
Can someone pretend to be you if they have no idea who you are?
It’s been a couple of weeks since I last addressed Worldcoin’s activities, but a lot has happened in Kenya, and now in Argentina also. Here’s a succinct (I hope) update that looks beyond the blaring headlines to see what is REALLY happening.
And, at the end of this post, I address what COULD happen if a fraudster “cut off someone’s face, including gouging out their eyes, and then you draped it all over your own face.” Hey, you have to consider ALL the use cases.
Argentina and data protection laws
So what is the reality in Argentina? According to CoinDesk, the Argentine Agency for Access to Public Information (AAIP) is conducting an investigation into WorldCoin.
According to the AAIP, an entity like Worldcoin must register with the AAIP, provide information about its data processing policy, and indicate the purpose for collecting sensitive data and the retention period for such data. Additionally, the agency requires details of the security and confidentiality measures applied to safeguard personal information. The AAIP did not confirm whether Worldcoin complies with the standards.
Worldcoin told CoinDesk in an emailed statement that “the project complies with all laws and regulations governing the processing of personal data in the markets where Worldcoin is available, including but not limited to Argentina’s Personal Data Protection Act 25.326.”
From https://www.coindesk.com/policy/2023/08/10/worldcoin-regulatory-scrutiny-grows-as-argentina-opens-investigation/
But what is this “personal data” that concerns Argentina so much?
The data that Worldcoin collects
Now a number of companies need to comply with local privacy regulations in numerous countries, and Worldcoin obviously must obey the law in the countries where it conducts business, including laws about personally identifiable information (PII). For illustration, here is an incomplete list of examples of PII, compiled by the University of Pittsburgh:
Name: full name, maiden name, mother’s maiden name, or alias
Personal identification numbers: social security number (SSN), passport number, driver’s license number, taxpayer identification number, patient identification number, financial account number, or credit card number
Personal address information: street address, or email address
Personal telephone numbers
Personal characteristics: photographic images (particularly of face or other identifying characteristics), fingerprints, or handwriting
Biometric data: retina scans, voice signatures, or facial geometry
Information identifying personally owned property: VIN number or title number
Asset information: Internet Protocol (IP) or Media Access Control (MAC) addresses that consistently link to a particular person
From https://www.technology.pitt.edu/help-desk/how-to-documents/guide-identifying-personally-identifiable-information-pii
To my knowledge, Worldcoin acquires PII in two separate instances: when downloading the World App, and when registering at an Orb.
Data collected by the World App
First, Worldcoin collects data when you download the World App. The data that is collected by the iOS version of the World App includes a user ID, the user’s coarse location, a name, contacts, and a phone number. I’ll admit that the collection of contacts is a little odd, but let’s see what happens to that data later in the process.

Data collected by the Orb
Second, Worldcoin collects data when you enroll at an Orb.
Obviously the Orb collects iris images, and also collects face images. But what else is collected at the Orb?
Nothing.
Worldcoin documents two use cases in its privacy statement: one “without data custody,” and one “with data custody.” In the first use case:
Your biometric data is first processed locally on the Orb and then permanently deleted. The only data that remains is your iris code. This iris code is a set of numbers generated by the Orb and is not linked to your wallet or any of your personal information. As a result, it really tells us — and everyone else — nothing about you. All it does is stop you from being able to sign up again.
From https://worldcoin.org/privacy
But what about the second use case, in which the user consents to have Worldcoin retain information (so that the user does not have to re-enroll if they get a new phone)?
Your biometric data is first processed locally on the Orb and then sent, via encrypted communication channels, to our distributed secure data stores, where it is encrypted at rest. Once it arrives, your biometric data is permanently deleted from the Orb.
From https://worldcoin.org/privacy
Regardless of whether biometric data is retained or not, other PII isn’t even collected at the Orb:
Since you are not required to provide personal information like your name, email address, physical address or phone number, this means that you can easily sign up without us ever knowing anything about you.
From https://worldcoin.org/privacy
“But John,” you’re saying, “names and phone numbers are not collected at the Orb, but names and phone numbers ARE collected by the World App. So how are the name, phone number, user ID, and ‘iris code’ linked together?” Let me reprint what Worldcoin says about the app:
Your Worldcoin App is your self-custodial wallet. That means, just like a physical wallet, that no banks, governments or corporations can do anything to it — like lose or freeze your money — you’re in complete control.
You also don’t need to enter any personal information to get or use the App. But even if you do, you can rest assured that, unlike others, we will never sell or try to profit from your personal information.
