Kling AI allows users to upload reference photographs of faces and characters to guide AI image and video generation — a process that involves extracting and processing facial features as biometric data.
When you upload a photo of a real person's face as a 'character reference' for AI generation, Kling AI processes that person's facial biometric data — and no consent disclosure or deletion right is disclosed in this document for the subject of the photo.
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See how other platforms handle Facial Reference Image Processing (AI Generation) and similar clauses.
Compare across platforms →Extracting facial geometry from uploaded photographs to control AI output constitutes biometric data processing under BIPA and GDPR Art. 9, regardless of whether a structured biometric template is stored.
1) REGULATORY FRAMEWORK: Illinois BIPA (740 ILCS 14/10) defines biometric identifiers to include facial geometry scans and templates — extraction from photos for AI generation purposes likely qualifies. GDPR Art. 9(1) classifies biometric data processed for the purpose of uniquely identifying a natural person as a special category requiring explicit consent under Art. 9(2)(a). CCPA §1798.140 includes biometric information in the definition of sensitive personal information. FTC Act Section 5 prohibits unfair collection practices. 2)
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