job; removed from backups as backups expire (within 35 days of deletion). |
| Liveness decision (live true/false, confidence score), session status, timestamps, session ID, the customer's reference tag | Rook | 13 months from the check. Earlier on customer request or account closure. | Same as above. |
| Billing records (counts only, no scores, no identifiers of the end user) | Rook | 7 years (tax records). | Deleted after 7 years. |
In short: Rook never stores a face. The only biometric-related data Rook retains is a decision and a score tied to a session ID and the customer's own reference, and that is deleted after 13 months at the latest.
4. When the purpose is satisfied
The initial purpose for which a face capture is processed (returning a liveness or comparison result to the customer) is satisfied the moment the result is returned. Face data is not retained beyond that point. Decision metadata is kept only for the operational purposes above and never to identify a person.
5. Destruction methods
Face data is never persisted, so destruction consists of releasing memory at the end of each request. Metadata is deleted by a daily scheduled job that removes every session older than 13 months; database deletions are permanent and backups holding deleted rows expire within 35 days. Deletion runs are logged (counts only). On a customer's request Rook deletes that customer's session metadata within 30 days; on account closure, within 30 days.
6. What Rook will never do
Sell, lease, trade or otherwise profit from biometric identifiers or information. Build any gallery, collection or index of faces. Use face data to train or improve models. Disclose biometric data except to the cloud provider performing the check, as the customer instructs, or as the law requires.
7. Customers' own obligations
Each customer collects biometric data from its own end users and must provide its own notice, obtain the required written consent before capture, and publish its own retention and destruction policy. Rook requires this in its Terms of Service and Data Processing Agreement.
8. Legal holds
If the law or a valid legal process requires Rook to retain particular session metadata beyond the schedule above, Rook will retain only what is required, for only as long as required, and then destroy it.
9. Changes
Rook will post any change here with a new date. Material changes are emailed to customers 30 days in advance.
Questions: privacy@tryminno.com · Rook Industries, Inc., 30 N Gould St Ste R, Sheridan, WY 82801