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Face & Likeness Policy

Last updated: October 2, 2026

This policy applies when You choose to use the optional features of flick.to (the "Service") that create an avatar or video content resembling You (the "Likeness Features"). It supplements Our Terms and Conditions and Privacy Policy, which continue to apply; if this policy conflicts with either of them in relation to the Likeness Features, this policy prevails. Capitalized terms not defined here have the meanings given in the Terms and Conditions. This policy is operated by Factum Labs Pte Ltd, 160 Robinson Road #14-04, Singapore 068914 ("We", "Us").

1. The Likeness Features are optional

The Likeness Features are off by default. You can use every part of the Service, including paid features, without them. If You do not enable them, Your films use a stock avatar and no photo of Your face is collected.

2. What We collect, and why

If You enable the Likeness Features, We collect, with Your explicit consent:

  • Face photo(s). One or more photographs of Your face taken in the app (for example, a front-facing photo and a smiling photo). We use these solely to create Your Face Model (below).
  • A verification check (may apply). We reserve the right to ask You to complete a short guided camera check to confirm that You are a live person capturing Your own face, including an automated comparison with Your face photo. We do not necessarily run this check on every capture. Where it runs, the check is a form of biometric verification; it is used once, for this purpose only, and the capture is deleted promptly after the check is completed. Any provider and processing country involved in a verification check will be named on the consent screen before the check runs.
  • Your Face Model. The digital representation of Your face that We derive from Your face photo(s), and keep for as long as the Likeness Features are on, so that We can apply Your likeness to each new film without keeping Your original photos. It consists of: a face template (a mathematical representation of Your facial features), Your look-alike avatar and profile picture, the avatar views used to place You in video scenes[, and a standardized cropped copy of Your face used to apply Your likeness — include only if engineering retains a crop] (together, the "Face Model"). The Face Model is what powers the feature after Your original photos are deleted; it is face data, and We protect it and delete it as described in this policy.

We do not knowingly collect face data of anyone other than You, and We may refuse or delete captures that fail a verification check or that We reasonably believe are not Your own face.

3. What We create and how it is used

We use Your Face Model to:

  • create a look-alike avatar and profile picture for Your Account;
  • apply Your likeness to the face-visible moments of the video scenes used in Your films; and
  • include Your likeness in scenes generated for Your rides.

Content created with the Likeness Features is AI-generated. It is labelled as AI-generated, both visibly and in embedded content credentials, and it may not perfectly resemble You.

We create and use Your Face Model only with Your explicit consent, which We ask for in the app before the camera opens. You can withdraw consent at any time by turning off the Likeness Features or using the "Delete my face data" control in settings. Withdrawal does not affect the lawfulness of processing before withdrawal, and it does not by itself delete films You have already created or shared — You can delete those separately in the app.

5. Processing by service providers, including AI services

Your face data is processed as follows:

  • By Us. Where feasible, Your Face Model is created and applied to video on infrastructure We operate, by automated systems under Our control.
  • By AI service providers. Some processing — including creating Your look-alike avatar and profile picture, and generating scenes — is performed by specialised AI service providers processing on Our documented instructions under data-processing agreements. For that processing, the provider receives the face photo or avatar imagery containing Your likeness needed for the specific generation. Our agreements with these providers prohibit them from using Your face data to train their models or for any purpose of their own, and require deletion within a short period after generation [confirm provider retention periods]. The name of each provider that will process Your likeness, and the country where that processing takes place, are shown to You on the consent screen before You enable the Likeness Features.
  • For verification. If a verification check runs (Section 2), it is performed by [Us / a provider named on the consent screen at that time] under the same restrictions.

We do not disclose Your face data to any other third party, except where required by law.

6. What We will never do with Your face data

We will not sell, lease, trade, or otherwise profit from Your face data. We will not use it to train Our own or any third party's AI models [confirm — see Part D, note 4]. We will not use it for advertising, marketing, or promotional material without Your separate, express permission, even if You share a film publicly — the promotional license in Our Terms and Conditions does not apply to content created with the Likeness Features. We will not use it to identify You or anyone else outside the Service, and We will not make Your likeness available to any other user except through films that You create and choose to share.

7. Retention and deletion

  • Original face photo(s): deleted within 24 hours of Your Face Model being created. New films are made from Your Face Model, not from Your original photos, which is why We do not need to keep them.
  • Verification capture: where a check runs, deleted promptly after the check.
  • Face Model: deleted within 30 days when any of the following happens first: You turn off the Likeness Features, You use "Delete my face data", You delete Your Account, or the Likeness Features go unused on Your Account for 90 consecutive days.
  • Films containing Your likeness: treated as content generations under Our Privacy Policy — deleted within 30 days of account deletion, and deletable individually in the app at any time.
  • Copies held by AI service providers: deleted within the short periods stated in Our agreements with them [confirm].

In all cases, deletion follows the backup and legal-retention rules described in Our Privacy Policy.

8. Your promises to Us

By enabling the Likeness Features, You represent and warrant that:

  • the face You capture is Your own face, and You are the person using the Account;
  • You are at least 18 years old;
  • You will not attempt to create a likeness of any other person — living or dead, real or synthetic, famous or private — or of any person under 18, including Yourself as a minor;
  • You will not use the Likeness Features or any resulting content to impersonate any person, to mislead others about who appears in the content, or in violation of the Content Restrictions in Our Terms and Conditions.

These promises are conditions of using the Likeness Features. If We reasonably believe You have broken them, We may refuse or remove content, disable the Likeness Features for Your Account, and suspend or terminate Your Account in accordance with Our Terms and Conditions. We may — but are not obliged to — use automated checks, including the verification check described in Section 2 where We choose to run it, to enforce this section, and Our not running a check does not limit Our rights under it.

Where the GDPR or similar laws apply, We process Your face data on the basis of Your explicit consent (Article 9(2)(a) GDPR), and Your likeness content on the basis of Your consent and the performance of Our contract with You. You have all of the rights described in Our Privacy Policy — including access, correction, erasure, restriction, objection, and portability — in relation to Your face data. Face data is transferred internationally only as described in Section 5 and protected by the safeguards described in Our Privacy Policy; the consent screen tells You the countries involved before You enable the feature.

10. Changes

If We materially change how the Likeness Features use Your face data, We will ask for Your consent again before the change applies to You. Turning the feature off always remains available in settings.

11. Contact

If You have any questions about this Face & Likeness Policy, You can contact Us: