PESONA operates a consent-first face licensing marketplace. We collect personal data — including biometric and face data — to operate the platform, verify identities, process licenses, and facilitate payouts. We are the data controller for all personal data collected through the PESONA platform.
Our registered jurisdiction and full legal entity details will be confirmed and updated in this policy upon incorporation. Until then, all data-related enquiries should be directed to privacy@pesona.ai.
| DATA TYPE | WHAT IT IS | WHY COLLECTED |
|---|---|---|
| Identity documents | Government-issued ID (passport, national ID, driving licence) | KYC verification, age confirmation |
| Face images | Still photographs from multiple angles and expressions | Marketplace profile, license fulfilment |
| Video footage | Silent lifestyle video and/or speaking video with liveness phrase | Marketplace profile, liveness verification, license fulfilment |
| Biometric data | Facial geometry derived from images and video; voice characteristics from speaking video | Identity verification, deduplication, license matching |
| Date of birth | Extracted from identity document | Age verification, minor account detection, custodial release scheduling |
| Display name | Chosen by you — not your legal name | Marketplace profile display |
| Legal name | Extracted from identity document | KYC, talent agreement, payout records. Never shown to Clients. |
| Consent preferences | Categories, markets, duration limits, base rate | License eligibility filtering, consent audit trail |
| Payout details | Bank account, cryptocurrency wallet, or payment method | Processing earnings disbursements |
| Signed agreements | Pesona Agreement, per-license NDAs | Legal record, dispute resolution |
| Usage data | Login timestamps, active licenses, dashboard activity | Platform operation, security, analytics |
| DATA TYPE | WHAT IT IS | WHY COLLECTED |
|---|---|---|
| Company details | Organisation name, registration number, country, industry | Account verification, billing, legal compliance |
| Contact details | Work email address, team member names | Account management, notifications, legal correspondence |
| Billing information | Payment method details (processed via Stripe — we do not store card numbers) | Subscription and license fee processing |
| Usage briefs | Campaign declarations including brand, product, category, markets, dates | License issuance, consent matching, audit trail |
| Render logs | Confirmation records of AI-generated outputs using licensed likenesses | Payout triggering, breach detection, compliance |
| Signed agreements | Client License Agreement, usage briefs, per-license NDAs | Legal record, dispute resolution |
| Usage data | Login timestamps, brief activity, API call logs | Platform operation, security, analytics |
We collect biometric data solely for the following purposes:
We do not use biometric data for advertising profiling, surveillance, or any purpose beyond operating the platform. We do not sell biometric data to third parties. Biometric characteristics derived from your content are stored encrypted and are accessible only to authorised platform systems — not to individual PESONA staff.
A mathematical hash of your facial geometry is generated at upload and stored separately from your images. This hash is used to detect duplicate account registrations. It does not reconstruct your face and cannot be used to identify you by a third party. When your account is deleted, this hash is permanently removed.
| PURPOSE | DATA INVOLVED | LEGAL BASIS |
|---|---|---|
| Identity verification (KYC) | ID documents, face images, biometrics | Legal obligation; explicit consent (biometrics) |
| Platform operation | Account data, consent preferences | Performance of contract |
| License fulfilment | Face images, video, usage briefs | Performance of contract; explicit consent |
| Payout processing | Payout details, transaction records | Performance of contract; legal obligation |
| Breach detection | Watermark data, render logs | Legitimate interest; legal obligation |
| Legal records | Signed agreements, payout logs | Legal obligation |
| Platform analytics | Anonymised usage data | Legitimate interest |
| Security | Login logs, API access logs | Legitimate interest; legal obligation |
PESONA uses Neon (PostgreSQL) for database storage and Vercel Blob for file storage. All data is stored in encrypted form at rest (AES-256) and in transit (TLS 1.3). Face images and video are stored in a dedicated, access-controlled storage bucket separate from general platform data.
