The policy states that images submitted by users to MetaHuman for character creation are collected to generate a 3D mesh for the requested in-game functionality, and asserts that the images are not used to identify the user.
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
This provision involves collection of photographic images of users, which may constitute biometric information or biometric identifiers under laws such as the Illinois Biometric Information Privacy Act (BIPA) and similar state statutes, even where Epic asserts the purpose is limited to mesh generation rather than identification. The legal classification of facial scan data used for mesh generation under applicable biometric privacy frameworks is not resolved by the policy's assertion of non-identification purpose.
Interpretive note: Whether collection of facial images for mesh generation constitutes collection of biometric identifiers or biometric information under applicable state law depends on the specific statutory definitions and how the processing pipeline operates, which is not fully described in the policy.
Under this provision, users who use MetaHuman provide facial images that Epic processes to create a character mesh. The agreement asserts that these images are not used to identify the user, but does not specify the retention period for the images or the generated mesh data following character creation.
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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
1) REGULATORY LANDSCAPE: Collection of facial images for mesh generation may implicate the Illinois Biometric Information Privacy Act (BIPA, 740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (CUBI, Tex.
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This provision involves collection of photographic images of users, which may constitute biometric information or biometric identifiers under laws such as the Illinois Biometric Information Privacy Act (BIPA) and similar state statutes, even where Epic asserts the purpose is limited to mesh generation rather than identification. The legal classification of facial scan data used for mesh generation under applicable biometric …
Under this provision, users who use MetaHuman provide facial images that Epic processes to create a character mesh. The agreement asserts that these images are not used to identify the user, but does not specify the retention period for the images or the generated mesh data following character creation.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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