Provision record
Synthesia · Synthesia Privacy Policy · View original document ↗

Personal Likeness and Voice Data for AI Avatar Creation

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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

Tinder Medium

If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ 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 Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & 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.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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/provision/CA-P-009276/personal-likeness-and-voice-data-for-ai-avatar-creation/
Accessed: Sept. 13, 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.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Synthesia?

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