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

MetaHuman Image Collection for Character Generation

High severity Medium confidence Explicit document language Common · 289 of 352 platforms
Stay ahead of the changes
Track Unreal Engine and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Clause Stability Stable

0
Changes
4
Months Monitored
May 21, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

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.

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
    Submit a data deletion request through Epic's privacy request process described in Section 9, specifying that the request concerns images or mesh data from MetaHuman character creation.

How other platforms handle this

Roblox Medium

To stop us collecting your location information, you can update your device settings, stop using the Service, or uninstall our mobile apps.

Tinder Medium

If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.

Skillshare Medium

When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.

See all platforms with this clause type →
▸ 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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
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
VPPA
United States Federal

Provision details

Document information
Document
Epic Games Privacy Policy
Entity
Unreal Engine
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-013236
Document ID
CA-D-00086
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
b22617ab34d143e7d922d8d0b92f6d5c7adbaf55ccac41007e2e34db51968d49
Analysis generated
May 21, 2026 06:38 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Unreal Engine
Document: Epic Games Privacy Policy
Record ID: CA-P-013236
Captured: 2026-05-21 06:38:16 UTC
SHA-256: b22617ab34d143e7…
URL: https://conductatlas.com/platform/unreal-engine/epic-games-privacy-policy/provision/CA-P-013236/metahuman-image-collection-for-character-generation/
Accessed: Aug. 12, 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

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does Unreal Engine's MetaHuman Image Collection for Character Generation clause do?

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 …

How does this clause affect you?

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.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.

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.