Provision record
Microsoft Azure · Microsoft Privacy · View original document ↗

Biometric Data Collection via Windows Hello and HoloLens

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Document Record

What it is

The statement discloses that Microsoft collects biometric data, including fingerprint and facial recognition data, through Windows Hello for device authentication. For HoloLens, iris scan data is used to create a numeric identifier stored locally on the device and not shared externally. Biometric data collection is stated to depend on user consent and the specific features used.

This analysis describes what Microsoft Azure'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 discloses biometric data collection practices for Windows Hello and HoloLens, which are subject to stringent biometric data protection laws in Illinois (BIPA), Texas, Washington, and other states, as well as GDPR Article 9 special category data requirements in the EU. The statement notes iris data in HoloLens is stored locally and not shared, which is a relevant technical control for compliance assessment.

Recent Activity

This document changed recently

Medium Apr 19, 2026

Microsoft now discloses that it may contact you by phone for marketing using automated dialers and AI-generated voices if you have consented to marketing communications, which represents a new disclosure of contact method and technology type. The company has also reorganized its data retention policy to state it retains data for broader business purposes including improving products and protecting systems, while removing previous specific examples and retention criteria, making it less clear exactly how long specific types of your data will be kept. You should review your consent settings for marketing communications and verify what contact methods you have authorized, particularly if you have concerns about automated or AI-generated calls.

View change record →
Medium Apr 1, 2026

Microsoft's privacy policy now provides a less detailed explanation of how long your data is retained. Previously, the policy included specific examples, such as how long deleted emails remain in your system before final deletion, and listed criteria for deciding retention periods. Now those details are consolidated into a more general statement pointing readers to separate product documentation. This means you'll need to consult multiple documents to understand retention timelines for specific services, which reduces transparency at the point of reading the main privacy policy.

View change record →
Medium Mar 6, 2026

Microsoft's updated retention policy provides greater specificity about how long your data persists and under what conditions it is deleted. The policy now explicitly states that deleted items from OneDrive and Outlook.com may remain in Microsoft's systems for up to 30 days before permanent removal, even after you empty the Deleted Items folder. Additionally, the updated terms clarify that retention periods depend on whether you have an expectation that Microsoft will keep the data until you actively remove it, and whether automated controls exist to let you access and delete data yourself. You can review Microsoft's privacy dashboard to exercise available deletion controls and understand which services retain your data under these criteria.

View change record →

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
    To remove Windows Hello biometric data, open Windows Settings, navigate to Accounts, then Sign-in options, and remove the facial recognition or fingerprint sign-in option. For HoloLens iris data, access HoloLens Settings and select the option to delete iris data from the device.

If You Do Nothing

Users who enable Windows Hello or HoloLens iris sign-in will have biometric data collected and processed as described in the terms; users in jurisdictions with biometric privacy statutes should review applicable consent and disclosure requirements.

Cross-platform context

See how other platforms handle Biometric Data Collection via Windows Hello and HoloLens and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Biometric data. Unique data about you from specific technical processing related to your physical, physiological, or behavioral characteristics to verify or confirm your identity. For instance, you can use your fingerprint or facial recognition to sign in to your Windows device via Windows Hello (please see the Windows Hello section below for more information). Our collection and use of biometric data depends on the products and features you use and your consent.

Excerpt from Microsoft Azure's Microsoft Privacy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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Insight

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

Applicable agencies

  • State AG
    State attorneys general in Illinois, Texas, Washington, and other states with biometric privacy statutes have enforcement authority over biometric data collection and consent requirements.
    File a complaint →
  • FTC
    The FTC has jurisdiction over unfair or deceptive practices related to biometric data collection and may exercise enforcement authority where biometric data practices are inconsistent with disclosed practices.
    File a complaint →

Provision details

Document information
Document
Microsoft Privacy
Entity
Microsoft Azure
Document last updated
May 5, 2026
Tracking information
First tracked
July 11, 2026
Last verified
Aug. 11, 2026
Record ID
CA-P-00018009
Document ID
CA-D-00018
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8d2402a9a4edd754f7948aeb28481a87ee7f4865aafd1d3042de12dacd9ddc8c
Analysis generated
July 11, 2026 02:05 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Microsoft Azure
Document: Microsoft Privacy
Record ID: CA-P-00018009
Captured: 2026-07-11 02:05:00 UTC
SHA-256: 8d2402a9a4edd754…
URL: https://conductatlas.com/platform/microsoft-azure/microsoft-privacy/biometric-data-collection-via-windows-hello-and-hololens/
Accessed: Aug. 11, 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 Microsoft Azure's Biometric Data Collection via Windows Hello and HoloLens clause do?

This provision discloses biometric data collection practices for Windows Hello and HoloLens, which are subject to stringent biometric data protection laws in Illinois (BIPA), Texas, Washington, and other states, as well as GDPR Article 9 special category data requirements in the EU. The statement notes iris data in HoloLens is stored locally and not shared, which is a relevant technical …

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