OpenSea's updated Privacy Policy (effective October 20, 2026) expands the types of personal data it collects and clarifies its data governance structure. The policy now explicitly describes collection of biometric data (facial recognition for identity verification), supplemental identity verification data for cryptocurrency onramp services (including full legal name, date of birth, tax ID, government-issued ID, and mobile number), and demographic information from surveys. The policy also clarifies that two entities—Ozone Networks, Inc. (OpenSea) and its subsidiary Sea Trove LLC—act as data controllers for different services, with Sea Trove handling wallet and onramp data processing.
Consumers: OpenSea now explicitly states it may collect facial biometric data through third parties to verify your identity for rewards or compliance purposes.
Consumers: If you use OpenSea's cryptocurrency onramp service, the policy now explicitly discloses collection of your full legal name, date of birth, tax ID, government ID, and mobile number.
Consumers: If you participate in OpenSea rewards programs, the policy now states it may collect your Social Security number or other tax identification number for tax reporting.
Data controllers: The policy now clarifies that a subsidiary company (Sea Trove LLC) is responsible for processing your data when you use wallet or onramp services, alongside third-party providers.
Consumers: The policy now explicitly states it collects demographic information you provide in surveys or research.
The updated policy establishes new collection of sensitive personal data categories not previously disclosed in explicit detail. Users of OpenSea's onramp services will have their full legal name, date of birth, tax ID, government-issued identification documents, mobile number, and IP address collected and transmitted to third-party onramp providers. Users subject to identity verification for rewards eligibility or compliance will have facial biometric data processed through third-party providers using facial recognition technology; the provider generates and holds the biometric identifier on OpenSea's behalf and destroys it within three years of last interaction. Users participating in rewards programs will have wallet address, name, contact information, and tax identification numbers collected for eligibility determination and tax reporting. You can decline to use onramp services and still access the Platform, and identity verification for rewards is required only in certain circumstances such as when required for rewards eligibility or compliance.
→ Review the updated privacy policy to understand what data is collected if you use onramp services or participate in rewards programs.
→ If you do not wish to use onramp services, you can continue to access the Platform without using those services.
→ If you are subject to identity verification for rewards eligibility, understand that facial biometric data may be processed by third-party providers and retained for up to three years.
New disclosure that facial recognition technology may be used to create a biometric identifier from selfies for identity verification; the provider holds and destroys the identifier within three years, and OpenSea receives only the verification result.
New disclosure that full legal name, date of birth, tax ID, government-issued ID, mobile number, IP and email addresses may be collected for cryptocurrency onramp services, either through OpenSea's interface or directly on the onramp provider's page.
Clarification that Ozone Networks, Inc. (OpenSea) and Sea Trove LLC (a subsidiary) are separate data controllers for different services; Sea Trove handles wallet and onramp data processing in addition to third-party providers.
This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology
OpenSea's updated privacy policy introduces explicit disclosure of biometric data collection (facial recognition for identity verification) and expanded identity verification data collection for cryptocurrency onramp services. The policy clarifies a dual data controller structure: Ozone …
Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.
Unlock the full institutional analysis — InsightConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-X-005752.
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