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The AUP prohibits using Stock Avatars to imply that the depicted real-life actor personally holds specific opinions, conditions, or characteristics, with an exception for enterprise service plan users for Stock Avatars and for Custom Avatar users with appropriate individual consent.
This analysis describes what Synthesia'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 restricts a specific category of potentially harmful synthetic media use involving the attribution of sensitive personal characteristics including medical conditions, disabilities, and political views to real individuals depicted by avatars, with tiered permissions based on service plan and consent.
Under this clause, users on non-enterprise plans are prohibited from creating content that attributes personal opinions, medical conditions, disabilities, or political views to the real-life actors depicted by Stock Avatars. Enterprise plan users and Custom Avatar users with individual consent may engage in these representations subject to applicable terms.
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"Using a Stock Avatar in a manner that is meant to, or is reasonably likely to, make viewers think the real-life actor personally holds, endorses, or actually has your stated opinions, characteristics or conditions (for example, publicly saying or strongly implying that the actor has a specific medical condition, disability or political view) - in the case of Stock Avatars, you may do so only on enterprise Service plans and in the case of a Custom Avatar, you may do so only with appropriate consent from the individual.Excerpt from Synthesia's Acceptable Use Policy
REGULATORY LANDSCAPE: Attribution of sensitive personal characteristics including health conditions and disabilities to identifiable individuals in AI-generated content engages GDPR's special category data provisions in the EU and UK, which impose heightened processing restrictions on data concerning health, biometrics, and political opinions. In the US, right-of-publicity laws and defamation law are relevant where false personal characteristics are publicly attributed to real individuals. The EU AI Act's prohibited practices provisions may apply to AI systems generating synthetic media that manipulates individuals based on sensitive characteristics. GOVERNANCE EXPOSURE: High. The attribution of medical conditions, disabilities, or political views to real individuals through AI-generated avatar content represents a high-risk synthetic media use case with significant legal exposure under privacy, defamation, and right-of-publicity frameworks across multiple jurisdictions. The tiered permission structure does not extinguish independent legal obligations that may apply regardless of service plan or contractual consent. JURISDICTION FLAGS: EU and UK organizations should assess whether creating avatar content attributing health or biometric characteristics to identifiable individuals constitutes special category data processing under GDPR, which would require a lawful basis beyond contractual permission. California's right-of-publicity statute and medical privacy laws create heightened exposure for US-based users. Illinois BIPA may be implicated where avatar creation involves biometric data derived from a real individual. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers using Stock Avatars to create training or simulation content involving attributed personal characteristics should confirm that their use case falls within a recognized lawful basis under applicable privacy law, independent of the AUP's enterprise plan exception. Vendor due diligence should assess whether enterprise agreements provide any additional indemnification or liability allocation for claims arising from avatar-based characteristic attribution. COMPLIANCE CONSIDERATIONS: Legal and compliance teams should assess whether any internal training, simulation, or scenario-based content involving attributed medical conditions, disabilities, or political views requires data protection impact assessments under GDPR. Organizations should document the consent basis for any Custom Avatar use involving attribution of sensitive characteristics, and confirm that individual consent meets applicable legal standards in relevant jurisdictions.
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This provision restricts a specific category of potentially harmful synthetic media use involving the attribution of sensitive personal characteristics including medical conditions, disabilities, and political views to real individuals depicted by avatars, with tiered permissions based on service plan and consent.
Under this clause, users on non-enterprise plans are prohibited from creating content that attributes personal opinions, medical conditions, disabilities, or political views to the real-life actors depicted by Stock Avatars. Enterprise plan users and Custom Avatar users with individual consent may engage in these representations subject to applicable terms.
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