GOAT uses a third-party provider, Persona, to perform identity verification by applying facial recognition technology to a selfie and government ID document, generating a biometric identifier that Persona retains until GOAT instructs its destruction; GOAT states it does not receive the biometric identifier itself but does receive the selfie image and extracted ID document data.
This analysis describes what GOAT'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 discloses that biometric identifiers derived from facial geometry are generated and held by a third-party processor on GOAT's behalf, which implicates state biometric privacy statutes, particularly Illinois BIPA, that impose specific notice, written consent, retention schedule, and destruction obligations on entities that collect or contract for the collection of biometric identifiers. The provision establishes GOAT's contractual control over the destruction timeline, which may affect how regulatory obligations are allocated between GOAT and Persona.
Interpretive note: Whether GOAT's contractual arrangement with Persona (in which Persona holds but GOAT does not receive the biometric identifier) satisfies BIPA's obligations for entities that 'collect' or 'obtain' biometric data is legally uncertain and may vary by jurisdiction and enforcement interpretation.
This provision establishes that users who undergo identity verification on GOAT's platform have a biometric identifier generated from their facial image by Persona, a third-party provider, and that this identifier is retained by Persona until GOAT instructs deletion. The agreement states that GOAT does not use, disclose, or retain biometric information for any other commercial purpose beyond the identity verification process described.
Cross-platform context
See how other platforms handle Biometric Identifier Collection via Facial Recognition (Persona) and similar clauses.
Compare across platforms →"Persona may use a combination of machine-learning tools and optical scans to verify your identity document and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provide to determine the likelihood that the images are a "match." We do not receive the biometric identifier generated from the images. It is generated and held by Persona until we inform them that the biometric identifier is no longer needed for the purposes described in this paragraph and must be destroyed.Excerpt from GOAT's Privacy Policy
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This provision discloses that biometric identifiers derived from facial geometry are generated and held by a third-party processor on GOAT's behalf, which implicates state biometric privacy statutes, particularly Illinois BIPA, that impose specific notice, written consent, retention schedule, and destruction obligations on entities that collect or contract for the collection of biometric identifiers. The provision establishes GOAT's contractual control over …
This provision establishes that users who undergo identity verification on GOAT's platform have a biometric identifier generated from their facial image by Persona, a third-party provider, and that this identifier is retained by Persona until GOAT instructs deletion. The agreement states that GOAT does not use, disclose, or retain biometric information for any other commercial purpose beyond the identity verification …
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