From https://worldcoin.org/privacy
So apparently, while the World App asks for your name, it is not a mandatory field. I just confirmed this on my World App (which I enabled on May 16, without orb verification); the only identifying information that I could find was my phone number and my user ID.
And I’m assuming that if I were to enroll at an Orb, the iris code would be linked to my user ID.
Depending upon Worldcoin’s internal architecture:
- It’s possible that the iris code could be linked to my phone number, either intentionally or unintentionally. But even if it is, an iris code in and of itself is useless outside of the Worldcoin ecosystem. In the same way that an Aware, IDEMIA, NEC, or Thales fingerprint template (not the fingerprint image) can’t be used to generate a full fingerprint image, a Worldcoin iris code can’t be used to generate a full iris image.
- If I choose the “with data custody” option, my biometric images could be linked to my phone number. Again, they could be linked either intentionally or unintentionally. If such a linkage exists, then that IS a problem. If a user chooses to back up both their World App data and their Orb biometric image data with Worldcoin (and again, the user must CHOOSE to back up both sets of data), how does Worldcoin ensure that the two sets of data can’t be linked?
Presumably Argentina’s AAIP will investigate Worldcoin’s architecture to ensure that there are no financial identity threats.
Which leads us to Kenya.
Kenya and data protection laws
When we last visited Kenya and Worldcoin on August 2, the government had announced that “(r)elevant security, financial services and data protection agencies have commenced inquiries and investigations to establish the authenticity and legality of the aforesaid activities, the safety and protection of the data being harvested, and how the harvesters intend to use the data.”
Those investigations continue, Worldcoin’s Kenya offices have been raided, and Parliament is angry at the regulatory authorities…for not doing enough. The article that reports this states that the Data Protection Unit feels it is not responsible for investigating the “core business” of the registered companies, but Parliament feels otherwise.
The article also makes another interesting statement:
…the office failed to conduct background checks on the company, whose operations have been banned in both the United States of America (USA) and Germany.
From https://nation.africa/kenya/news/you-ve-failed-kenyans-mps-tell-data-commissioner-immaculate-kassait-over-worldcoin-saga-4338518
Um, fake fake fake.
As I previously noted, I can visit an Orb in Santa Monica, California to register my irises. Last I checked, Santa Monica is still part of the United States of America (USA).
Now what I CAN’T do is obtain some Worldcoin when I register my irises.
In addition, Worldcoin tokens (“WLD”) are not intended to be available for use, purchase, or access by US persons, including US citizens, residents, or persons in the United States, or companies incorporated, located, or resident in the United States, or who have a registered agent in the United States. We do not make WLD available to such US persons. Furthermore, you agree that you will not sell, transfer or make available WLD to US persons.
From User Terms And Conditions, Version 3.10, Effective August 2, 2023, https://worldcoin.pactsafe.io/rkuawsvk5.html#contract-qx3iz24-o
But US persons can still download the app and provide irises to our hearts’ content.
We just can’t get any crypto.
And for the Argentine and Kenyan authorities, the main reason they care about this is the crypto.
Worldcoin is useless for most identification use cases
I’ll make the point that I made before.
Worldcoin is NOT a tool to identify and exploit poor people.
In fact, as the term is commonly understood, Worldcoin does not, and cannot, identify ANYONE.
This is by design.
World ID is a digital passport that lets you prove you are a unique and real person while remaining anonymous.
From https://worldcoin.org/world-id
So if you think that obtaining a World ID will allow you to
- open a bank account,
- obtain state welfare benefits, or
- vote in a local election…
…think again.
Worldcoin CANNOT identify you as a known individual.
It can only establish your uniqueness.
But what about the hacks?
But if you’d like to be unsettled, I’ll close with a quote from another Blockworks article written by someone who visited an Orb in Brooklyn, New York. Last I checked, Brooklyn is still part of the United States of America (USA).
I continued on a darker vein: What if a criminal mastermind decided to cut out someone’s eyes, and use them to steal their identity?
The Orb engineer told me that it wouldn’t work. This Orb needs to see alive, blinking eyes, and a human face that is real attached to them. A picture of someone’s eyes won’t scan, robot eyes won’t scan, canine eyes won’t scan.
But then I got him.
If you cut off someone’s face, including gouging out their eyes, and then you draped it all over your own face, could you register as them with a Worldcoin scanner and steal their identity?
Yes.
Although he promised that the Worldcoin R&D team has not tested this particular edge case.
From https://blockworks.co/news/worldcoin-eyeballs-scan-brooklyn
(Repeats to myself) Face/Off was only a movie…Face/Off was only a movie…




























