Legal
Digital Twin and Biometric Data Policy
How B2B Auto Loop handles the face and voice data behind a Digital Twin
Retention and destruction policy referenced in Master Subscription Agreement Section 8.4 and Privacy Policy Section 6.4
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1. What This Policy Covers
If a Customer records a real person's face or voice to create a Digital Twin avatar or voice clone, we treat that data as its own protected category. It may be biometric data under laws such as the Illinois Biometric Information Privacy Act, and we handle it that way (Privacy Policy Section 6).
Creating a Digital Twin avatar or voice clone through the Service may involve capturing biometric identifiers of the depicted individual, including facial geometry and voiceprint data, which are regulated under state biometric privacy laws including the Illinois Biometric Information Privacy Act (740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code ยง 503.001) and Washington's biometric privacy law (RCW 19.375). Master Subscription Agreement Clause 8 is modeled on the Illinois standard, the strictest of the three, and is designed to satisfy the others as well (Master Subscription Agreement Section 8.1).
A Digital Twin is available on Growth and Scale only. Launch uses stock presenters and stock voices and cannot upload a face or voice (Master Subscription Agreement Section 8.9). We do not knowingly create a voice clone or Digital Twin of anyone under 18, whoever asks (Privacy Policy Section 6.7).
2. Consent
Before any recording, the person completes an identity and liveness check, reads a standalone consent screen, and records a spoken consent statement on camera. The consent screen says what is collected, why, how long we keep it, and how to ask for deletion. An employer's permission does not replace the person's own consent (Privacy Policy Section 6.1).
Under Master Subscription Agreement Section 8.3, we do not accept any biometric data without completing our own consent capture, in this required order:
- Identity verification and liveness check of the individual.
- A standalone consent screen, separate from the account terms and Acceptable Use Policy, stating what biometric data is collected, the specific purpose, the retention and destruction schedule, that the data will not be sold or shared for others' own purposes, and how to request deletion.
- The individual's affirmative consent, not mere acknowledgment.
- A recorded, on-camera verbal consent statement spoken by the individual.
- A signed likeness license.
- Only then, capture of the likeness or voice recording used to build the Synthetic Persona.
We keep a record of the consent screen version, timestamp, method, originating IP address and the recorded consent statement for as long as we hold the data plus two years. Consent runs to the individual depicted, not only to the Customer. An employer's authorization does not substitute for the individual's own release (Master Subscription Agreement Section 8.3).
3. Purpose
The data is used to create and run the Digital Twin for the Customer's own outbound sales and marketing. A Digital Twin is never built for, or used by, anyone other than the Customer the person agreed to, without fresh consent (Privacy Policy Section 6.2). Where the same individual's biometric data would be used for more than one tenant, fresh, purpose-specific consent is obtained for each tenant engagement (Master Subscription Agreement Section 8.5).
4. Where the Data Is Processed
Digital Twin face and voice data is processed only on infrastructure that BAL controls, in specific United States data centers in North Carolina, Texas and Washington that we will pin for this work before any Digital Twin processing begins. These data centers hold SOC 2 Type II and ISO 27001 certifications. It is never sent to the third-party providers that render stock-presenter videos (Privacy Policy Section 6.2).
The only exceptions are the identity and liveness check, which an identity verification provider performs, and the optional image tool described in Section 8 below, which needs the person's separate, express agreement (Privacy Policy Section 6.2).
5. No Training, No Sale
We do not use Digital Twin face or voice data to train shared or cross-Customer models, and no third party may use it to train a model. We do not sell, license or resell a Digital Twin or voice model. We do not use it in the Loop Score (Privacy Policy Section 6.3).
The Loop Score engine and other behavioral-scoring models do not use, train on, or incorporate biometric data. If our architecture ever changes so that any scoring or inference model would incorporate biometric data, we will first disclose the change in writing to all affected Customers, obtain fresh consent from each affected individual, and provide an opt-out (Master Subscription Agreement Section 8.6.1).
