Cash App collects your facial scans and extracts biometric information from photographs you submit as part of identity verification. This biometric data is stored and processed alongside your Social Security number and government ID.
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 collection of biometric data including facial scans is subject to specific state laws such as Illinois BIPA, which impose written consent, retention schedule, and prohibition-on-sale requirements that go beyond a general privacy notice disclosure.
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 prohi…
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 behal…
The policy states that facial scans and biometric information extracted from photographs are collected for verification purposes; users in Illinois, Texas, and Washington may have additional statutory rights regarding consent to and deletion of this biometric data that are not fully addressed by this notice alone.
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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
1) REGULATORY LANDSCAPE: The explicit collection of facial scans and biometric information extracted from photographs engages the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifiers Act (CUBI), and the Washington My Health MY Data Act (to the extent biometric data constitutes health data). BIPA requires a written, informed consent prior to collection, a publicly available retention and destruction schedule, and prohibits profit from biometric data. The Illinois Attorney General and private plaintiffs have standing to bring BIPA claims. The CCPA/CPRA classifies biometric data as sensitive personal information, triggering opt-out and limitation-of-use rights enforced by the California Privacy Protection Agency. 2) GOVERNANCE EXPOSURE: High. The notice discloses biometric data collection for verification but does not articulate a BIPA-compliant separate written consent mechanism, a public retention schedule, or a destruction timeline for biometric data. This creates material litigation and regulatory exposure for users in Illinois and heightened scrutiny exposure in California. 3) JURISDICTION FLAGS: Illinois residents face the highest exposure given BIPA's private right of action. Texas and Washington residents have statutory rights under CUBI and related statutes respectively. California residents have the right to limit use of sensitive personal information under the CPRA. Users outside these states may have limited additional statutory protections beyond this notice. 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party identity verification services that process biometric data on Cash App's behalf must be assessed as processors under applicable biometric statutes. Vendor contracts should confirm that biometric data is not retained beyond the stated verification purpose and is not sold or shared. Standard commercial DPA language may be insufficient for BIPA compliance without specific biometric data provisions. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent mechanism currently used at the point of biometric data collection to assess whether it meets BIPA's written consent standard. A publicly available biometric data retention and destruction schedule should be evaluated. Data mapping should confirm where biometric data is stored, processed, and whether it is shared with any third party beyond the verification context stated in the notice.
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The collection of biometric data including facial scans is subject to specific state laws such as Illinois BIPA, which impose written consent, retention schedule, and prohibition-on-sale requirements that go beyond a general privacy notice disclosure.
The policy states that facial scans and biometric information extracted from photographs are collected for verification purposes; users in Illinois, Texas, and Washington may have additional statutory rights regarding consent to and deletion of this biometric data that are not fully addressed by this notice alone.
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