Provision record
Checkout.com · Checkout.com Privacy · View original document ↗

Biometric Data Collection and Retention

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Document Record

What it is

The notice authorizes collection of facial images and voice recordings from which biometric identifiers (faceprints, voiceprints, minutiae templates) are extracted for identity verification, with that biometric data shared with Snowflake Computing and Amazon Web Services and retained for up to 365 days before deletion.

This analysis describes what Checkout.com'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision names the specific biometric data categories collected, the two third-party cloud processors receiving that data, and establishes a 365-day outer retention limit, each of which are operationally significant parameters for compliance with GDPR, UK GDPR, and US state-level biometric privacy statutes that impose consent, disclosure, and retention requirements.

Interpretive note: The phrase 'or if our collection of biometric information is otherwise permitted by law' reserves a non-consent legal basis that is not further specified, and the adequacy of the stated consent mechanism under US state biometric laws (BIPA, Texas CUBI) requires jurisdiction-specific legal evaluation.

Recent Activity

This document changed recently

Medium Jun 19, 2026

The updated policy establishes formal complaint procedures for UK and Australia users, requiring Checkout to acknowledge complaints within 30 days and respond without undue delay. For UK users specifically, the policy clarifies that complaints must first be raised with Checkout before escalating to the Information Commissioner's Office. The policy also discloses that transaction information collection now includes country data alongside currency and amount. For Australia users, the policy clarifies that identity verification is a legal requirement and cannot be provided anonymously or pseudonymously. Users in these jurisdictions can submit data protection complaints through Checkout's designated process and escalate to their respective regulatory authorities if dissatisfied with Checkout's response.

View change record →

Consumer impact (what this means for users)

This provision establishes that Merchant Customers who use Checkout's identity verification services may have facial images, voiceprints, and derived biometric templates collected, shared with Snowflake Computing and Amazon Web Services, and retained for up to 365 days, with processing stated to require explicit consent. The agreement also states that biometric collection may proceed where otherwise permitted by law, independent of consent.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Email dpo@checkout.com to submit a biometric data deletion request, identifying yourself and specifying the biometric data you wish deleted. The notice states data is deleted no later than 365 days after collection.

Cross-platform context

See how other platforms handle Biometric Data Collection and Retention and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
If you consent to our collection of biometric information or if our collection of biometric information is otherwise permitted by law, you agree that we may collect your imagery of the face, and voice recordings, from which an identifier template such as a faceprint, a minutiae template, or a voiceprint, can be extracted in order to verify your identity using Checkout's verification services. Your biometric information may be shared with our third-party cloud providers Snowflake Computing and Amazon Web Services. We will delete your biometric information no later than 365 days after the date you provide it.

Excerpt from Checkout.com's Privacy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
Checkout.com Privacy
Entity
Checkout.com
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-016110
Document ID
CA-D-00663
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
aabf92a3ffd7ad34135ff9f030ee34d8f733b33feed3b830c2380fe5554a223b
Analysis generated
July 9, 2026 09:37 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Checkout.com
Document: Checkout.com Privacy
Record ID: CA-P-016110
Captured: 2026-07-09 09:37:20 UTC
SHA-256: aabf92a3ffd7ad34…
URL: https://conductatlas.com/platform/checkoutcom/checkoutcom-privacy/provision/CA-P-016110/biometric-data-collection-and-retention/
Accessed: Sept. 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Checkout.com's Biometric Data Collection and Retention clause do?

This provision names the specific biometric data categories collected, the two third-party cloud processors receiving that data, and establishes a 365-day outer retention limit, each of which are operationally significant parameters for compliance with GDPR, UK GDPR, and US state-level biometric privacy statutes that impose consent, disclosure, and retention requirements.

How does this clause affect you?

This provision establishes that Merchant Customers who use Checkout's identity verification services may have facial images, voiceprints, and derived biometric templates collected, shared with Snowflake Computing and Amazon Web Services, and retained for up to 365 days, with processing stated to require explicit consent. The agreement also states that biometric collection may proceed where otherwise permitted by law, independent of …

Is ConductAtlas affiliated with Checkout.com?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Checkout.com.