If you use the MetaHuman feature to create a game character based on your appearance, Epic collects photos of your face, but states the images are used only to generate a 3D mesh and not to identify you.
This analysis describes what Unreal Engine'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
Facial images are considered biometric data under several state laws, and the policy's assertion that they are not used for identification does not necessarily exempt their collection from biometric privacy statute requirements in states like Illinois, which require prior written consent regardless of the intended use.
Interpretive note: Whether the facial image collection for MetaHuman triggers biometric privacy statutes depends on jurisdiction-specific definitions and whether the mesh generation process involves extraction of biometric identifiers, which is not technically specified in the policy.
Users of Epic's MetaHuman tool who submit facial photos should be aware that biometric privacy laws in some states may give them specific rights regarding how their facial image data is collected, retained, and deleted, independent of Epic's stated purpose limitation.
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"When you use MetaHuman to create in-game characters, we collect images of you to generate a mesh solely to provide the requested functionality, not to identify you.Excerpt from Unreal Engine's Epic Games Privacy Policy
REGULATORY LANDSCAPE: Facial images collected for 3D mesh generation may constitute biometric identifiers or biometric information under Illinois BIPA (740 ILCS 14), Texas CUBI, Washington's My Health MY Data Act, and other state biometric frameworks, …
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Facial images are considered biometric data under several state laws, and the policy's assertion that they are not used for identification does not necessarily exempt their collection from biometric privacy statute requirements in states like Illinois, which require prior written consent regardless of the intended use.
Users of Epic's MetaHuman tool who submit facial photos should be aware that biometric privacy laws in some states may give them specific rights regarding how their facial image data is collected, retained, and deleted, independent of Epic's stated purpose limitation.
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