This analysis describes what Cash App'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
The provision establishes biometric data as a permissible category of personal information within Cash App's identity verification framework. This designation affects how the service processes, stores, and potentially shares facial and biometric information under the terms of the privacy policy.
The updated policy establishes that children under 13 may use Cash App services if a parent or guardian signs up for or authorizes the account on their behalf. Previously, the policy explicitly prohibited any use by children under 13. The revised language clarifies that data deletion obligations apply when Cash App learns an account belongs to an unauthorized child under 13, but does not specify what happens to data from authorized child accounts or how parental oversight operates. A separate Privacy Notice for Children is referenced but not included in the change summary.
View change record →The revised policy shifts from prohibiting all children under 13 from using Cash App to permitting use when a parent or guardian explicitly authorizes or signs up for the service on the child's behalf. This creates a new lawful use path for families, but also establishes a distinction between authorized and unauthorized child accounts. The policy states that if a child under 13 operates an unauthorized account, Cash App will delete collected data upon discovery. Parents or guardians who authorize services should review the new Privacy Notice for Children for details on how child data is processed.
View change record →The updated terms state that children under 13 can no longer use Cash App, eliminating a path that previously existed for parents to authorize accounts on behalf of younger children. The revised language no longer references a separate Privacy Notice for Children, consolidating all child data handling disclosures into the main policy. If Cash App collects data and later learns it came from a child under 13, the policy requires deletion of that data, though the updated language broadens this obligation by removing the phrase 'for an unauthorized account', potentially extending deletion requirements beyond accounts that were never authorized.
View change record →Users who complete identity verification on Cash App consent to the collection and processing of facial scans and extracted biometric data as a condition of verification. The terms authorize Cash App to retain this biometric information for verification purposes as specified in the privacy policy.
How other platforms handle this
"By clicking 'Next', you are indicating that you have read and agree to the TERMS OF USE AND PRIVACY POLICY"
We automatically collect certain information from your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Service, we collect information about the individual web pages or products th...
Location data. Data about your device's location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device's IP address...
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"Additional Identification Information, such as: Your full mailing address; date of birth; government-issued identification, including Social Security number, passport, or driver's license; and photographs, facial scan and biometric information extracted from such images for verification purposes.— Excerpt from Cash App's Cash App Privacy Policy
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The provision establishes biometric data as a permissible category of personal information within Cash App's identity verification framework. This designation affects how the service processes, stores, and potentially shares facial and biometric information under the terms of the privacy policy.
Users who complete identity verification on Cash App consent to the collection and processing of facial scans and extracted biometric data as a condition of verification. The terms authorize Cash App to retain this biometric information for verification purposes as specified in the privacy policy.
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