This analysis describes what OpenSea'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
This commitment conditions cross-border data transfers on the existence of a legally valid transfer mechanism, providing a compliance baseline for EEA, UK, and Swiss residents.
The updated policy establishes new collection of sensitive personal data categories not previously disclosed in explicit detail. Users of OpenSea's onramp services will have their full legal name, date of birth, tax ID, government-issued identification documents, mobile number, and IP address collected and transmitted to third-party onramp providers. Users subject to identity verification for rewards eligibility or compliance will have facial biometric data processed through third-party providers using facial recognition technology; the provider generates and holds the biometric identifier on OpenSea's behalf and destroys it within three years of last interaction. Users participating in rewards programs will have wallet address, name, contact information, and tax identification numbers collected for eligibility determination and tax reporting. You can decline to use onramp services and still access the Platform, and identity verification for rewards is required only in certain circumstances such as when required for rewards eligibility or compliance.
View change record →If you are located in the EEA, UK, or Switzerland, OpenSea commits to transferring your personal data out of those regions only under a legally valid mechanism with appropriate safeguards.
How other platforms handle this
We may disclose Contact Data as we reasonably believe is necessary to comply with any judicial or governmental subpoenas, warrants or orders.
All transfers of information to service providers are covered by appropriate data agreements and, in the case of cross-border data transfers, legal mechanisms for doing so.
The Company collect and process personal information in [Singapore, Malaysia] for the purpose of providing the services.
"We will use appropriate safeguards for transferring your personal data out of the EEA, UK and Switzerland where required and only transfer such personal data under a legally valid transfer mechanism including, where relevant, entering into the EU Standard Contractual Clauses...Excerpt from OpenSea's Privacy Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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This commitment conditions cross-border data transfers on the existence of a legally valid transfer mechanism, providing a compliance baseline for EEA, UK, and Swiss residents.
If you are located in the EEA, UK, or Switzerland, OpenSea commits to transferring your personal data out of those regions only under a legally valid mechanism with appropriate safeguards.
ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.
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