Unreal Engine · Epic Games Privacy Policy · View original document ↗

Facial Image Collection via MetaHuman

High severity Unique · 0 of 325 platforms
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Facial images are biometric data under Illinois BIPA, Texas CUBI, and Washington My Health MY Data Act, and Epic's policy does not specify a biometric-specific consent mechanism, retention schedule, or destruction policy as required by those laws.

Consumer impact (what this means for users)

Using MetaHuman requires you to submit facial images to Epic, which constitutes collection of biometric data that is subject to special legal protections in Illinois, Texas, Washington, and the EU — and you may not realize this constitutes a meaningfully different category of data than standard account information.

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.

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▸ View Original Clause Language DOCUMENT RECORD
"
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

Applicable regulations

CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
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
Epic Games Privacy Policy
Entity
Unreal Engine
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
May 9, 2026
Record ID
CA-P-000628
Document ID
CA-D-00086
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
6c9a1562e0e89a4ac5fd75fde762ccb9cff446945926d63aea566c2fd9cfb2e1
Analysis generated
May 9, 2026 15:56 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Unreal Engine
Document: Epic Games Privacy Policy
Record ID: CA-P-000628
Captured: 2026-05-09 15:56:42 UTC
SHA-256: 6c9a1562e0e89a4a…
URL: https://conductatlas.com/platform/unreal-engine/epic-games-privacy-policy/facial-image-collection-via-metahuman/
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

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

Frequently Asked Questions

What does Unreal Engine's Facial Image Collection via MetaHuman clause do?

Facial images are biometric data under Illinois BIPA, Texas CUBI, and Washington My Health MY Data Act, and Epic's policy does not specify a biometric-specific consent mechanism, retention schedule, or destruction policy as required by those laws.

How does this clause affect you?

Using MetaHuman requires you to submit facial images to Epic, which constitutes collection of biometric data that is subject to special legal protections in Illinois, Texas, Washington, and the EU — and you may not realize this constitutes a meaningfully different category of data than standard account information.

Is ConductAtlas affiliated with Unreal Engine?

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