Provision record
Microsoft · Microsoft Privacy Statement (Legacy) · View original document ↗

Biometric Data Collection via Windows Hello and HoloLens

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Document Record

What it is

The statement discloses collection of biometric data including fingerprint and facial recognition data through Windows Hello and iris data through HoloLens; collection is described as consent-dependent, and HoloLens iris data is stated to remain on-device and not shared.

This analysis describes what Microsoft'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 establishes consent as the stated basis for biometric data collection; the on-device storage representation for HoloLens iris data and the product-specific scope of biometric collection are operationally significant for compliance under biometric-specific state laws.

Recent Activity

This document changed recently

Medium Jun 26, 2026

The updated privacy statement removes the previous detailed list of third-party sources from which Microsoft obtains personal data, including data brokers, public social media posts, location service providers, co-branded partners, and developers. Under the revised language, Microsoft describes obtaining data from 'Microsoft affiliates, subsidiaries, and third parties' without specifying the categories or types of third parties as explicitly as before. The company states it has reorganized the document for greater clarity and accessibility, but the operational effect is that users receive less specific disclosure about where their data originates from outside Microsoft.

View change record →
Medium Apr 19, 2026

The updated policy establishes additional grounds on which Microsoft may retain personal data. While the prior version tied retention to specific user expectations and available deletion controls, the revised language authorizes retention for 'operating our business, meeting our contractual and legal obligations, improving and developing our products and services, protecting the safety and security of our systems and customers, and resolving disputes.' This expands the stated purposes beyond transaction fulfillment and legal compliance. The updated policy directs users to product-specific documentation for retention details rather than providing explicit deletion procedures and timelines in the privacy statement itself.

View change record →
Medium Apr 1, 2026

The updated policy now grounds data retention in five broad business purposes: operating the business, meeting contractual and legal obligations, improving and developing products and services, protecting system and customer safety, and resolving disputes. Previously, the policy articulated specific criteria for determining retention periods, including customer expectations for retention until manual deletion, availability of automated deletion controls, and data sensitivity. The revised language removes these granular criteria and instead requires users to consult individual product documentation to understand when their specific data will be deleted. This shifts the burden of finding retention timelines from the main policy statement to separate product-specific documents.

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, navigate to Windows Settings, select Accounts, then Sign-in options, and remove fingerprint or facial recognition data; for HoloLens iris data, access HoloLens device settings to delete stored iris data.

If You Do Nothing

Biometric data collection through Windows Hello or HoloLens will proceed under the consent provided at feature setup; users who do not review consent terms may not be aware of the full scope of data collected

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. HoloLens takes an image of your iris and measures distances between key points to create and store a numeric value that represents only you. This data stays on the HoloLens and is not shared with anyone, and you can choose to delete this data from your HoloLens at any time.

Excerpt from Microsoft's Privacy Statement (Legacy)

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision engages Illinois BIPA, which requires informed written consent before collecting biometric identifiers and imposes strict notice, retention, and destruction requirements; BIPA applies to fingerprint and facial geometry data.

Insight

Unlock the full institutional analysis

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

Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive data collection practices, including consent representations related to biometric data collection at scale.
    File a complaint →
  • State AG
    State attorneys general in Illinois, Texas, Washington, and other jurisdictions with biometric privacy laws have enforcement authority over biometric data collection practices.
    File a complaint →

Provision details

Document information
Document
Microsoft Privacy Statement (Legacy)
Entity
Microsoft
Document last updated
March 5, 2026
Tracking information
First tracked
Aug. 1, 2026
Last verified
Aug. 1, 2026
Record ID
CA-P-00001003
Document ID
CA-D-00001
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
038c77f4e0e0960bdacc607fc616e0fe9c09d77f584fa91f8e3c4c3050fea6dd
Analysis generated
August 1, 2026 01:43 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Microsoft
Document: Microsoft Privacy Statement (Legacy)
Record ID: CA-P-00001003
Captured: 2026-08-01 01:43:30 UTC
SHA-256: 038c77f4e0e0960b…
URL: https://conductatlas.com/platform/microsoft/microsoft-privacy-statement-legacy/biometric-data-collection-via-windows-hello-and-hololens/
Accessed: Sept. 8, 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's Biometric Data Collection via Windows Hello and HoloLens clause do?

This provision establishes consent as the stated basis for biometric data collection; the on-device storage representation for HoloLens iris data and the product-specific scope of biometric collection are operationally significant for compliance under biometric-specific state laws.

Is ConductAtlas affiliated with Microsoft?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Microsoft.