Coinbase collects your name, address, date of birth, government-issued ID, and biometric data such as facial recognition information when you sign up and verify your identity.
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
The collection of biometric data for identity verification is subject to specific state laws including Illinois BIPA, which imposes strict notice, consent, and deletion requirements, and the policy's retention of this data may interact with those obligations.
Interpretive note: The exact scope of biometric data collected and the specific retention periods are not fully detailed in the truncated document, creating some uncertainty about precise compliance obligations.
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 →Users who complete identity verification on Coinbase provide biometric data, which the policy states Coinbase collects and retains; the handling of this biometric data is subject to varying legal protections depending on the user's state of residence.
How other platforms handle this
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.
We collect your personal data when you use our Services, create a new eBay account, provide us with information via a web form, add or update information in your eBay account, participate in online community discussions or otherwise interact with us.
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Coinbase has changed this document before.
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"We collect personal information you provide to us such as your name, address, phone number, email address, date of birth, and government-issued identification. We may also collect biometric information from you, such as facial recognition data, to verify your identity.— Excerpt from Coinbase's Coinbase Privacy Policy
REGULATORY LANDSCAPE: Biometric data collection engages the Illinois Biometric Information Privacy Act, Texas CUBI Act, and Washington My Health MY Data Act, each of which imposes distinct notice, written consent, and retention schedule requirements. The FTC Act's Section 5 unfair or deceptive practices authority is also relevant. Where collection involves EU or UK users, GDPR Article 9 treats biometric data as a special category requiring explicit consent or another enumerated legal basis. GOVERNANCE EXPOSURE: High. Biometric data has the highest sensitivity classification under most US state privacy frameworks, and failures to comply with BIPA specifically have resulted in significant class action litigation. The policy's retention provisions tied to regulatory recordkeeping may create tension with BIPA's requirement to delete biometric data within defined periods. JURISDICTION FLAGS: Illinois residents have private rights of action under BIPA. Texas and Washington impose state AG enforcement. EU and UK users require explicit consent or a documented Article 9 exemption. California CPRA classifies biometric data as sensitive personal information with opt-out rights. CONTRACT AND VENDOR IMPLICATIONS: Third-party identity verification vendors processing biometric data on Coinbase's behalf must have data processing agreements specifying retention limits, security standards, and sub-processor controls consistent with GDPR Article 28 and equivalent state requirements. Procurement teams should assess whether vendors have BIPA-compliant written policies. COMPLIANCE CONSIDERATIONS: Compliance teams should audit biometric data retention schedules against BIPA's destruction requirements and document the legal basis for biometric processing for each jurisdiction. A consent mechanism review is warranted to confirm that BIPA-required written release is obtained prior to collection, separate from general terms of service acceptance.
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The collection of biometric data for identity verification is subject to specific state laws including Illinois BIPA, which imposes strict notice, consent, and deletion requirements, and the policy's retention of this data may interact with those obligations.
Users who complete identity verification on Coinbase provide biometric data, which the policy states Coinbase collects and retains; the handling of this biometric data is subject to varying legal protections depending on the user's state of residence.
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