Wealthfront collects selfie photographs and government ID images for identity verification, which may be considered biometric data under some state laws, and requires vendors to delete this data within 90 days.
This analysis describes what Wealthfront'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 establishes the operational framework for biometric data handling during account onboarding, establishing both the authorization for collection and a mandatory retention window followed by destruction protocols. The requirement for vendor compliance on data destruction creates a specific procedural obligation tied to Wealthfront's third-party vendor management.
Your facial biometric data is collected during identity verification and shared with third-party vendors, though those vendors are contractually required to destroy it within 90 days of collection, limiting long-term exposure.
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"We may use third-party vendors for identity verification. These vendors analyze whether the Client's "selfie" matches the government-issued identity document. The information collected from Client photographs may constitute biometric information in some jurisdictions. Where required by law, we will seek consent from you prior to any such collection. We require our third-party vendors who support identity verification to agree to destroy any potential biometric data that is created or gathered for purposes of verifying your identity no more than ninety (90) days after its collection.— Excerpt from Wealthfront's Wealthfront Privacy Policy
Collection of biometric data triggers obligations under BIPA (Illinois), CUBI (Texas), and similar state biometric privacy laws, requiring informed consent, data use policies, and destruction schedules; the 90-day vendor destruction requirement appears designed to address these obligations but compliance teams should verify it covers all applicable jurisdictions.
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This provision establishes the operational framework for biometric data handling during account onboarding, establishing both the authorization for collection and a mandatory retention window followed by destruction protocols. The requirement for vendor compliance on data destruction creates a specific procedural obligation tied to Wealthfront's third-party vendor management.
Your facial biometric data is collected during identity verification and shared with third-party vendors, though those vendors are contractually required to destroy it within 90 days of collection, limiting long-term exposure.
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