Privacy Policy

Effective Date: October 21, 2025
Last Updated: October 21, 2025

Imitation.Skin Agency ("we," "our," or "us") is committed to protecting your privacy and handling your personal information with transparency and care. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website, services, and AI-powered video content creation platform.

1. Information We Collect

We collect the following categories of personal information:

1.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, company name
• Business Information: Job title, industry, company size, budget range
• Communication Data: Messages, inquiries, and feedback you send us
• Project Details: Content requirements, brand guidelines, creative briefs
• Payment Information: Billing address, payment method details (processed securely through third-party payment processors)

1.2 Information We Collect Automatically

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent on pages, click patterns, referral sources
• Analytics Data: Website performance metrics, conversion tracking, user behavior patterns
• Cookie Data: Session cookies, preference cookies, analytics cookies (see Section 9)

1.3 Licensed Talent Information

• Biometric Data: Facial images, voice recordings, physical characteristics (only for licensed talent who sign release agreements)
• Identity Documents: Government-issued IDs for age verification and legal compliance
• Legal Agreements: Signed likeness release forms, talent contracts, consent documentation

2. How We Collect Information

We collect information through the following methods:

• Website Forms: Contact forms, strategy call booking forms, quiz submissions
• Email Communications: Correspondence, newsletters, service updates
• Client Onboarding: Service agreements, project intake forms, creative briefs
• Cookies and Tracking: Website analytics, session tracking, preference management
• Third-Party Integrations: Payment processors, email service providers, CRM systems
• Talent Acquisition: Casting sessions, photo shoots, video recordings (with explicit consent)

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Delivery

• Provide AI-powered video content creation services
• Generate AI content using licensed likenesses or custom avatars
• Deliver finished video assets to clients
• Provide customer support and technical assistance
• Process payments and manage billing

3.2 Business Operations

• Communicate about services, projects, and updates
• Respond to inquiries and schedule strategy calls
• Manage client accounts and project workflows
• Conduct market research and improve our services
• Analyze website performance and user experience

3.3 Marketing and Communications

• Send promotional emails about services and features (with consent)
• Display targeted advertising based on your interests
• Create anonymized case studies and testimonials (with permission)
• Share educational content and industry insights

3.4 Legal and Compliance

• Comply with legal obligations and regulations
• Enforce our Terms of Service and licensing agreements
• Protect our rights, property, and safety
• Prevent fraud, abuse, and unauthorized use
• Maintain records for tax and accounting purposes

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

• Consent: When you provide explicit consent for marketing communications or talent licensing
• Contract Performance: To fulfill our service agreements and deliver content
• Legitimate Interests: To improve our services, prevent fraud, and operate our business
• Legal Obligation: To comply with applicable laws, regulations, and legal processes

5. Information Sharing and Disclosure

We do not sell your personal information. We may share your data with the following parties:

5.1 Service Providers

• Cloud Hosting: AWS, Google Cloud (for secure data storage)
• Payment Processing: Stripe, PayPal (for secure payment transactions)
• Email Services: Mailchimp, SendGrid (for communications)
• Analytics: Google Analytics, Mixpanel (for website performance)
• CRM Systems: HubSpot, Salesforce (for customer management)

5.2 AI Technology Partners

• We use enterprise-grade AI tools to generate video content
• Licensed talent data is processed securely with encryption
• No client data is shared with public AI models
• All AI partners are vetted for GDPR and CCPA compliance

5.3 Legal Requirements

• Law enforcement agencies (when required by law)
• Government authorities (in response to subpoenas or court orders)
• Legal advisors (for professional advice and representation)

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified of any such change.

6. AI and Data Processing

6.1 How We Use AI Technology

Imitation.Skin Agency uses artificial intelligence to create video content featuring licensed likenesses or custom avatars. Our AI processes:

• Facial images and voice recordings (from licensed talent only)
• Client-provided scripts and creative direction
• Brand guidelines and style preferences
• Video rendering and post-production elements

6.2 Data Protection in AI Processing

• All biometric data is encrypted at rest and in transit
• AI models are trained on explicitly licensed data only
• No personal data is used to train public AI models
• Access to AI systems is restricted to authorized personnel
• Regular security audits ensure data protection compliance

6.3 Talent Rights and Consent

Licensed talent retains specific rights over their likeness:

• Explicit consent is required before AI processing
• Talent can review and approve AI-generated content
• Talent can revoke consent per contractual terms
• Compensation is provided per licensing agreements

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

• Client Data: Retained for the duration of the service relationship plus 7 years for legal compliance
• Marketing Data: Retained until you unsubscribe or request deletion
• Licensed Talent Data: Retained per licensing agreement terms (typically 5-10 years)
• Website Analytics: Aggregated and anonymized data retained indefinitely
• Payment Records: Retained for 7 years for tax and accounting purposes

8. Your Privacy Rights

Depending on your location, you may have the following rights:

8.1 GDPR Rights (EEA Residents)

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Opt out of marketing communications and profiling
• Right to Withdraw Consent: Revoke consent at any time

8.2 CCPA/CPRA Rights (California Residents)

• Right to Know: Request disclosure of collected personal information
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of the sale of personal information (we do not sell data)
• Right to Non-Discrimination: Equal service regardless of privacy choices
• Right to Correct: Request correction of inaccurate information
• Right to Limit Use: Limit use of sensitive personal information

8.3 How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email: privacy@imitation.skin

We will respond to your request within 30 days (or as required by applicable law).

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your website experience:

9.1 Types of Cookies We Use

• Essential Cookies: Required for website functionality (cannot be disabled)
• Analytics Cookies: Google Analytics, Mixpanel (track website performance)
• Marketing Cookies: Facebook Pixel, Google Ads (display targeted advertising)
• Preference Cookies: Remember your settings and preferences

9.2 Managing Cookies

You can control cookies through:

• Browser settings (disable or delete cookies)
• Our cookie consent banner (opt out of non-essential cookies)
• Third-party opt-out tools (e.g., Google Analytics Opt-out)

10. Data Security

We implement industry-standard security measures to protect your personal information:

• Encryption: SSL/TLS encryption for data in transit; AES-256 encryption for data at rest
• Access Controls: Role-based access, multi-factor authentication, and regular audits
• Secure Infrastructure: Enterprise-grade cloud hosting with SOC 2 compliance
• Regular Backups: Automated backups with disaster recovery protocols
• Employee Training: Regular security and privacy training for all staff
• Incident Response: 24/7 monitoring and breach notification procedures

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

11. International Data Transfers

Your personal information may be transferred to and processed in countries outside your country of residence, including the United States. We ensure appropriate safeguards are in place:

• Standard Contractual Clauses: EU-approved data transfer agreements
• Privacy Shield (or equivalent): Compliance with international data transfer frameworks
• Data Processing Agreements: Contracts with all third-party processors

12. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately at privacy@imitation.skin.

13. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website
• Sending email notifications to registered users
• Displaying a prominent notice on our homepage

Your continued use of our services after such changes constitutes acceptance of the updated policy.

15. Contact Us

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Effective Date: October 21, 2025
This Privacy Policy was last updated on October 21, 2025.