Jurisdiction Notices

The rules that govern what is traded here differ sharply by country. These notices summarise the position in the markets the registration flow currently models. They are summaries, not advice.

Last updated 22 September 2026Version draft · pending review by counsel per market

European Union and EEA

Facial images and voice recordings used to identify a person are biometric data under the GDPR and require explicit consent under Article 9(2)(a). Consent must be freely given, specific, informed and unambiguous, and withdrawable. Article 50 of the EU AI Act requires that artificially generated or manipulated image, audio and video content depicting real people be disclosed as such. Cross-border transfers rely on adequacy decisions or Standard Contractual Clauses.

United Kingdom

The UK does not recognise a standalone image or personality right. Protection comes from passing off, trade marks, data protection and — decisively — contract. The written scope recorded on this platform is therefore central rather than supplementary. UK GDPR Article 9 explicit consent applies to biometric processing.

Türkiye

KVKK Law No. 6698 treats biometric data as special-category personal data requiring explicit consent under Article 6. Article 86 of Law No. 5846 (FSEK) governs rights in a person's picture and portrait and requires consent for display. Article 24 of the Civil Code and Article 49 of the Code of Obligations protect personality rights. Cross-border transfer is governed by Article 9.

United States

Right of publicity is state law and varies substantially, including on post-mortem duration. Illinois BIPA and the Texas CUBI statute impose written-notice and written-release requirements for biometric identifiers. California AB 2602 and AB 1836, and the Tennessee ELVIS Act, impose specific requirements on contracts licensing digital replicas of voice and likeness, including that the scope be reasonably specific. FTC endorsement guidance applies to advertising use.

China

Articles 1019 and 1023 of the Civil Code protect portrait and voice rights and prohibit making, using or publishing a portrait without consent. PIPL requires separate consent for sensitive personal information and for cross-border provision. The Deep Synthesis Provisions and subsequent labelling measures require conspicuous marking of synthetically generated or edited content.

Other markets modelled

—Canada — PIPEDA meaningful consent; Quebec Law 25 express consent for biometrics and CAI notification.
—Brazil — LGPD Article 11 highlighted consent for biometric data; Civil Code Articles 20–21 on image rights.
—India — DPDP Act 2023 free, specific, informed and unambiguous consent with clear affirmative action.
—Japan — APPI, including individual identification codes derived from face and voice.
—South Korea — PIPA separate consent for unique identifying information and overseas transfer.
—Australia and New Zealand — Privacy Act APP 3.3 for sensitive information and APP 8 for cross-border disclosure.
—South Africa — POPIA consent for special personal information.
—Gulf states — UAE and Saudi PDPL consent and transfer rules, plus local media content standards.

Countries not modelled

Where no pack exists for an applicant's country, the global baseline applies and the applicant confirms they have independently satisfied themselves that participation is lawful where they live. We add packs as markets are validated.