PRIVACY POLICY        CLOSE

PRIVACY POLICY November 2025

LAST UPDATED: March 31, 2026

The Privacy Policy describes how Impersonas Inc. and its affiliated entities (“Impersonas” “we” and “us”) process personal information about you.  This Privacy Policy applies when you visit or use our websites or mobile applications, including our Impersonas web app and our Impersonas for Talent web app (each a “Site” and collectively “Sites”), contact us, communicate with us on behalf of a vendor or customer, create an account, or otherwise interact with us.  

If you have any questions, please contact us as provided below. If you have a disability and need to receive this Privacy Policy in a different format, please contact us at info@impersonas.com.

CONTENTS

  1. Categories of Personal Information We Process
  2. Sources Of Personal Information
  3. Purposes for Collecting Personal Information
  4. How We Disclose Personal Information
  5. We Combine Information
  6. Sensitive Personal Information
  7. How Long We Keep Personal Information
  8. Cookies, Analytics, and Other Tracking Technology
  9. Links to Other Websites
  10. Security
  11. This Website is Not Intended for Children
  12. Marketing Communications
  13. Processing in the United States
  14. Nevada Privacy Rights
  15. Privacy Rights of Individuals Outside the United States
  16. Contact Us
  17. Updates to Our Privacy Policy

CATEGORIES OF PERSONAL INFORMATION WE PROCESS

The type of information that we collect depends on your interaction and relationship with us.  We collect the below categories and types of personal information with your consent or as otherwise required or permitted by law.  

  • Contact Information.  We collect full name, stage name, email address, current address, telephone number, and business contact information. 

  • Identifiers.  We collect government-issued ID information (for KYC or verification), and digital signature.
  • Personal Characteristics or Traits.  We collect date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, country of residence, military or veteran status, and disability information as permitted by law.
  • Financial Information.  We collect tax identification number, financial or bank account information, tax-related information, wire instructions, disbursement logs, royalites, licensing fees, and billing address.
  • Account Information. We collect your username and password.
  • Internet or Electronic Usage Data.  We collect data related to network and website interaction history, IP address, browser type and device information, operating system, website cookie information, interaction with advertisements and browsing time, login history. We also collect your interaction with marketing emails and newsletters. It includes analytics identifiers, session duration, bounce rate, navigations patterns, embedded content data.
  • Digital Asset and IP-related Information. We collect photographic image collections, 3D and/or AI avatar files, AI-trained likeness models, and voice-trained models (non-biometric, consent-based), metadata or internal identifiers associated with the digital likeness, licensing and collaboration history, and IP ownership documentation and representation agreements.
  • Contractual and Legal Information. We collect licensing agreements and the detailed terms of those contracts, digital or smart contract data (which may include the names of parties involved, wallet addresses used for transactions, time and date stamps, and any digital signatures provided as part of the agreement),  records of consent and approval logs that are required for sublicensing arrangements or collaborative projects, any communications related to the negotiation and execution of these agreements, contracts with existing representors, agents, managers, or other third-party intermediaries involved in representing talent. If digital image rights have already been licensed to a third party, documentation for those existing contracts is also included within this category.
  • Authentication and Security Information. We collect your verification status and KYC records, blockchain or wallet authentication data, access and audit logs.
  • Audio/Visual Data.  We collect audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings.
  • Approximate Geolocation Data.  We collect geolocation data including the general region or area from which you access our Sites.  
  • Professional or Employment Information.  We collect your company name or organization affiliation, job title or professional role, company or agency name, business registration information or proof of affiliation, management and representation contacts, relationship details between the applicant and represented talent, documentation or evidence submitted to authenticate business identity.
  • Recruitment information. We collect job application details, previous work history, salary wage expectation, reference information, compensation and bonus data, benefits data, dependency information, emergency contact information, health insurance information such as your policy number and spouse or dependent information, time tracking, absence and annual leave, travel booking details, business contact details, expense details, performance rating, records of disciplinary action, health and safety related information, workers compensation claims, grievances and complaints, exit interview and comments, and reasons for termination.  To the extent permitted and required by applicable laws, we may collect information about your medical and treatment history, diagnosis, dates of service, provider name, and your ability to work.
  • Inferences.  We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.

  • Talent/Brand Information and Logos. We may publicly display certain information—such as talent names, industries, bios, company names, and partner logos—on public avatar (“impersona”) pages and marketing materials to showcase our collaborations and services. This may also include links to talent or business partner social media profiles, and may be used in external marketing, investor pitches, and testimonials.

  • User-Generated Content (UGC). Where applicable, we may display content generated through collaborations (e.g., advertising materials, press releases, or licensed assets) between talent and brand partners. All such content is reviewed before publication. Requests for removal or modification of such content can be made via our support email, subject to contractual or legal retention obligations.

  • Some information we collect to create your impersona could be considered “Biometric Data” under applicable laws. For more information on how Impersonas and its vendors collect this information, please see our Biometric Information Retention and Handling Policy and our Consumer Health Data Privacy Notice.
               

