Actor Likeness & Consent Policy

This is the page that matters most for a product like ours, and the one the category is thinnest on. When an ad shows a person who appears to speak, three separate interests exist: the person whose likeness it is, the advertiser running it, and the audience being addressed. This policy sets out what we owe each of them.

1. Where our actors come from

Our presenter library is licensed from a third-party avatar provider. We did not engage or pay those performers directly, and the releases covering them are held by that provider under its own contracts, not by us. We rely on its representation that each presenter derives from a real performer who consented to synthetic reproduction of their likeness and voice for commercial advertising.

We say that plainly because the distinction matters to you. Our assurance about a presenter is only ever as strong as our provider’s, and we are not in a position to independently verify an individual release. We do not scrape faces, we do not derive presenters from social media, and we do not generate a presenter designed to resemble a specific identifiable person — but those are statements about our own conduct, not a warranty about the provenance of every likeness in the catalogue.

What we are doing about that. We are building a consent register that records, per presenter, the permitted uses, the territory, the term, and a reference to the underlying evidence — so that this page can eventually make a verifiable claim rather than a passed-through one. Until that register is populated, treat this section as a description of our supply chain, not a guarantee.

Category restrictions. Our provider’s terms exclude categories performers did not agree to be associated with — including political advocacy, adult content, gambling, tobacco, weapons, and any depiction implying a performer personally endorses a medical, financial, or legal outcome. Those exclusions are why the corresponding entries exist in the Acceptable Use Policy. They are not arbitrary house rules; they are the boundary of somebody’s consent, and breaching them exposes you as well as us.

2. Performers can withdraw

A performer may withdraw their likeness. Because the library is licensed rather than contracted by us directly, a withdrawal normally reaches us through our provider. When it does — or when a performer contacts us directly — we stop offering that presenter for new generations immediately.

Creative you already generated remains licensed to you and does not have to be taken down — you built a campaign in good faith on a presenter we offered. But if a performer withdraws for a serious reason, such as their likeness being used in a way that harms them, we will contact you and ask you to retire the affected creative, and we will refund the credits it consumed. We think that balance is right. If a court or a legal obligation requires removal, we will tell you and explain why.

3. No exclusivity

A presenter is a shared asset. The same synthetic person can appear in a competitor’s ad, including in your category, on the same platform, in the same week. If you need a face nobody else can use, you need a custom actor built from a performer you have engaged directly — a presenter from the shared library will never give you that, and we will not pretend otherwise.

4. Uploading a real person

If the service lets you supply footage or a likeness of a real person, you are making a representation to us, and it is a serious one.

• You have that person’s written, informed consent to create synthetic video of them for advertising — not a verbal agreement, not an inference from an old modelling contract, and not consent given for a different purpose.
• They understood that the result would be synthetic: that they would appear to say words they never said.
• They can withdraw that consent, and you will stop running the creative if they do.
• They are living and over 18, or you hold the rights of the estate and the applicable jurisdiction permits the use.

You may never upload: a public figure, a celebrity, or a politician you have not engaged; anyone from footage you found online; or any person for the purpose of making them appear to endorse something, confess something, or say something they did not say. That is true even if the result is labelled as synthetic.

By uploading a likeness you represent and warrant that the statements above are true, you agree to provide the signed consent on request, and you indemnify us for any claim by the person depicted (Terms of Service, section 9). We may suspend cloning features, refuse a source file, or remove a custom actor at our discretion — including on a complaint from the person depicted — without refund. Source recordings and derived likeness data are deleted within 60 days of the actor being deleted, the account closing, or a verified request from the person depicted.

Personal-avatar creation requires a reviewed approval for the exact source files and settings. An approval ID or a checkbox supplied without an active review record cannot authorize training or rendering. Expired or revoked approvals block new render requests and jobs that have not started. Contact support to provide the signed permission and source material for review. This control does not remove media already exported or cancel work that a rendering service has already accepted.

5. The law you are operating under

Right of publicity is a real and enforceable right in many jurisdictions, and it is personal to the individual — our permission is irrelevant to it. Several US states give a person whose voice or likeness is digitally simulated a direct statutory claim, some with fixed statutory damages that do not require proving financial loss. A growing number of jurisdictions also require synthetic media in advertising to be disclosed as such.

This is a summary for orientation, not legal advice, and the position is changing quickly. If you are building campaigns on real-person likeness, get your own advice for the markets you run in. Compliance with our policy is not a defence to a claim by the individual.

6. If your likeness is being misused

If you believe creative made with our service uses your likeness or voice without your consent, write to hello@fireplaceugc.com with enough detail to identify the creative. You do not need a lawyer to contact us and you do not need to prove your case first.

We acknowledge within 2 business days and investigate. Where the complaint is credible we suspend the creative while we look into it, rather than leaving it running until we are certain — the cost of a wrongly-paused ad is recoverable and the cost of a wrongly-running one is not. The full route, including how a customer disputes a removal, is on the Copyright & Takedown page.