Provision record
Square · Square Privacy Notice · View original document ↗

Identity Verification and Biometric-Adjacent Data Collection

High severity Medium confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

Square may collect government ID documents and, in some cases, biometric data such as facial recognition information to verify who you are and to comply with legal requirements.

This analysis describes what Square'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)

Biometric data and government-issued identity documents are among the most sensitive categories of personal information, and their collection triggers specific legal obligations in several US states and under GDPR that go beyond standard privacy protections.

Interpretive note: The specific biometric data types collected, the consent mechanism used, and the retention schedule are not fully detailed in the policy excerpt, creating uncertainty about whether collection practices satisfy BIPA and CPRA requirements in all applicable contexts.

Clause Stability Stable

0
Changes
5
Months Monitored
May 11, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Change history

added May 22, 2026

This new provision discloses the collection of sensitive identity documents and biometric data, addressing a significant privacy practice not explicitly covered in the previous version.

View full change record →

Consumer impact (what this means for users)

If Square collects biometric identifiers from you during identity verification, this data is subject to heightened legal protections in states like Illinois, Texas, and Washington, and you may have rights to consent, disclosure, and deletion that Square must honor under applicable state law.

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
    Visit squareup.com/privacy and submit a deletion request specifically referencing identity verification or biometric data. If you are an Illinois resident, you may also have rights under BIPA to request destruction of biometric identifiers.

How other platforms handle this

Notion Medium

To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to submit your request via your account.

ZipRecruiter Medium

we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We collect identity verification information including government-issued identification documents (such as a driver's license or passport) and may collect biometric information or biometric identifiers as needed to verify your identity, comply with legal requirements, or prevent fraud.

Excerpt from Square's Privacy Notice

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: Biometric data collection engages Illinois BIPA, Texas CUBI Act, and Washington's My Health MY Data Act (for certain contexts), each of which imposes specific consent, retention, and destruction requirements.

Insight

Unlock the full institutional analysis

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

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 →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
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
Square Privacy Notice
Entity
Square
Document last updated
May 5, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 11, 2026
Record ID
CA-P-010454
Document ID
CA-D-00363
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0289c6d8cb5faae7f0a22b62297d5eb529db7cfcc001f60a8fa38563c167ffc3
Analysis generated
May 11, 2026 06:14 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Square
Document: Square Privacy Notice
Record ID: CA-P-010454
Captured: 2026-05-11 06:14:10 UTC
SHA-256: 0289c6d8cb5faae7…
URL: https://conductatlas.com/platform/square/square-privacy-notice/provision/CA-P-010454/identity-verification-and-biometric-adjacent-data-collection/
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 Square's Identity Verification and Biometric-Adjacent Data Collection clause do?

Biometric data and government-issued identity documents are among the most sensitive categories of personal information, and their collection triggers specific legal obligations in several US states and under GDPR that go beyond standard privacy protections.

How does this clause affect you?

If Square collects biometric identifiers from you during identity verification, this data is subject to heightened legal protections in states like Illinois, Texas, and Washington, and you may have rights to consent, disclosure, and deletion that Square must honor under applicable state law.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Square?

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