Identity documents submitted during KYC are processed by our third-party KYC provider. Once verification is complete, the raw document images are not retained by PESONA — only the verification result, the extracted date of birth, and the KYC provider reference ID are stored in our systems. KYC providers have their own privacy policies governing their data practices.
| RECIPIENT | DATA SHARED | PURPOSE |
|---|---|---|
| Clients (brands, agencies) | Display name, content tier, consent categories, rate, face images and video (licensed scope only) | License fulfilment — only within executed usage brief scope |
| KYC provider | Identity documents, face images (liveness) | Identity verification |
| Payment processor (Stripe) | Billing details, transaction amounts | Subscription and license fee processing, payout disbursement |
| Regulatory authorities | Evidence packages in confirmed breach cases | Regulatory reporting obligation |
| Arbitration bodies | Relevant case evidence | Dispute resolution, upon escalation |
| AI training dataset licensees | Consented face and video data only (where separate dataset license executed) | Dataset licensing — requires explicit additional consent |
We do not sell personal data. We do not share personal data with advertisers, data brokers, or marketing platforms. We do not share any Pesona's legal identity, contact details, or biometric data with Clients — ever.
| DATA TYPE | RETENTION PERIOD | WHAT HAPPENS AFTER |
|---|---|---|
| Face images & video | Duration of active account + 30-day withdrawal notice period + until all active licenses expire | Permanently deleted from storage and database |
| Biometric characteristics | Same as face images & video | Permanently deleted — including all derived hashes |
| Identity documents | Not retained after KYC completion (held by KYC provider per their policy) | KYC provider deletes per their retention schedule |
| Legal name & DOB | Duration of active account + 90-day legal hold after deletion | Permanently deleted after legal hold period |
| Signed agreements | 7 years from execution | Permanently deleted. Anonymised record retained for audit. |
| Transaction & payout records | 7 years from transaction date | Anonymised after 7 years |
| Render logs | 3 years from render date | Permanently deleted |
| Client billing records | 7 years from transaction date | Permanently deleted |
| Platform usage logs | 12 months rolling | Automatically purged |
When a Pesona withdraws from the platform, the deletion sequence proceeds in a defined order: storage files first, then database records, then auth account. The sequence is automated and logged. A confirmation email is sent when deletion is complete.
PESONA operates across multiple markets in Southeast Asia and India. Data may be processed in different jurisdictions as part of normal platform operations — for example, KYC verification, payment processing, or cloud infrastructure may involve data crossing borders.
Where data is transferred across borders, we ensure that appropriate safeguards are in place, including:
Biometric data is subject to additional transfer restrictions in several markets. Where local law requires biometric data to be stored within the country of collection, we comply with those localisation requirements.
Depending on your country of residence, you have some or all of the following rights over your personal data. To exercise any right, contact privacy@pesona.ai. We respond within 30 days.
PESONA does not knowingly collect personal data directly from individuals under 18. Minor accounts are created and managed by a parent or legal guardian, who is responsible for all data submitted on the minor's behalf.
The guardian's explicit consent is required for all data collection relating to a minor. This consent is documented at account creation and at each license notification. All consent records relating to minor accounts are retained for a minimum of 7 years from the date of the relevant transaction.
PESONA uses cookies and similar technologies to operate the platform. We distinguish between:
You can manage cookie preferences in your account settings or browser settings at any time.
Thai residents have rights under the PDPA including access, correction, deletion, data portability, objection, and withdrawal of consent. Biometric data is sensitive personal data under Section 26 of the PDPA and is processed only with your explicit consent. Complaints may be directed to the Office of the Personal Data Protection Committee (PDPC).
Indian residents have rights under the DPDP Act 2023 including access, correction, erasure, and grievance redressal. Face data may constitute biometric data under applicable rules. We comply with all applicable obligations as a Data Fiduciary under the DPDP Act. Complaints may be directed to the Data Protection Board of India.
Malaysian residents have rights under the PDPA 2010 including access to and correction of personal data. We comply with the data protection principles including the consent, notice, and security principles. Complaints may be directed to the Department of Personal Data Protection.
Indonesian residents have rights under Law No. 27 of 2022 on Personal Data Protection, including rights to access, correction, deletion, and objection. Biometric data is classified as specific personal data requiring explicit consent. Complaints may be directed to the Ministry of Communication and Information Technology.
If you are located in the EU or EEA, the GDPR applies to processing of your personal data. You have the rights described in Section 9 above. Your supervisory authority is the data protection authority in your country of residence.
We may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable law. Where changes materially affect how we process your personal data — especially biometric or face data — we will notify you by email at least 30 days before the changes take effect and obtain fresh consent where required by law.
The effective date at the top of this policy indicates when it was last updated. Continued use of the platform after changes take effect constitutes acceptance of the revised policy, except where fresh consent is required, in which case a separate consent action will be requested.
For any privacy-related queries, to exercise your rights, or to raise a concern: