Provision record
OpenRouter · OpenRouter Privacy Policy · View original document ↗

User Responsibility for Third-Party Biometric Consent

High severity High confidence Explicit document language Common · 298 of 352 platforms

Key Facts · in the document’s own words

What does OpenRouter place responsibility on the user to ensure?
“If you submit image, audio or video data containing the voice or image of another person to a Model that performs biometric processing, you are responsible for ensuring that you have obtained appropriate notice and consent from that individual as required by applicable law.”
Version CA-V-006865, captured Sept. 11, 2026 · live source ↗
Our reading, not the document’s words
OpenRouter places responsibility on the user to ensure they have obtained appropriate notice and consent from any individual whose voice or image appears in biometric-processing data submitted to a Model, as required by applicable law.
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This analysis describes what OpenRouter'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)

OpenRouter transfers legal compliance obligations for third-party biometric consent to the user, meaning the user — not OpenRouter — bears responsibility for satisfying applicable biometric privacy laws regarding other individuals.

Recent Activity

This document changed recently

Medium Sep 1, 2026

The updated policy raises the minimum age to use OpenRouter from 13 to 18 years old, meaning users under 18 are no longer eligible. For users who upload files through the Files API feature, the revised terms establish specific handling procedures: files are encrypted at rest and in transit, transmitted to model providers you select, retained until deletion or account closure, and not used for training or marketing purposes. The policy specifies that access is restricted to automated systems necessary to operate the service, and manual access occurs only for investigating violations, responding to legal process, or providing support. You can delete uploaded files at any time, which triggers removal efforts from active systems and backups within timeframes specified in the Data Processing Agreement.

View change record →

Consumer impact (what this means for users)

If you submit another person's voice or image to a biometric-processing Model through OpenRouter, the legal obligation to obtain that person's appropriate notice and consent rests with you.

How other platforms handle this

Midjourney Medium

You are responsible for all content, including any images, videos, and prompts, that you input or generate when using Editor and/or Video.

Duolingo Medium

Any time you click on a link (including advertising banners) or submit your personal information to a third-party website, you will be subject to that third party's privacy policies.

Pinterest Medium

In case of such an assignment by us, you are entitled to terminate the agreement with immediate effect by deactivating your account. We will provide you with reasonable notice of any such assignment.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
If you submit image, audio or video data containing the voice or image of another person to a Model that performs biometric processing, you are responsible for ensuring that you have obtained appropriate notice and consent from that individual as required by applicable law.

Excerpt from OpenRouter's Privacy Policy

Provision details

Document information
Document
OpenRouter Privacy Policy
Entity
OpenRouter
Date stated by the document
Aug. 31, 2026
As printed in OpenRouter’s text (version CA-V-006865), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
May 12, 2026
Text quoted from version
CA-V-006865, captured Sept. 11, 2026
Record ID
CA-P-066416
Document ID
CA-D-000811
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-006865)
477b94e5c69d71aee92300ecdd2be2b925d76d0605d518b54f52833b6117fe0b
Analysis generated
May 21, 2026 01:12 UTC
Methodology
Evidence
✓ Excerpt found verbatim in version CA-V-006865 (checked Oct. 5, 2026)
Citation Record
Entity: OpenRouter
Document: OpenRouter Privacy Policy
Record ID: CA-P-066416
Version: CA-V-006865
Captured: 2026-09-11 01:30:03 UTC
SHA-256: 477b94e5c69d71ae…
URL: https://conductatlas.com/platform/openrouter/openrouter-privacy-policy/provision/CA-P-066416/user-responsibility-for-third-party-biometric-consent/
Accessed: Oct. 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 OpenRouter's User Responsibility for Third-Party Biometric Consent clause do?

OpenRouter transfers legal compliance obligations for third-party biometric consent to the user, meaning the user — not OpenRouter — bears responsibility for satisfying applicable biometric privacy laws regarding other individuals.

How does this clause affect you?

If you submit another person's voice or image to a biometric-processing Model through OpenRouter, the legal obligation to obtain that person's appropriate notice and consent rests with you.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 298 platforms. See the full comparison.

Is ConductAtlas affiliated with OpenRouter?

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