Character.AI prohibits creating characters or content that impersonates real people, whether public figures or private individuals, without their permission.
This analysis describes what Character.AI'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 addresses reputational, privacy, and intellectual property risks associated with AI-generated content depicting real people, and its reference to 'permissible contexts' leaves room for interpretive uncertainty about what uses are allowed.
Interpretive note: The document references 'permissible contexts' for use of name or likeness without defining them, leaving the practical scope of the prohibition ambiguous.
Users who create characters based on real people, including celebrities or public figures, may have that content removed if Character.AI determines it constitutes impersonation, and the document does not define what 'permissible contexts' means in practice.
How other platforms handle this
Users may not use ElevenLabs' platform to generate voice content for the purpose of committing fraud, including financial fraud, identity theft, or unauthorized impersonation for financial gain.
You may not use the Services to generate content that violates applicable laws or regulations, including content that is defamatory, obscene, fraudulent, or that infringes the intellectual property rights of any third party.
Content that's meant to praise, promote, or aid violent extremist or criminal organizations is not allowed on YouTube. We rely on many factors — like certain government and international organization designations — to determine what constitutes criminal or terrorist organizations.
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"Be Creative But Don't Impersonate: Don't impersonate public figures or private individuals, or use someone's name, likeness, or persona without permission or outside of permissible contexts.— Excerpt from Character.AI's Character.ai Community Guidelines
REGULATORY LANDSCAPE: Impersonation and use of likeness without consent engage state right of publicity laws (notably in California and New York), the FTC Act's prohibition on deceptive practices, and potentially the Lanham Act for trademark-related identity misuse. The FTC has also issued guidance on AI-generated impersonation in the context of consumer fraud. EU General Data Protection Regulation provisions on processing of personal data including biometric and identity-related information may also be relevant. GOVERNANCE EXPOSURE: Medium. The provision's reference to 'permissible contexts' without definition creates enforcement ambiguity. Right of publicity claims and defamation exposure associated with AI-generated impersonation content are an active area of legal development, and platforms hosting such content face potential secondary liability depending on jurisdiction and applicable Section 230 protections. JURISDICTION FLAGS: California's right of publicity statute (Civil Code Section 3344) and New York's analogous provisions create heightened exposure for use of name or likeness without consent. Illinois and other states have enacted or are considering AI-specific personality rights legislation. EU GDPR may apply to processing of personal data associated with real-person characters. CONTRACT AND VENDOR IMPLICATIONS: Legal teams should assess whether the platform's character creation tools include technical controls or review processes for content involving real-person names or likenesses, or whether enforcement is reactive and complaint-driven. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the platform's DMCA and takedown processes extend to right of publicity and impersonation complaints, and whether affected individuals have a clear reporting pathway. The undefined scope of 'permissible contexts' should be reviewed for legal adequacy.
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This provision addresses reputational, privacy, and intellectual property risks associated with AI-generated content depicting real people, and its reference to 'permissible contexts' leaves room for interpretive uncertainty about what uses are allowed.
Users who create characters based on real people, including celebrities or public figures, may have that content removed if Character.AI determines it constitutes impersonation, and the document does not define what 'permissible contexts' means in practice.
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