Biometric Information Notice

AKAPULU BIOMETRIC INFORMATION NOTICE Last updated: 2026-08-22 This Biometric Information Notice explains how Akapulu LLC ("Akapulu," "we," "us," or "our") collects, uses, discloses, secures, retains, and deletes biometric or biometric-related information when you use avatar recording and related features. By recording video/audio in Akapulu for avatar creation, you consent to our collection, use, disclosure, retention, and other processing of biometric or biometric-related information as described in this Notice. In this Notice, words and phrases such as "including," "for example," and "such as" mean "including, without limitation." 1. Scope This Notice applies to biometric or biometric-related processing in Akapulu avatar creation and operation workflows, including avatars that remain private and avatars that are made public through Akapulu's approval workflow. 2. What We Mean by Biometric Information For this Notice, biometric or biometric-related information may include information generated from measurements of physical or behavioral characteristics (for example, face geometry or voice characteristics) used in avatar-related processing and identity/safety controls. 3. What We Collect When you record media in Akapulu avatar creation workflows, we may collect and process: - video and audio recordings you provide, - inferred face geometry and related visual features, - inferred voice characteristics and related audio features, - metadata needed to support recording, verification, fraud prevention, and compliance. 4. How We Use Biometric Information We use biometric or biometric-related information to: - create and operate your avatar features, - verify user identity and reduce impersonation/fraud risk, - support safety, abuse prevention, and legal compliance, - maintain and improve platform quality and model performance. 4.1 Public Avatar Authorization If you request public-avatar access and Akapulu approves and enables your avatar as public, you authorize Akapulu to display that avatar in public/catalog contexts within the Services and to allow other logged-in Akapulu users and API customers to use that avatar in real-time conversations and to generate talking clips through the Services. If your avatar is enabled as public, you also authorize Akapulu to use, reproduce, display, and distribute that public avatar and related output for Akapulu marketing and promotional purposes (for example on our website, social media, product demos, and sales materials). 5. How We Share Biometric Information We do not sell, lease, or trade biometric information for profit. We may disclose biometric information to service providers and vendors only as necessary to provide the Services and subject to contractual data protection obligations. Providers may include third parties used for cloud infrastructure, realtime media, speech processing, model serving, and related operations. If you request public-avatar access and Akapulu approves and enables your avatar as public, avatar outputs derived from biometric or biometric-related processing may be made available to other logged-in Akapulu users and API customers for real-time conversation use and talking-clip generation within the Services. 6. Security We use reasonable administrative, technical, and organizational safeguards to protect biometric information. No system can guarantee absolute security. 7. Retention and Deletion We retain biometric or biometric-related information as long as reasonably necessary for avatar operation, product improvement, safety/security, legal compliance, and other lawful business purposes, or as otherwise required/permitted by law. Depending on service operations and legal requirements, some data may be retained long-term or indefinitely unless deletion is requested and applicable law requires or permits deletion. We may delete or de-identify biometric information when no longer required. Where applicable law grants deletion rights, you may request deletion as described below. If you request that a public avatar be removed, we will stop future platform use of that avatar. Historical conversation recordings and talking clips already created using that avatar may be retained. After we verify a valid removal request, we will also use commercially reasonable efforts to remove that avatar from Akapulu-controlled marketing and promotional surfaces within 30 days, subject to operational, legal, and safety constraints. 8. Withdrawal of Consent and Requests To request deletion, withdraw consent where applicable, switch an avatar from public to private, remove a public avatar, or ask questions about biometric processing, contact: Email: [email protected] For additional information about our broader data practices, see the Akapulu Privacy Policy. 9. Changes to This Notice We may update this Notice from time to time. For material updates, we may provide notice by email, in-product notice, posting, or similar means. Updated versions are effective when posted unless otherwise stated.