Biometric Data Notice
This notice describes how ACE by Revelation Inc. AI collects, uses, stores, and destroys biometric data. This notice is provided in compliance with the Illinois Biometric Information Privacy Act (740 ILCS 14, "BIPA") and similar state biometric privacy laws.
1. What Biometric Data We Collect
ACE collects the following categories of biometric identifiers and biometric information:
Facial Geometry
Extracted from photographs and video recordings you upload during onboarding. This includes the spatial relationship between facial features (eyes, nose, mouth, jaw line) used to create a photorealistic AI avatar that looks like you.
Voiceprints
Derived from voice recordings you provide during onboarding. This includes vocal characteristics such as pitch, tone, cadence, and speech patterns used to create an AI voice clone that sounds like you.
Expressions & Mannerisms
Captured from training video you record (typically 2 minutes). This includes head movements, facial expressions, gestures, and lip-sync patterns used to create realistic video replicas.
2. Purpose of Collection
We collect biometric data for the following specific, limited purposes:
- AI photo avatars: Creating a photorealistic digital avatar of you for use in AI-generated marketing graphics and social media images.
- AI video replicas: Creating a video replica that can speak scripted content with your likeness and mannerisms.
- AI voice clones: Creating a synthetic voice that matches your natural speaking voice for use in video narration and audio content.
3. How Your Biometric Data Is Used
- Your biometric data is used to train AI models that are unique to you. We create a separate, isolated model for each client.
- Your biometric data is never shared across clients. One client's facial data or voice data is never used to train another client's model.
- Your biometric data is never sold, leased, traded, or otherwise monetized.
- Your biometric data is never used to train general-purpose AI models.
4. Retention Schedule
Your biometric data is retained only as long as necessary to fulfill the purpose for which it was collected. Specifically:
- While your account is active: Your biometric data and trained AI models are retained to provide the service.
- Upon cancellation: All biometric data and trained AI models are permanently destroyed within 30 days.
- Upon deletion request: All biometric data and trained AI models are permanently destroyed within 30 days of your request.
- Inactivity: If your account has been inactive for 3 years, all biometric data is permanently destroyed after providing 30 days' notice.
Whichever of the above events occurs first triggers destruction of your biometric data.
5. Destruction Policy
When biometric data is scheduled for destruction, the following steps are taken:
- Source files (photographs, video recordings, voice recordings) are permanently deleted from our cloud storage (Supabase Storage).
- API calls are made to delete your trained AI models from our third-party providers: HeyGen (photo avatar), Tavus (video replica), and ElevenLabs (voice clone).
- Database records containing biometric metadata are permanently deleted.
- A destruction confirmation is logged with a timestamp, and you are notified by email that destruction is complete.
6. Third-Party Processors
Your biometric data is shared with the following third-party processors solely to create your AI avatar and voice clone:
| Provider | Data Shared | Purpose | Privacy Policy |
|---|---|---|---|
| HeyGen | Photographs, facial geometry | Photo avatar creation | heygen.com/privacy |
| Tavus | Video (face, voice, mannerisms) | Video replica training | tavus.io/privacy |
| ElevenLabs | Voice recordings, voiceprints | Voice cloning and text-to-speech | elevenlabs.io/privacy |
Each provider is contractually required to use your biometric data only for the specific purpose listed above and to delete it upon our instruction.
7. Your Rights
You have the right to:
- Request deletion: Ask us to permanently destroy all of your biometric data and trained AI models at any time.
- Revoke consent: Withdraw your consent to the collection and use of your biometric data at any time. This will trigger destruction of your biometric data within 30 days and may limit or terminate your ability to use avatar-related features.
- Request consent records: Obtain a copy of your consent records, including the date and method by which you provided consent.
- File a complaint: If you believe your biometric privacy rights have been violated, you may file a complaint with us or with your state attorney general.
8. Contact
For questions about this Biometric Data Notice, to exercise your rights, or to report a concern:
Revelation Inc. AI
[email protected]
We will acknowledge your request within 5 business days and complete any requested action within 30 days.