When you use certain Runway features to create videos or audio, the service may collect your voice recordings and face scans, which are considered biometric data under some state laws. Runway states it only uses this biometric data to deliver the specific feature you requested.
This analysis describes what Runway'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
Biometric identifiers such as face scans and voiceprints are among the most sensitive personal data categories and are subject to specific consent, retention, and destruction requirements under laws such as Illinois BIPA and Texas CUBI. The policy does not disclose a specific biometric data retention schedule, which is a material requirement under several of these statutes.
Interpretive note: The provision asserts biometric data is used only to provide the requested service, but the absence of a stated retention schedule creates uncertainty about full compliance with state biometric statutes that impose mandatory retention and destruction timelines.
Provision name updated from 'Biometric Data Collection' to 'Biometric Data Collection for AI Features' to clarify the AI context, but the excerpt content remains identical.
View full change record →Users who activate face or voice-based generation features in Runway are submitting biometric data. The policy asserts use is limited to providing the requested service, but does not state how long biometric data is retained or when it is destroyed, which may limit users' ability to verify compliance with applicable state biometric privacy laws.
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"Biometric data, such as voice data and scans of faces that you submit when you use certain product features to create videos and audio using characteristics like voice and face. Such characteristics may be considered biometric identifiers or biometric information under certain laws including applicable privacy laws. When you choose to use these features, we use any biometric data submitted by you only to provide the service requested by you.Excerpt from Runway's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates Illinois BIPA (740 ILCS 14), Texas Capture or Use of Biometric Identifier Act (CUBI), Washington's biometric privacy statute, and potentially the California Consumer Privacy Act's sensitive personal information category.
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Biometric identifiers such as face scans and voiceprints are among the most sensitive personal data categories and are subject to specific consent, retention, and destruction requirements under laws such as Illinois BIPA and Texas CUBI. The policy does not disclose a specific biometric data retention schedule, which is a material requirement under several of these statutes.
Users who activate face or voice-based generation features in Runway are submitting biometric data. The policy asserts use is limited to providing the requested service, but does not state how long biometric data is retained or when it is destroyed, which may limit users' ability to verify compliance with applicable state biometric privacy laws.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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