Provision record
PayPal · PayPal Privacy Statement · View original document ↗

Biometric Data Collection and Use

High severity Unique · 0 of 352 platforms
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Document Record

What it is

The policy discloses that PayPal may collect biometric data including voice identification, photo identification, and face scans for authentication purposes, with collection stated to occur upon consent in the user experience. The policy establishes a 3-year maximum retention period for biometric data after account closure.

This analysis describes what PayPal'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 discloses collection of biometric data, which is classified as Sensitive Personal Information under the policy and is subject to heightened statutory protections in multiple jurisdictions including Illinois under BIPA and Texas and Washington under their respective biometric privacy statutes. The consent mechanism, retention period, and disclosure practices for biometric data carry distinct compliance obligations that differ from general personal data requirements.

If You Do Nothing

Biometric data collected with user consent will be retained and used for authentication and related purposes as described, for up to 3 years after account closure unless applicable law requires otherwise

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Biometric data : Such as voice identification, photo identification, or face scans, which we may collect when you consent in the user experience to authenticate you for certain actions related to your account, including, for example, to verify your identity before you access accounts and Services, recover passwords, update profile information, manage payments and payment methods, lift account limitations, and initiate cryptocurrency transfers.

Excerpt from PayPal's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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

Applicable agencies

  • FTC
    The FTC has authority over biometric data collection and consent practices as consumer protection and privacy matters
    File a complaint →
  • State AG
    State attorneys general in Illinois, Texas, Washington, and California have enforcement authority over biometric privacy statutes applicable to this data collection practice
    File a complaint →

Provision details

Document information
Document
PayPal Privacy Statement
Entity
PayPal
Document last updated
May 5, 2026
Tracking information
First tracked
Sept. 5, 2026
Last verified
Sept. 5, 2026
Record ID
CA-P-00045005
Document ID
CA-D-00045
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fde8a24bf5ca4ca5b9a3d100953e755767b80806013c664f784af3e36652738a
Analysis generated
September 5, 2026 02:03 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: PayPal
Document: PayPal Privacy Statement
Record ID: CA-P-00045005
Captured: 2026-09-05 02:03:15 UTC
SHA-256: fde8a24bf5ca4ca5…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/biometric-data-collection-and-use/
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 PayPal's Biometric Data Collection and Use clause do?

This provision discloses collection of biometric data, which is classified as Sensitive Personal Information under the policy and is subject to heightened statutory protections in multiple jurisdictions including Illinois under BIPA and Texas and Washington under their respective biometric privacy statutes. The consent mechanism, retention period, and disclosure practices for biometric data carry distinct compliance obligations that differ from general …

Is ConductAtlas affiliated with PayPal?

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