The policy states that Venmo collects face scan data from users who provide consent through the in-app user experience, for the stated purposes of account authentication and fraud and risk management.
This analysis describes what Venmo'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 authorizes collection of biometric identifiers in the form of face scans, a category of data that is subject to specific statutory requirements in several U.S. states including Illinois, Texas, and Washington. The consent mechanism is described as occurring within the user experience, but the policy does not specify the form, timing, or revocability of that consent.
Interpretive note: The policy does not specify the form, timing, or revocability of biometric consent, nor does it identify whether a standalone biometric retention schedule exists, creating uncertainty about compliance with state biometric statutes.
Under this clause, Venmo collects face scan data from users who consent within the app, retaining it under the same 10-year post-relationship retention schedule stated elsewhere in the policy. The agreement does not specify a standalone mechanism for users to withdraw biometric consent or request deletion of face scan data independently of a full account deletion request.
Cross-platform context
See how other platforms handle Biometric Face Scan Collection and similar clauses.
Compare across platforms →"Biometric Information - when you consent in the user experience, we collect face scans to authenticate your account and manage fraud and risk.Excerpt from Venmo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Washington My Health My Data Act to the extent facial …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
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.
This provision authorizes collection of biometric identifiers in the form of face scans, a category of data that is subject to specific statutory requirements in several U.S. states including Illinois, Texas, and Washington. The consent mechanism is described as occurring within the user experience, but the policy does not specify the form, timing, or revocability of that consent.
Under this clause, Venmo collects face scan data from users who consent within the app, retaining it under the same 10-year post-relationship retention schedule stated elsewhere in the policy. The agreement does not specify a standalone mechanism for users to withdraw biometric consent or request deletion of face scan data independently of a full account deletion request.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Venmo.