The policy discloses that Figure AI collects sensory data including photos, videos, and recordings of users and their physical environments, used for providing and improving services and correspondence, and disclosed to service providers.
This analysis describes what Figure AI'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
This provision authorizes collection of photos, videos, and environmental recordings, which may constitute biometric or sensitive data under frameworks including Illinois BIPA, Texas CUBI, or other state biometric laws not explicitly cited in the policy. The operational context of a humanoid robotics company makes this category particularly material for assessing regulatory exposure.
Interpretive note: Whether collected sensory data constitutes biometric identifiers subject to BIPA, CUBI, or other biometric frameworks depends on the specific nature of data collected and applicable statutory definitions, which the policy does not clarify.
The agreement authorizes collection of photos, videos, and recordings of users and their environments, shared with service providers for service provision and improvement purposes. Users subject to state biometric privacy laws may have additional rights or consent requirements that are not explicitly described in this policy.
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"Sensory Data such as photos, videos, or recordings of you and/or of your environment.— Excerpt from Figure AI's Figure AI Privacy Policy
1) REGULATORY LANDSCAPE: This provision may implicate Illinois BIPA, Texas CUBI, and Washington's biometric privacy frameworks depending on whether the sensory data collected constitutes biometric identifiers as defined under those statutes. The CCPA and CPRA classify certain biometric data as sensitive personal data requiring heightened protections. The FTC has brought enforcement actions related to undisclosed biometric data collection. The policy does not reference biometric frameworks specifically. 2) GOVERNANCE EXPOSURE: High. Collection of photos, videos, and environmental recordings by a robotics and AI company creates substantial exposure under state biometric privacy laws if the data constitutes biometric identifiers. Illinois BIPA in particular provides a private right of action with statutory damages, creating significant litigation exposure. The policy does not describe specific retention periods, destruction schedules, or written policies for sensory data as required by BIPA. 3) JURISDICTION FLAGS: Illinois (BIPA), Texas (CUBI), Washington, and New York create heightened exposure for biometric data collection. California (CPRA) requires opt-in consent for sensitive personal data, which may include biometric information derived from sensory data. The policy's disclosure that sensory data is shared with service providers without specifying data processing restrictions may create additional exposure. 4) CONTRACT AND VENDOR IMPLICATIONS: Service provider agreements for entities receiving sensory data should be reviewed to confirm appropriate data processing restrictions, retention limitations, and compliance with applicable biometric privacy laws. The policy does not describe contractual restrictions imposed on service providers receiving sensory data, which may require additional due diligence. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether sensory data collected constitutes biometric identifiers under Illinois BIPA, Texas CUBI, or other applicable frameworks. A data mapping exercise should document the specific types of sensory data collected, retention periods, and service providers with whom it is shared. Written biometric data policies and informed consent mechanisms may be required in certain jurisdictions prior to collection.
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This provision authorizes collection of photos, videos, and environmental recordings, which may constitute biometric or sensitive data under frameworks including Illinois BIPA, Texas CUBI, or other state biometric laws not explicitly cited in the policy. The operational context of a humanoid robotics company makes this category particularly material for assessing regulatory exposure.
The agreement authorizes collection of photos, videos, and recordings of users and their environments, shared with service providers for service provision and improvement purposes. Users subject to state biometric privacy laws may have additional rights or consent requirements that are not explicitly described in this policy.
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