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

Windows Recall requires Windows Hello biometric authentication to decrypt

High severity Explicit document language Unique · 0 of 352 platforms
Stay ahead of the changes
Track Microsoft and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
ⓘ

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

Recent Activity

This document changed recently

Medium Sep 10, 2026

The updated statement expands what device data Microsoft collects to explicitly include interactions with Microsoft websites and apps, moving beyond prior language that mentioned only device details, hardware, and settings. The terms now authorize Microsoft to personalize Copilot using conversation history (including saved memories) and optionally using data from other Microsoft products like Bing, Edge, and MSN. You can manage memories and control personalization features using settings within Microsoft Copilot at any time.

View change record →
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 →

How other platforms handle this

Minecraft Medium

GDPR...requires organizations to maintain appropriate security of personal data.

Public.com Medium

These choices do not apply to certain informational communications including important information and documentation relating to your account.

OpenAI Medium

We implement commercially reasonable technical, administrative, and organizational measures designed to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Each time Recall is opened, users must authenticate using Windows Hello biometric sign-in or PIN to decrypt snapshot contents.

Excerpt from Microsoft's Privacy Statement (Legacy)

Provision details

Document information
Document
Microsoft Privacy Statement (Legacy)
Entity
Microsoft
Tracking information
First captured by ConductAtlas
March 5, 2026
Text quoted from version
CA-V-006591, captured Sept. 11, 2026
Record ID
CA-P-016873
Document ID
CA-D-000001
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-006591)
026452c25b8988052a3e63ae41cac2a0ff195edf3a413aa2a16c9ce515232257
Analysis generated
July 9, 2026 17:07 UTC
Methodology
Evidence
✓ Excerpt found verbatim in version CA-V-006591 (checked Oct. 5, 2026)
Citation Record
Entity: Microsoft
Document: Microsoft Privacy Statement (Legacy)
Record ID: CA-P-016873
Version: CA-V-006591
Captured: 2026-09-11 00:08:37 UTC
SHA-256: 026452c25b898805…
URL: https://conductatlas.com/platform/microsoft/microsoft-privacy-statement-legacy/provision/CA-P-016873/windows-recall-requires-windows-hello-biometric-authentication-to-decrypt/
Accessed: Oct. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does Microsoft's Windows Recall requires Windows Hello biometric authentication to decrypt clause do?

The clause states: “Each time Recall is opened, users must authenticate using Windows Hello biometric sign-in or PIN to decrypt snapshot contents.”

Is ConductAtlas affiliated with Microsoft?

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