Synthesia · Synthesia Privacy Policy · View original document ↗

Personal Likeness and Voice Data for AI Avatar Creation

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

If you create a custom AI avatar using your own face or voice, Synthesia collects and stores that likeness and voice data to build and operate the avatar.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Your face and voice are among the most sensitive categories of personal data and may qualify as biometric data under Illinois, Texas, or Washington state law, triggering specific consent, retention, and deletion obligations.

Interpretive note: Whether personal likeness and voice data qualifies as biometric data under GDPR Article 9 or specific US state laws depends on regulatory interpretation and how the data is processed technically; classification is not settled across all jurisdictions.

Consumer impact (what this means for users)

Using the custom avatar feature means Synthesia processes your personal likeness and voice recordings; depending on your location, this may be governed by biometric privacy laws that give you specific rights to consent, limit use, and demand deletion.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Email privacy@synthesia.io with a request to delete your personal AI avatar data including likeness and voice recordings. Identify your account and specify the data you want deleted.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you choose to create a Personal AI Avatar, we will collect and process your personal data including your physical appearance (likeness) and voice. This data is used to create and operate your personalised AI Avatar within our platform.

— Excerpt from Synthesia's Synthesia Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Processing of personal likeness and voice for AI avatar generation engages GDPR Article 6 lawful basis requirements and potentially Article 9 if regulators classify such data as biometric data revealing identity. In the US, the Illinois Biometric Information Privacy Act requires informed written consent before collecting biometric identifiers including facial geometry and voiceprints; the Texas CUBI Act and Washington BIPA equivalent impose similar requirements. The FTC has enforcement authority over deceptive or unfair biometric data practices. The EU AI Act may impose additional transparency and human oversight requirements on AI systems using personal likeness. (2) GOVERNANCE EXPOSURE: High. The processing of personal likeness and voice data for AI avatar creation represents the highest-risk data processing activity in this policy. Unauthorized or insufficiently consented collection of biometric identifiers under BIPA carries statutory damages of $1,000 to $5,000 per violation without requiring proof of harm, creating significant class action exposure for organizations deploying this feature with employees or third parties. (3) JURISDICTION FLAGS: Illinois, Texas, and Washington create the highest exposure for biometric data collection without explicit informed consent. EU and UK users are protected by GDPR and UK GDPR, requiring a clearly documented lawful basis. California's CPRA does not treat facial recognition as biometric data in the same way as BIPA but does include it in the definition of sensitive personal information, triggering opt-out and limit-use rights. Organizations in healthcare or financial services contexts should assess whether additional sector-specific rules apply. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers using Synthesia's custom avatar features for employees or third parties should ensure their own consent mechanisms and internal policies satisfy applicable biometric privacy laws before uploading likeness or voice data. The DPA between Synthesia and enterprise customers should clearly delineate controller and processor responsibilities for this data type, including retention periods and deletion obligations. Standard commercial DPAs may not address biometric data specifically and may require amendment. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should map all workflows involving custom avatar creation to identify whether employee or third-party likeness data is being processed; obtain BIPA-compliant written consent if operating in Illinois; update data inventories to classify likeness and voice data separately from standard personal data; and confirm that Synthesia's deletion processes for avatar data meet applicable statutory timelines upon contract termination.

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Applicable agencies

  • FTC
    The FTC has enforcement authority over unfair or deceptive practices involving biometric and personal data collection, including AI-generated likeness processing.
    File a complaint →
  • State AG
    State Attorneys General in Illinois, Texas, and Washington have enforcement authority over biometric privacy laws that may apply to personal likeness and voice data collection.
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Synthesia Privacy Policy
Entity
Synthesia
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
May 10, 2026
Record ID
CA-P-009276
Document ID
CA-D-00470
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
7648d9071447f69ed848238281e6ab982ee2d650c8e20eb74c961b356314a183
Analysis generated
April 30, 2026 07:49 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Synthesia
Document: Synthesia Privacy Policy
Record ID: CA-P-009276
Captured: 2026-04-30 07:49:32 UTC
SHA-256: 7648d9071447f69e…
URL: https://conductatlas.com/platform/synthesia/synthesia-privacy-policy/personal-likeness-and-voice-data-for-ai-avatar-creation/
Accessed: June 27, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Synthesia's Personal Likeness and Voice Data for AI Avatar Creation clause do?

Your face and voice are among the most sensitive categories of personal data and may qualify as biometric data under Illinois, Texas, or Washington state law, triggering specific consent, retention, and deletion obligations.

How does this clause affect you?

Using the custom avatar feature means Synthesia processes your personal likeness and voice recordings; depending on your location, this may be governed by biometric privacy laws that give you specific rights to consent, limit use, and demand deletion.

Is ConductAtlas affiliated with Synthesia?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Synthesia.