When you sign up as a Fan, OnlyFans may ask you to take a selfie video (.gif) which is processed by a third-party provider to estimate your age or verify your identity. The results and metadata of this process are collected and stored.
This analysis describes what OnlyFans'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
Selfie-based age estimation involves the processing of facial image data, which may qualify as biometric data under certain state laws such as Illinois BIPA, creating significant legal and consent obligations that the policy does not explicitly address.
Interpretive note: Whether the selfie .gif age estimation process legally constitutes biometric data processing under BIPA or analogous statutes is legally uncertain and depends on the specific technology used and jurisdictional interpretation.
Fans may have their facial image data processed by a third-party vendor to estimate age, which goes beyond standard identity checks and may create biometric data rights and risks depending on the user's location.
How other platforms handle this
To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to submit your request via your account.
we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).
"where we carry out third-party age estimation, or third-party age and identity verification of Fans, a short .gif, taken from a 'selfie' that you provide to our third-party providers ... the results of the third-party age estimation process or third-party age and identity verification process (pass / fail and reason for failing) ... metadata associated with the third-party age estimation process or third-party age and identity verification process (e.g. user start and finish time)Excerpt from OnlyFans's Privacy Policy
REGULATORY LANDSCAPE: This provision may engage Illinois BIPA, Texas CUBI, Washington state biometric law, and GDPR/UK GDPR provisions on special category data (Article 9).
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Selfie-based age estimation involves the processing of facial image data, which may qualify as biometric data under certain state laws such as Illinois BIPA, creating significant legal and consent obligations that the policy does not explicitly address.
Fans may have their facial image data processed by a third-party vendor to estimate age, which goes beyond standard identity checks and may create biometric data rights and risks depending on the user's location.
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