SOURCES OF PERSONAL INFORMATION

We collect personal information in the following ways:

  • Directly from you.  We collect contact information, identifiers, personal characteristics or traits, financial information, account information, audio/visual data, professional or employment information, recruitment information, digital asset and IP-related information, contractual and legal Information, and authentication and security information that you provide directly to us.

  • Automatically.  When you access our Sites, we collect identifiers, approximate geolocation data, and internet or electronic usage data using tools like browser cookies.

  • From third parties.  We may collect contact information, identifiers, personal characteristics or traits, digital asset and IP-related information, contractual and legal information, and authentication and security Information, audio/visual data, professional or employment information, and education information, from third-parties including our vendors, clients, recruiters, talent agents, brand partners, talent representatives, and service providers.

  • From our employees or job applicants.  We collect contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, recruitment information, professional or employment information from our current or former job applicants, contractors and employees.

PURPOSES FOR COLLECTING PERSONAL INFORMATION

We use personal information for the following business and commercial purposes:

  • Providing our Products and Services.  We use contact information, identifiers, personal characteristics or traits, financial information, account information, audio/visual data, professional or employment information, recruitment information, digital asset and IP-related information, contractual and legal Information, inferences, and authentication and security information to allow individuals to use our services, provide the services we have contracted for, process payments, and provide updates and reports requested by individuals.

  • Transactional Purposes.  We use contact information, identifiers, financial information, professional or employment information, account information, digital asset and IP-related information, contractual and legal Information, inferences, and authentication and security information and to: (i) communicate with you; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, clients, and service providers; and (iv) provide supporting business activities such as billing and collections, procurement, and tax related activities;

  • Recruiting and Hiring.  We use contact information, identifiers, audio/visual data, professional or employment information, recruitment information, and inferences to make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews.

  • Employment Purposes.  We use contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, professional or employment information, and recruitment information, and inferences, to administer all aspects of our employment or contractor relationship with you.  For example, we use the information to complete new hire paperwork, enroll you in our human resource management system, provide you access to our offices and IT systems, set up your personnel file, create benefits packages and provide and administer employee benefits, and other employment related functions.

  • Business Operations.  We use contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, professional or employment information, account information, digital asset and IP-related information, contractual and legal Information, and authentication and security information for our day-to-day business operations.

  • Analytical Purposes.  We use identifiers, internet or electronic usage data, inferences, and approximate geolocation data to analyze preferences, trends and statistics.

  • Marketing and Promotional Purposes.  We use contact information, identifiers, internet or electronic usage data, inferences, and approximate geolocation data, to improve our marketing efforts, send email communications and newsletters and to provide you with information about us, including personalized marketing communications.

  • Maintenance and Improvement of our Sites and Systems.  We use identifiers, approximate geolocation data, internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems.  Maintenance of our systems includes activities such as applying security controls for company systems, and support functions.

  • Security and Fraud Prevention.  We use all categories of information to: : (i) protect us, our employees, and our Sites, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.

  • Legal.  We use all categories of information to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

  • Other Purposes.  We may use your information for other reasons we may describe to you.

HOW WE DISCLOSE PERSONAL  INFORMATION

We disclose personal information in the following circumstances:

  • Service Providers.  We may share personal information with vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf.  

  • Affiliates.  We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.

  • Analytics/Advertising Partners.  We may share personal information with third party analytics or advertising partners, including social media platforms and networks, who provide analytics or marketing and advertising services to us.  

  • Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us.  

  • Government Entities. We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.

  • Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.  

  • Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

WE COMBINE INFORMATION

We combine information we obtain from different sources with publicly available information, including to create inferences about you.  For example, we may combine information that we have collected offline with information we collect online.  We combine information that we have collected across other third party sites.  We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

SENSITIVE PERSONAL INFORMATION

Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

HOW LONG WE KEEP PERSONAL INFORMATION

We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests).   We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future.  We use the following criteria to determine retention periods:

  • how long the information is needed to provide our services and operate our business;
  • whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
  • whether any law, statute, or regulation allows for a specific retention period;
  • whether an individual has agreed to a longer retention period;
  • whether the data is considered to be sensitive data; and
  • what the expectation for retention was at the time the data was provided to us.
  • Collaboration and financial transaction records may be retained indefinitely for audit, verification, and regulatory compliance, even if an associated user profile is deleted, unless otherwise required by law.

COOKIES, ANALYTICS, AND OTHER TRACKING TECHNOLOGY

Cookies and Tracking Technology
We want you to be aware that certain online tools exist to help us serve and recognize you when you visit our website. We receive and store certain types of information when you visit our website. When you access the website, we (including third-party analytics and advertising companies we work with) may place small data files on your computer or other device. These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, log files, or other local storage provided by your browser or associated applications.  These tracking technologies, which are often referred to collectively as cookies, collect information about your use of the Sites and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked and conversion information. We use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity.  If you want to remove or block cookies, you may be able to update your browser settings. You can also find instructions on how to manage cookies on different types of web browsers at www.allaboutcookies.org.

Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Opting Out of Cross-Contextual Behavioral Advertising and Targeted Advertising
We allow third-parties to provide analytics and advertising services and serve advertisements on our behalf across the Internet and in mobile applications. Our advertising partners may collect information about your activities on our Sites on your current device and combine it with information about your activities on other websites, mobile apps, and devices.  They may also collect IP address, browser or operating system type and version, and demographic or inferred-interest information, as well as personal information if you have submitted such information to us through the Sites, such as your name, postal address, email address, or device ID.  They collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Facebook cookies or Google's Advertising ID), cross-device linking, and similar technologies.  For example, our advertising partners may use the fact that you visited our website to target advertising to you on other websites and mobile apps on your current device or on other devices you use.  They may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household.  This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices.  These third parties partners use this information for our and their own advertising, analytics, attribution, and reporting purposes.  To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit http://www.aboutads.info/choices.

Global Privacy Control and Opt-Out Preference Signals
Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “global privacy control” or other opt-out preference signals.  We will respond to these signals in a frictionless manner.  Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address.  If you configure this setting on your browser, certain features on our site may not work and you will receive less targeted advertising.  You will also need to turn the setting on for each browser that you use.

Google Analytics
We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.

LINKS TO OTHER WEBSITES

Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use. Some content, including public profiles of talent, avatar pages, or collaboration histories, may be indexed by search engines and made publicly accessible. Private user information and account details are not indexed and remain confidential.

SECURITY

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

THIS WEBSITE IS NOT INTENDED FOR CHILDREN

We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to info@impersonas.com.

MARKETING COMMUNICATIONS

Marketing Emails.  You can opt out of marketing or advertising emails by using the "unsubscribe" link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us at info@impersonas.com.  Once we process your request, we will cease using the information for such purposes at no charge to you.  If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.

PROCESSING IN THE UNITED STATES

Please be aware that information we obtain about you will be processed in the United States by our service providers or us. By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country.

PRIVACY RIGHTS OF INDIVIDUALS OUTSIDE THE UNITED STATES

This section applies to residents of the United Kingdom, South Korea, UAE, Japan, and Saudi Arabia.

Controller. The controller of your personal information is Impersonas.

Disclosure and Cross-Border Transfer.  Personal information that is shared with affiliates and third parties as described in this Privacy Policy is done in compliance with requisite protections under applicable data protection laws. In accordance with these laws, transfers of personal information are conducted through mechanisms and with protections that comply with applicable laws (such as data transfer agreements that that contain standard contractual clauses adopted by the Information Commissioner, or other such transfer mechanism as prescribed by the Personal Information Protection Commission (South Korea and Japan), UAE Data Office, or Saudi Data and Artificial Intelligence Authority). In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information. By using the Sites or any of our products or services, you are understand and agree that we may share your personal information among our affiliates, our service providers, and other third parties, which may be located in countries outside of your own.

Lawful Basis for Processing Personal Information. The lawful basis for our collection and use of your personal information described in this Privacy Policy is that the processing is (i) necessary for our legitimate interests in carrying out our business, provided those interests are not outweighed by your rights and interests; (ii) necessary to perform a contract with a third-party or with you; (iii) necessary to comply with a legal obligation; or (iv) based, when necessary and appropriate, on your consent.

Special (“Sensitive”) Categories of Data. Unless we specifically authorize you to do so, do not send us any Special Categories of Data, which is defined under applicable data protection laws as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric characteristics, health, or sexual orientation.

Segmentation and Automated Decision Making.  We do not use segmentation or automated decision-making without human intervention, including profiling.

Your Rights Over Your Personal Information. Subject to certain exceptions and limitations, you have the right to:

  • Ask us to confirm whether we are processing your personal information.

  • Ask us to provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format.  Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

  • Request that we update or correct your personal information when it is inaccurate or incomplete.

  • Request that we delete your personal information in certain circumstances.

  • Request that we limit processing or stop processing your personal information in certain circumstances including for marketing activities and profiling for marketing activities and profiling for statistical purposes and, subject to certain exceptions, where such processing is based on our legitimate business interests.

  • Withdraw or revoke consent previously granted to the extent permitted by law.

  • Verified users (registered talent, their teams, and businesses) may request to update or delete their profile information by contacting us at info@impersonas.com. General visitors may unsubscribe from newsletters or marketing emails via the unsubscribe link or by contacting us.

  • Please note, certain financial, contractual, or collaboration history information may be retained to fulfill verification, auditing, and legal obligations. Such records are not subject to deletion at the user's request except as required by applicable law.

Exercising Your Rights. To exercise any of your rights, please contact us at info@impersonas.com. We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester's identity.

You also have the right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs. For the UK, you have the right to lodge a complaint with the Information Commissioner’s Office. The ICO’s complaint procedures may be found at https://ico.org.uk/make-a-complaint/.

CONTACT US

If you have any questions about this Policy or our data practices, please email us at info@impersonas.com

UPDATES TO OUR PRIVACY POLICY

 From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates.  The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Sites. 



Impersonas Inc. is a company registered in Delaware, USA. We operate a platform that connects public figures, talent, and studios to opportunities in digital identity and media licensing.© IMPERSONAS Inc. All rights reserved.

© IMPERSONAS Inc. All rights reserved.
 







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