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
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.
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 →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 other platforms handle this
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.
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.
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.
"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
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.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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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.
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.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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