Square · Square Privacy Notice · View original document ↗

Identity Verification and Biometric-Adjacent Data Collection

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity Square recorded 4 documented changes in the last 30 days.
Start monitoring updates
Monitor governance changes for Square Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
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.

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

PlanetScale Medium

When you visit the Careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other in...

American Airlines Medium

American does not knowingly collect personal information directly from children – persons under the age of 13, or another age if required by applicable law – other than when required to comply with the law or for safety and security reasons. Due to the nature of our Services, we may collect travel i...

GOAT Medium

We may collect information about your location, including precise geolocation information, when you use our Services. We use this information to provide location-based services, such as showing you products available in your area, and for other purposes described in this Privacy Policy.

See all platforms with this clause type →

Monitoring

Square has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.

Start Watcher free trial Or create a free account →
▸ 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 Square Privacy Notice

ConductAtlas Analysis

Institutional analysis (Compliance & 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. GDPR Article 9 classifies biometric data used for unique identification as special category data requiring explicit consent or another qualifying basis. The CCPA/CPRA also treats biometric information as sensitive personal information requiring opt-in consent for collection and use. GOVERNANCE EXPOSURE: High. BIPA litigation in Illinois has produced some of the largest privacy-related class action settlements in US history. Noncompliance with biometric data statutes carries statutory damages and class action exposure. The policy's statement that biometric data may be collected for verification purposes without clearly specifying the consent mechanism creates compliance risk in jurisdictions with explicit consent requirements. JURISDICTION FLAGS: Illinois BIPA requires written consent before biometric data collection and has a private right of action. Texas and Washington have similar but distinct frameworks. GDPR Article 9 applies to EEA users. California CPRA requires opt-in consent for sensitive personal information including biometric data. New York does not have a statewide biometric privacy law as of the document analysis date, but New York City has enacted relevant protections. CONTRACT AND VENDOR IMPLICATIONS: Third-party identity verification vendors used by Square in connection with this collection should be assessed for their own biometric data handling compliance, consent infrastructure, and retention and destruction practices. Data processing agreements with these vendors should specify that biometric data is not retained beyond the verification purpose. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that Square's consent collection mechanism for biometric or identity document data meets BIPA and CPRA requirements, including written consent and disclosure of retention schedule. Data mapping should clearly document which user populations are subject to biometric collection and in which product flows. Retention and destruction schedules for biometric data should be audited against statutory requirements in applicable jurisdictions.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

Track 1 platform — free Try Watcher free for 14 days

Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.

Applicable agencies

  • State AG
    State attorneys general in Illinois, Texas, Washington, and California have enforcement authority over biometric data collection practices under BIPA, CUBI Act, and CPRA respectively.
    File a complaint →
  • FTC
    The FTC has authority over unfair or deceptive practices related to biometric data collection under Section 5 of the FTC Act and has issued guidance on biometric privacy.
    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/identity-verification-and-biometric-adjacent-data-collection/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Related Analysis

Professional Governance Intelligence

Need to monitor specific governance provisions?

Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Professional free trial

Or start with Watcher →

Built from archived source documents, structured governance mappings, and historical version tracking.

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.

Is ConductAtlas affiliated with Square?

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