Adobe can collect faceprints and voiceprints when you use certain photo and video organization features. These features are off by default and Adobe says it deletes biometric data when you turn them off, but some exceptions may apply.
This analysis describes what Adobe's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Biometric data like faceprints is sensitive and largely irreplaceable if misused. Users in states like Illinois have strong legal protections for this data that may exceed what this policy describes, and the carve-out 'unless otherwise specified in the Software or Services' creates some ambiguity about data deletion timelines.
Interpretive note: The carve-out 'unless otherwise specified in the Software or Services' for biometric data deletion introduces ambiguity about which products or features may deviate from the default deletion commitment, and the sufficiency of in-app enablement as written consent under BIPA is legally unsettled.
Enabling photo grouping or voice features in Adobe apps may result in the collection of biometric identifiers such as faceprints, which are subject to specific legal protections in several U.S. states. The policy states this data is deleted when the feature is turned off, with a carve-out for cases where the software specifies otherwise.
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"Biometric identifiers or information defined under United States laws or other applicable laws (e.g., faceprints and voiceprints, etc.); Where required by law, we will seek any required permissions from you prior to any such collection. Adobe offers certain features that let you edit and organize your photographs, videos, and other types of content using characteristics like face and voice (e.g., you can group similar faces, places, and image characteristics within your collection), and such characteristics may be considered biometric identifiers or biometric information under certain US laws or other applicable privacy laws. When you choose to use these features, Adobe is acting only on your instructions in order to facilitate the service requested by you. These features are off by default and, should you choose to enable them, you can always disable these features. Where we process biometric identifiers or biometric information to deliver a feature requested by you, we delete this information once you turn off the feature, unless otherwise specified in the Software or Services.Excerpt from Adobe's Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages the Illinois Biometric Information Privacy Act (BIPA), which requires written informed consent prior to collection of biometric identifiers including faceprints, a publicly available retention and destruction policy, and prohibition …
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Biometric data like faceprints is sensitive and largely irreplaceable if misused. Users in states like Illinois have strong legal protections for this data that may exceed what this policy describes, and the carve-out 'unless otherwise specified in the Software or Services' creates some ambiguity about data deletion timelines.
Enabling photo grouping or voice features in Adobe apps may result in the collection of biometric identifiers such as faceprints, which are subject to specific legal protections in several U.S. states. The policy states this data is deleted when the feature is turned off, with a carve-out for cases where the software specifies otherwise.
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