Biometric Data Policy

What we collect

Creator Cast is opt-in. When you create your own digital double, we capture, with your explicit consent and 18+ attestation: live selfie face frames (front, left, right), liveness/anti-spoof evidence, and a short spoken voice-challenge recording. These are biometric identifiers (facial geometry and voiceprint).

Creator selfie portraits (Fan Selfies)

Creators can enable Fan Selfies— AI images that show their real appearance next to a fan's — by uploading a small set of portrait photographs of themselves. This is a separate, explicit opt-in with its own consent and does not require the identity verification described below. The portraits are your real likeness and are treated as special-category biometric data: they are stored in our own object storage, and each time a fan selfie is created your portrait likeness is sent to our AI image sub-processor to compose that one image (it is not retained by that provider).

You can remove individual portraits at any time from your Creator Cast settings — removal deletes them from storage. If you later opt in to verified real-person video, the same portraits are registered with the verification provider (under that flow's separate consent) so you never upload them twice; and if you verified first, the portraits you uploaded there serve Fan Selfies the same way. On revoke or erasure they are destroyed with the rest of your Creator Cast data, as described in the schedule below.

Verified real-person video identity

Some Creator Cast owners additionally opt in to generate video that features their real appearance (rather than a stylised synthetic double). This requires a separate, explicit verification step. With your consent, you complete a liveness face scan hosted by a specialist verification provider on your own device, and one or more portrait photographs of your own likeness are stored in that provider's verified-identity asset library so that only you can generate real-person video of yourself.

Unlike the digital-double flow above, in this flow your biometric liveness data and portrait likeness are held by that verification provider — they are not processed once and discarded. The provider operates outside the European Economic Area (Singapore). This transfer and storage happen only after your separate, explicit consent. Your portraits are also kept in our own object storage(the creator selfie portraits described above) so Fan Selfies can be composed from your likeness — our image-generation sub-processor cannot read the provider's asset library directly. When you revoke your verified identity or request erasure, a single erasure request triggers deletion of both your data at the verification provider and the portraits in our object storage — and it runs immediately on a verified deletion request. See our sub-processor list for the provider and the transfer safeguards that apply.

How the verification works. The provider performs real-person verification — detection technology confirms a live person (not a photo, replay, or mask) — and same-person authentication, which compares the face captured during the scan against the portrait photos you upload to confirm they depict the same individual. The facial image retained after a successful scan is used only as the baseline for that comparison. This is not a government or identity-database check and does not establish your legal identity.

The provider acts only on our instructions. It processes your facial information solely to provide this verification and same-person matching for us, and does not use it for any purpose unrelated to our instructions — it is not used to train its models. The storage period and deletion of your facial information are determined and carried out by us as described here. If you want to access, correct, delete, or port your facial information, or withdraw your consent, you request it directly from us (from your Creator Cast settings or via your privacy choices) and we action it, including deletion at the provider. Withdrawing consent stops the processing and deletes the stored facial information.

For the full detail on this flow — verification mechanics, the provider, transfers, retention, your rights, and content-safety handling — see our Real-Person Video Verification Policy.

Purpose & lawful basis

We process this data solely to generate your consented “digital double” variants and the AI clips you or your fans create from them. Our lawful basis is your explicit consent (GDPR Art. 9(2)(a)); for US residents, your written release (e.g. Illinois BIPA). We do not use it to identify you for any other purpose.

Retention & destruction schedule

• Raw capture (face frames + voice recording): deleted immediately once your digital-double variants are successfully generated. If generation does not complete, the raw capture is held only as long as needed to retry and is force-deleted within 7 days at the latest. We keep only the derived synthetic variants and the consent/age/liveness metadata — not the raw biometric source.
• On revoke or deletion: all remaining Creator Cast media (variants, previews, and any residual capture) is permanently destroyed within 30 days, and immediately on a verified erasure request.
• Creator selfie portraits: the portrait images held in our object storage (whether uploaded for Fan Selfies directly or during real-person verification) are destroyed on the same schedule; for verified owners, the same erasure request also triggers deletion of your data at the verification provider — neither store is left behind, and any deletion that cannot be completed immediately is retried until confirmed.
• Consent records: the proof that you consented (version, timestamp, age attestation) is retained as required to evidence lawful processing.

Disclosure & transfers

We do not sell, lease, trade, or profit from your biometric data. To create your digital-double variants, your raw capture frames are processed once by an AI image sub-processor acting on our instructions, then deleted on the schedule above. After that, only the derived synthetic variants are used for clip generation, and — in the digital-double flow — your raw capture frames are never sent to third-party video providers.

If you enable creator selfie portraits, your real portrait likeness is stored in our object storage and sent to our AI image sub-processor to compose the real-person images (such as Fan Selfies) that you or your fans request. If you separately opt in to the verified real-person video identity described above, your liveness biometric data and portrait likeness are additionally transferred to and stored by a specialist verification provider located outside the European Economic Area (Singapore, a country without an EU adequacy decision). The transfer is safeguarded by the EU Standard Contractual Clauses (GDPR Art. 46) incorporated into our data processing agreement with the provider — which commits it to processing your data solely on our instructions and never using it to train its models — and takes place only with your separate, explicit consent. Every store holding your portraits is erased under the single erasure request described above. See our sub-processor list for the providers involved.

Fan selfies

When a viewer chooses to appear in a creator's clip, we capture a live in-browser selfie from the viewer, with their consent. That selfie is a biometric identifier and is processed by a third-party AI vision sub-processor to confirm it shows a live face, and then sent to our generation sub-processor as a labelled reference image so it can compose the requested clip. The selfie is stored in our object storage for this purpose.

Fan reference selfies are retained until the associated creator's Creator Cast character (digital double) is removed, at which point they are deleted along with it. A viewer can request access to or deletion of their own selfie at any time by contacting dpo@prismposter.com. See our sub-processor list for the providers involved.

Your controls

You can pause or revoke your Creator Cast identity, and request access to or deletion of your data, at any time from your Creator Cast settings or by contacting dpo@prismposter.com. Revocation stops further generation and triggers destruction on the schedule above. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at www.aki.ee.