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

On-Device Biometric Data and Face-Clustering

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Document Record

What it is

The policy states that Samsung's services may automatically generate biometric data including face-clustering data that groups images of the same face across photos stored on the device, and that this data remains on-device and is not accessed, transferred to, or shared by Samsung. Deletion of this data is the user's responsibility through device settings, factory reset, or photo deletion.

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This analysis describes what Samsung'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)

The automatic generation of face-clustering data from stored photos may implicate state biometric privacy laws such as the Illinois Biometric Information Privacy Act (BIPA), which imposes specific notice, consent, and retention requirements for biometric identifiers generated from facial geometry. The policy's assertion that Samsung does not access this data limits Samsung's ability to fulfill deletion requests on behalf of users.

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Interpretive note: Whether automatic on-device generation of face-clustering data constitutes biometric data collection under BIPA or analogous statutes is a question subject to ongoing litigation and regulatory interpretation; the policy's assertion that Samsung does not access the data does not resolve the notice and consent question under all applicable state frameworks.

Recent Activity

This document changed recently

Medium Jul 22, 2026

The updated policy expands Samsung's data collection authority to include device registration, verification for repairs, and configuration of device settings. The terms now explicitly state that Samsung may collect card and transaction information if you apply for a Samsung-branded payment card. Samsung clarified that it will only send personalized marketing when you have provided consent, where required by law. The policy removed its previous statement that defective devices are wiped of personal information before analysis; the updated terms now state Samsung will analyze returned defective devices without that explicit pre-analysis data deletion commitment. For US residents, the policy now discloses rights to opt out of sale of personal information, sharing for cross-context behavioral advertising, targeted advertising processing, sensitive data collection or processing, and to request lists of third parties receiving your information.

View change record →

Consumer impact (what this means for users)

The policy discloses that Samsung services may automatically generate face-clustering biometric data on-device without explicit user initiation, and that this data persists unless the user clears the device cache, performs a factory reset, or deletes the relevant photos. Because Samsung states it does not access this data, users must manage its deletion directly through device-level actions.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    To remove face-clustering biometric data, clear the cache in your system settings, reset your device to factory settings, or delete the relevant photos. To remove registered biometric data or Bixby Voice wake-up command, go to the applicable settings on your device.

Cross-platform context

See how other platforms handle On-Device Biometric Data and Face-Clustering and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Samsung also may generate certain biometric data automatically when certain Services are used (e.g., Samsung's face-clustering technology may group together images of the same face from different photographs stored on your device ("Face-Clustering Data")). This biometric data remains on your device and is not transferred to or accessed or obtained by Samsung. Samsung does not share this biometric data with third parties. Face-Clustering Data will remain on your device unless you clear the cache in your system settings, reset your device to its factory setting, or delete the relevant photos from your device. You can delete your registered biometric data or your Bixby Voice wake-up command from your device at any time in the applicable settings. Because Samsung does not have access to this data, Samsung cannot delete it for you.

Excerpt from Samsung's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Samsung Privacy Policy
Entity
Samsung
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015902
Document ID
CA-D-00571
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
e01714c2c34eae93eda17ae527749f29c680226685f02265732d48266b771396
Analysis generated
July 9, 2026 09:05 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Samsung
Document: Samsung Privacy Policy
Record ID: CA-P-015902
Captured: 2026-07-09 09:05:37 UTC
SHA-256: e01714c2c34eae93…
URL: https://conductatlas.com/platform/samsung/samsung-privacy-policy/provision/CA-P-015902/on-device-biometric-data-and-face-clustering/
Accessed: Sept. 26, 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 Samsung's On-Device Biometric Data and Face-Clustering clause do?

The automatic generation of face-clustering data from stored photos may implicate state biometric privacy laws such as the Illinois Biometric Information Privacy Act (BIPA), which imposes specific notice, consent, and retention requirements for biometric identifiers generated from facial geometry. The policy's assertion that Samsung does not access this data limits Samsung's ability to fulfill deletion requests on behalf of users.

How does this clause affect you?

The policy discloses that Samsung services may automatically generate face-clustering biometric data on-device without explicit user initiation, and that this data persists unless the user clears the device cache, performs a factory reset, or deletes the relevant photos. Because Samsung states it does not access this data, users must manage its deletion directly through device-level actions.

Is ConductAtlas affiliated with Samsung?

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