Snapchat collects images, videos, and associated metadata from your camera when you use the app, including content from Snaps and augmented reality Lenses that process your facial features.
This analysis describes what Snapchat'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 provision establishes the operational basis for camera and photo collection as a mandatory data input for service delivery. The clause ties data collection directly to specific service features, establishing that these permissions are functionally necessary for the platform's core operations.
Interpretive note: The policy describes camera and image data collection but does not explicitly characterize Lens-based facial processing as biometric data collection; the biometric privacy law applicability is inferred from the nature of the technology described and applicable state law definitions.
Snapchat's privacy policy now includes expanded language describing how the platform collects, processes, and shares user data. The updated policy discloses additional practices and operational procedures governing user information. Review of the specific added sentences is necessary to determine whether new data collection, retention, or sharing practices are described, or whether existing practices receive clarified disclosure.
View change record →When you use Snapchat's camera features including Lenses and filters, Snap collects image and video data that may include facial geometry information; depending on your state, this may qualify as biometric data subject to specific legal protections.
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"Camera and photos. Many of our services require us to collect images and other information from your device's camera and photos. For example, you won't be able to send Snaps or upload photos from your camera roll without this permission. We may collect information about the images and videos you share, including metadata and the content itself.— Excerpt from Snapchat's Snapchat Privacy Policy
(1) REGULATORY LANDSCAPE: Illinois' Biometric Information Privacy Act (BIPA) requires informed written consent before collecting biometric identifiers including face geometry scans, and provides a private right of action. Texas and Washington have analogous biometric privacy statutes. Several other states are considering similar legislation. Snap has faced litigation concerning Lens features and BIPA applicability. GDPR treats biometric data used for identification as a special category under Article 9, requiring explicit consent or another enumerated exception. (2) GOVERNANCE EXPOSURE: High. Camera-based AR features that process facial geometry create BIPA and analogous state law exposure, and Snap has been subject to related legal proceedings. The policy does not specifically address biometric data collection or provide BIPA-specific consent disclosures in this provision. (3) JURISDICTION FLAGS: Illinois presents the highest BIPA exposure given its private right of action and statutory damages structure. Texas and Washington have state AG-enforced biometric statutes. EU/EEA users are protected by GDPR Article 9's special category framework for biometric data. Several additional states including New York and California are expanding biometric privacy protections. (4) CONTRACTUAL AND VENDOR IMPLICATIONS: Third-party Lens creators and augmented reality developers on Snap's platform may also process facial geometry data; their contractual obligations to Snap and their own compliance obligations should be assessed. (5) COMPLIANCE CONSIDERATIONS: Legal teams in Illinois and other states with biometric privacy laws should assess whether Snap's consent mechanisms for camera features satisfy applicable statutory requirements, whether retention and destruction schedules for biometric data are in place, and whether any required written policies exist. EU compliance teams should confirm that facial data processing by Lenses is covered by an appropriate GDPR Article 9 basis.
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This provision establishes the operational basis for camera and photo collection as a mandatory data input for service delivery. The clause ties data collection directly to specific service features, establishing that these permissions are functionally necessary for the platform's core operations.
When you use Snapchat's camera features including Lenses and filters, Snap collects image and video data that may include facial geometry information; depending on your state, this may qualify as biometric data subject to specific legal protections.
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