Biometric Data Collection and Retention Policy

Effective Date/Last Updated: 07/27/2026

Biometric Data Collection and Retention Policy

Kenco Logistic Services, LLC, Kenco Transportation Services, LLC, Kenco Transportation Management, LLC, and/or Kenco Management Services, LLC (“Kenco”) may collect, store, and use Biometric Data for certain purposes described below, and it may disclose that Biometric Data in certain circumstances.  This Policy explains what that means for you, and how you consent to Kenco’s activities.  

Definitions  

“Biometric Data” as used in this Policy includes both: (i) “Biometric Identifiers”, meaning a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits.  Biometric Identifiers do not include writing samples, written signatures, photographs, human biological samples used for scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color; and (ii) “Biometric Information”, meaning any information, regardless of how it is captured, converted, stored, or shared, that is based on Biometric Identifiers, including a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, that is used to identify an individual.

Data Collection and Purpose

Kenco uses a fleet camera system from Samsara, Inc. (“Samsara”). The Samsara system includes both a road-facing camera and inward facing cameras to capture video footage of critical events. Samsara uses certain analytics, processing and artificial intelligence techniques on the data collected from the cameras to provide analysis, including event and object recognition, driver recognition and performance, and other safety and efficiency objectives.  

Certain data collected from Samsara cameras, including facial scans, may be considered Biometric Data under many states’ laws, including Illinois. Samsara cameras, and the related technology and processing techniques, allows Kenco to use this Biometric Data to confirm that the Samsara dash cameras are not obstructed or blocked, analyze driving and driver performance, improve customer service, optimize efficiency, improve safety, use for legal or litigation purposes and defense, analyze risk and to observe driving behaviors. Using the Samsara camera system features enhances safety by increasing the efficacy of the driver-based insights, improve driver safety and efficiency, helps Kenco to maintain accurate logs of our operations, and allows Kenco to coach drivers.  

The data collected will be disclosed to Samsara and stored on Samsara’s cloud servers. Samsara will have access to the Biometric Data to perform the functions of its services agreement with Kenco. A copy of the Samsara privacy policy and related links is available at https://www.Samsara.com/support/privacy.        

Data Storage, Protection and Disclosure Policy  

Kenco’s policy is to protect and store Biometric Data in accordance with applicable laws and regulations, including, but not limited to, the Illinois Biometric Information Privacy Act.  Specifically, Kenco shall use a reasonable standard of care to store, transmit, and protect from disclosure any Biometric Data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which Kenco stores, transmits, and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual such as social security numbers. 

Any Biometric Data collected from drivers using Samsara cameras will not be disclosed to parties other than Kenco or Samsara, except in the following circumstances: (1) after Kenco obtains appropriate written consent from the driver(s); (2) when disclosure is required by federal, state, or local law; or (3) when disclosure is required by a valid subpoena or warrant issued by a court. Within Kenco, the Biometric Data may be shared with only those employees who have a need to know for a specific business purpose.   

Retention and Destruction of Biometric Data

Kenco will retain any Biometric Data collected using Samsara cameras during the time that an individual is employed with or assigned to work at Kenco in a role for which Samsara cameras are used. Within a reasonable time following the conclusion of the assignment or the employee relationship, or upon a driver’s transfer to a position for which Samsara cameras are not utilized, whichever occurs first, Kenco and Samsara will permanently delete the Biometric Data that it retained. In any event, any Biometric Data will be permanently deleted within ninety (90) days after the driver is deactivated from the Samsara system. Absent a valid warrant or subpoena issued by a court of competent jurisdiction, Kenco will comply with this retention schedule and destruction guidelines.

Consent Form

Before you begin or continue your employment with or your assignment to Kenco in a role for which Samsara cameras are used, you must execute the Notice and Consent to Collection of Biometric Data form accompanying this Policy (for Employee or for Contractor).