Consistent with 740 ILCS 14/15(c), neither BAL nor the Customer will sell, license or monetize a Synthetic Persona on a standalone basis for any purpose other than the one for which the original biometric consent was obtained, resell a trained avatar or voice model to any third party without fresh written consent from the individual, or derive revenue from a Synthetic Persona beyond what was disclosed in the consent process (Master Subscription Agreement Section 8.6).
6. Retention and Destruction Schedule
We permanently delete a person's face and voice data, including voice-clone training data, at the earliest of the following (Privacy Policy Section 6.4; Master Subscription Agreement Section 8.4):
| Trigger | When deletion happens |
|---|---|
| Purpose satisfied | The Digital Twin is permanently removed from active systems and test environments, or a voice or avatar model is superseded and the prior model destroyed. Disabling an avatar or pausing a campaign does not count. |
| Three years | Three years after the person's last interaction with the Service or any Synthetic Persona derived from their data. |
| Withdrawal, departure or termination | 30 days after the person withdraws consent, leaves the Customer's organization or engagement, or the Customer's account or relationship with us ends for any reason. |
This covers facial-geometry data, source footage, voice-clone training data, voice and face models and rendered clips. Deletion is secure erasure, not just hiding the file. Encrypted backup copies are not restored and expire on a rolling schedule within 30 more days, so nothing remains in any backup more than 60 days after the trigger. We provide deletion confirmation to the Customer on request.
From the single retention schedule in Privacy Policy Section 8:
| Data | How long we keep it |
|---|---|
| Digital Twin face and voice data | Source footage, voice and face models and rendered clips are deleted within 30 days of consent withdrawal, the person's departure, or termination. Backup copies expire on a rolling schedule within 30 more days (60 days in total) and are not restored. Section 6.4 sets the outer limits. |
| Consent records | Text-message and conversation consent: 5 years. Digital Twin consent: as long as we hold the data plus 2 years. |
| Backups | Encrypted backups are stored in a bucket created with the provider's United States jurisdictional restriction; providers may process account and network metadata elsewhere. Backups roll off on a 30-day cycle, so deleted data leaves them within 30 days after deletion. |
7. Withdrawal, Departure and Deletion on Request
A person can withdraw consent at any time at privacy@b2bautoloop.com. A Customer must tell us at once if the person leaves its organization. When we receive either notice, we stop using the Digital Twin and disable live links to videos that use it right away, and we delete the source footage, voice model and rendered clips within 30 days (Privacy Policy Section 6.5).
Under the Master Subscription Agreement, the Customer must notify us in writing within two (2) business days after it learns that the person has withdrawn or revoked consent, has left or is about to leave the Customer's organization or engagement, that the Customer can no longer produce the person's documented consent, or that a claim or complaint about the Synthetic Persona has been made. The Customer will not use that likeness or voice again, including after re-hire or re-engagement, without fresh consent (Master Subscription Agreement Section 8.7).
We will delete a Synthetic Persona, its biometric data and the associated rendered content on the verified written request of the individual depicted or of the Customer, in accordance with the schedule above, and will confirm the deletion on request (Master Subscription Agreement Section 8.8).
8. Optional Image Tool
Optional outfit changes to a person's image run on our own models by default. Only if the person separately and expressly agrees during setup do we send a still image to a third-party cloud AI provider, which processes it only to perform the Service for us and may not use it to train its models without our permission. That provider never receives voice data. The person can withdraw this agreement at any time at privacy@b2bautoloop.com (Privacy Policy Section 6.6).
9. Contact
Questions, withdrawals of consent and deletion requests: privacy@b2bautoloop.com. Legal notices: legal@b2bautoloop.com. This clause describes our intended practice and does not define or limit the obligations that biometric privacy laws independently impose on either party (Master Subscription Agreement Section 8.5). It addresses U.S. state law only.