Provision record
Synthesia · Synthesia Terms of Service · View original document ↗

Custom Avatar Consent Requirement

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Document Record

What it is

Customer is contractually responsible for obtaining free and informed consent from any individual whose voice or likeness is used to create a Custom Avatar, and for ensuring that individual is above the applicable statutory legal age. This obligation rests entirely with the Customer, not Synthesia.

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)

This provision places the legal and operational burden of consent documentation and age verification for Custom Avatar creation on the Customer organization. Non-compliance could result in both contractual liability to Synthesia under the Customer indemnification clause and direct regulatory exposure under biometric data laws and right-of-publicity statutes.

Consumer impact (what this means for users)

Under this clause, any organization using Synthesia to create Custom Avatars must independently verify that the individual whose voice or likeness is being used has provided free and informed consent and is above the applicable statutory legal age, with the agreement assigning sole responsibility for this obligation to the Customer.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Customer will (a) inform Authorized Users of all Customer policies and practices that are relevant to Customer's use of the Services, including the use of any Avatars, and of any settings that may impact the processing or generation of Customer Data, (b) ensure any submission, processing, use or generation of Customer Data is lawful, and (c) ensure that when it authorizes the creation or use of a Custom Avatar using the voice or likeness of an individual, such individual is over the applicable statutory legal age and has provided free and informed consent.

Excerpt from Synthesia's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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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

Provision details

Document information
Document
Synthesia Terms of Service
Entity
Synthesia
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014119
Document ID
CA-D-00471
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
ad7eced3d63c9adc5930b8cce31cc3296ed7d3d4ea35081a5c1e458b31820557
Analysis generated
July 9, 2026 04:47 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Synthesia
Document: Synthesia Terms of Service
Record ID: CA-P-014119
Captured: 2026-07-09 04:47:54 UTC
SHA-256: ad7eced3d63c9adc…
URL: https://conductatlas.com/platform/synthesia/synthesia-terms-of-service/provision/CA-P-014119/custom-avatar-consent-requirement/
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 Custom Avatar Consent Requirement clause do?

This provision places the legal and operational burden of consent documentation and age verification for Custom Avatar creation on the Customer organization. Non-compliance could result in both contractual liability to Synthesia under the Customer indemnification clause and direct regulatory exposure under biometric data laws and right-of-publicity statutes.

How does this clause affect you?

Under this clause, any organization using Synthesia to create Custom Avatars must independently verify that the individual whose voice or likeness is being used has provided free and informed consent and is above the applicable statutory legal age, with the agreement assigning sole responsibility for this obligation to the Customer.

Is ConductAtlas affiliated with Synthesia?

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