Plaid · Plaid End User Privacy Policy · View original document ↗

Biometric facial geometry comparison for identity

High severity High confidence Explicitdocumentlanguage Common · 298 of 352 platforms
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This analysis describes what Plaid'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)

Plaid explicitly collects and processes biometric facial geometry data—a sensitive category—for identity verification purposes.

Recent Activity

This document changed recently

High Apr 21, 2026

End consumers may see their financial data accessed by a broader range of people under developer accounts, but Plaid now requires developers to formally designate and manage these 'Authorized Users' and take responsibility for their conduct. The introduction of session replay and activity monitoring means developer interactions with your financial data may be recorded for audit or security purposes. The policy does not specify what data is covered by monitoring or how long recordings are retained, which creates operational uncertainty for developers handling sensitive consumer financial information.

View change record →
Medium Apr 19, 2026

Plaid's updated terms establish a new direct relationship with you through the Plaid Account and introduce a monitoring service that operates through a web app. The terms now authorize Plaid to share financial information needed for third-party apps to initiate payments to or from you, which is a broader statement of data-sharing scope than the previous language. This means Plaid's role shifts from primarily facilitating connections to third-party apps toward directly providing account services, including monitoring. The effective date is April 14, 2026, though the change was detected on April 19, 2026. Review your Plaid Account settings to understand what data Plaid holds and how the monitoring service works.

View change record →
Medium Apr 3, 2026

The updated terms clarify that Plaid may request and collect phone numbers, email addresses, and other contact information when you connect financial accounts or verify your identity through a Plaid-connected application. The terms no longer describe a separate Plaid Monitoring Service or Plaid Web-App. The Plaid Account is now framed primarily as a tool to accelerate onboarding and use of third-party applications rather than as a standalone service for monitoring and alerts. The updated language authorizes Plaid to store identity verification data within your Plaid Account if you choose to do so.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 4136 other provisions on other platforms.

Consumer impact (what this means for users)

By providing a photo or video image to Plaid, you permit Plaid to derive and compare your facial geometry against your identity document for identity verification.

How other platforms handle this

ZipRecruiter Medium

authorize ZipRecruiter to connect your account to the account of a "Connected Site" (e.g., Google, LinkedIn, Monster, Facebook or Twitter), we may be able to access information you have provided to the Connected Site...

NVIDIA NIM Medium

telemetry information collected includes: (i) microservice settings, (ii) usage data and (iii) hardware environment.

Glassdoor Medium

Some of our ad partners may also enable us to collect similar data directly from their website or app by integrating our or our affiliates' advertising technology.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
we may compare your derived facial geometry from the image on your identity document to your derived facial geometry in the photograph or video image that you provide to determine whether a person matches their identity document.

— Excerpt from Plaid's Plaid End User Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Plaid End User Privacy Policy
Entity
Plaid
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-028802
Document ID
CA-D-00169
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0a8d827572962cc5012319c796e08d8fb49190be40484061ff10c08cf6718f4b
Analysis generated
May 9, 2026 15:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Plaid
Document: Plaid End User Privacy Policy
Record ID: CA-P-028802
Captured: 2026-05-09 15:51:01 UTC
SHA-256: 0a8d827572962cc5…
URL: https://conductatlas.com/platform/plaid/plaid-end-user-privacy-policy/provision/CA-P-028802/biometric-facial-geometry-comparison-for-identity/
Accessed: July 12, 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 Plaid's Biometric facial geometry comparison for identity clause do?

Plaid explicitly collects and processes biometric facial geometry data—a sensitive category—for identity verification purposes.

How does this clause affect you?

By providing a photo or video image to Plaid, you permit Plaid to derive and compare your facial geometry against your identity document for identity verification.

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 Plaid?

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