Coinbase collects your facial geometry data when you verify your identity, which is some of the most sensitive personal data that exists.
This analysis describes what Coinbase'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 collection establishes a data processing mechanism tied to Coinbase's identity verification and legal compliance framework. This data category receives different regulatory treatment than standard personal information under biometric privacy statutes in certain jurisdictions.
Current version consolidates biometric and KYC data collection into a single provision and changes language from 'may collect' to 'collect,' emphasizing active collection of government-issued ID alongside biometric data.
View full change record →Your facial geometry is collected during identity verification and stored by Coinbase and potentially its third-party identity verification vendors, creating exposure to biometric data breaches that cannot be remediated by credential rotation.
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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"We may collect biometric data such as your facial geometry through identity verification processes. We use this to verify your identity and comply with our legal obligations.— Excerpt from Coinbase's Coinbase Privacy Policy
REGULATORY FRAMEWORK: Collection of biometric identifiers implicates Illinois BIPA (740 ILCS 14/1 et seq.) requiring written consent, a retention policy, and prohibition on sale; Texas CUBI (Tex. Bus. & Com. Code §503.001); Washington My Health MY Data Act; GDPR Art. 9 (special category data requiring explicit consent or another Art. 9(2) basis); and CCPA/CPRA §1798.140 defining biometric information as sensitive personal information requiring opt-out or limitation rights. Primary enforcers: Illinois AG and private right of action under BIPA; FTC; EU DPAs.
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Biometric collection establishes a data processing mechanism tied to Coinbase's identity verification and legal compliance framework. This data category receives different regulatory treatment than standard personal information under biometric privacy statutes in certain jurisdictions.
Your facial geometry is collected during identity verification and stored by Coinbase and potentially its third-party identity verification vendors, creating exposure to biometric data breaches that cannot be remediated by credential rotation.
ConductAtlas has identified this type of provision across 20 platforms. See the full comparison.
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