Provision record
Wealthfront · Wealthfront Privacy Policy · View original document ↗

Biometric Data Collection and Retention

Medium severity Common · 296 of 352 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

Medium Jun 2, 2026

The updated policy establishes that Wealthfront may collect personal information about minors when adult account holders designate them as beneficiaries or when custodians provide information during account opening. The policy clarifies that the company does not have actual knowledge of collecting information directly from minors themselves. Additionally, the revised terms disclose that the company may use client personal information to train, develop, and improve AI-powered features, which may be tested with employees or released to clients. The policy states that AI feature outputs are provided for informational purposes only and do not constitute investment advice, and that Wealthfront makes no representation that such outputs are accurate, complete, or suitable for any purpose. If you become aware your child has directly provided information to Wealthfront without your consent, you may contact support@wealthfront.com to request deletion.

View change record →

Clause Stability Stable

0
Changes
5
Months Monitored
Apr 3, 2026
First Seen
Apr 17, 2026
Last Seen
This clause type exists across 4187 other provisions on other platforms.

Consumer impact (what this means for users)

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.

How other platforms handle this

ZipRecruiter Medium

You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.

NVIDIA NIM Medium

NIM container releases that collect data, collect it for the following purposes: (a) to properly configure and optimize products for use with Software; and (b) to improve NVIDIA products and services.

Glassdoor Medium

Some of our ad partners may also enable us to collect similar data directly from their website or app by integrating our or our affiliates' advertising technology.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
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 Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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 …

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
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GLBA
United States Federal
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
Wealthfront Privacy Policy
Entity
Wealthfront
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-001755
Document ID
CA-D-00367
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
de1de4b45e40f23ffec14db7756fd7949361019e04533f8af62af13deaa6be81
Analysis generated
March 20, 2026 05:09 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Wealthfront
Document: Wealthfront Privacy Policy
Record ID: CA-P-001755
Captured: 2026-03-20 05:09:24 UTC
SHA-256: de1de4b45e40f23f…
URL: https://conductatlas.com/platform/wealthfront/wealthfront-privacy-policy/provision/CA-P-001755/biometric-data-collection-and-retention/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Wealthfront's Biometric Data Collection and Retention clause do?

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.

How does this clause affect you?

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.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.

Is ConductAtlas affiliated with Wealthfront?

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