Privacy Policy

Last updated: 2026-07-16 1. Controller The Felizo service is operated by an individual entrepreneur (natural person). Country of operation: Brazil. Full identification of the operator is provided upon legitimate request via the contact e-mail. Contact e-mail: contato@felizo.org. This entity determines the purposes and means of processing the personal data described in this Policy. 2. What data we collect and where it comes from Depending on how you sign in and use the Service, we collect: from Telegram — your Telegram id, name, username, and interface language; from Google sign-in — your Google account identifier (sub) and e-mail address; from e-mail sign-in — the e-mail address you provide; from WhatsApp — your WhatsApp phone number. We also collect the selfies, photos, videos, and text prompts you upload or write. If you use the "My Twin" feature, we also collect: a voice sample you record or upload to create a synthetic clone of your voice; where you choose to narrate the script in your own voice ("my recording"), the audio of that narration; and a consent video in which you appear on camera, read a code shown on screen aloud, and state that you agree to create your AI twin; and, if you choose to record video instead of audio only while providing your voice sample, a short video of your face and voice from that step (audio-only recording is always available as an equal alternative). We also collect the images and videos the Service generates for you; your token balance and transaction history; payment metadata from our payment processors, such as status, amount, and currency (we do not receive or store your full card number); and product-usage events collected through PostHog analytics, such as which screens you open and which features you use. 3. Why we process your data (legal bases) We process your data to perform our contract with you — running your generations, managing your token balance, processing payments, and operating the referral program — and based on your consent where required, for example when you upload a selfie for face-based generation, when you upload a voice sample to clone your voice, when you record the consent video for the "My Twin" feature, or for marketing messages. Your facial image and voice are treated as sensitive data (biometric data, Article 5(II) and Article 11 of the LGPD); for this reason, before creating your AI twin, we ask for specific, prominently displayed consent, separate from your general acceptance of these Terms, within the feature's own creation flow. We also rely on our legitimate interest to keep the Service secure, prevent fraud and abuse of the referral program, and improve the Service through aggregated analytics. 4. Who we share data with We share data with the following processors, only to the extent needed for the purpose stated: fal.ai — receives your uploaded photos and text prompts to run AI image and video generation and, where you use that feature, to train your personal LoRA avatar model; where you use the "My Twin" feature, fal.ai also receives your voice sample (or the audio of your live narration) and your approved portrait, and forwards them to specialised AI model providers, who clone your voice, synthesise the narration of the script, and animate your portrait with lip-sync, creating the synthetic video of your twin speaking. The current list of these providers is available on request at contato@felizo.org. These providers may be located outside Brazil, including in the United States; by using the feature, you consent to this international data transfer, necessary to provide the requested service; Stripe — receives payment details to process card, Apple Pay, Google Pay, PIX, and Mercado Pago payments and subscriptions; Telegram — operates the bot interface, Telegram Stars payments, and any service or marketing messages we send you there; Meta / WhatsApp — operates the WhatsApp Business channel you may use to access the Service and any messages we send you there; Cloudflare — stores your uploaded and generated media in Cloudflare R2 object storage and provides infrastructure and CDN services; PostHog — receives identified product-usage events to help us understand how the Service is used (PostHog session recording is not enabled for the Service). Where you have consented to marketing messages, you can opt out at any time: on WhatsApp by replying STOP or PARAR, and on Telegram by blocking the bot; service messages necessary to operate your account may continue regardless. We do not sell your personal data. 5. Selfies, face images, and biometric-adjacent data When you upload a selfie or another photo of a face to generate images or videos with your likeness, or to train a personal LoRA avatar model, that photo and the model derived from it are used only to produce the generations you request through your account. We do not sell face templates or trained avatar models, and we do not use them for any purpose other than the generations you request. You can delete your uploaded photos, generation results, and trained avatar models at any time by requesting account or content deletion through support; deletion removes this media from our storage (see Section 6). If you use the "My Twin" feature: your voice sample is used to create a synthetic clone of your voice, and that clone (or, if you choose to narrate in your own voice, the recording of that narration) is combined with your portrait to generate a synthetic video in which your image and voice appear to "speak" the script you wrote. We treat the voice sample, the cloned voice, and the consent video with the same care given to your face photos in this Section: we do not sell them, we do not use them to train third-party models beyond what is needed to generate your own content, and you can request deletion of the voice sample, the consent video, the generated synthetic videos, and the twin itself at any time. Note: the copy of the cloned voice model kept by the AI provider (Section 4) is deleted at our request to that provider, which may take some additional time. If you choose to record video (instead of audio only) while providing your voice sample: we treat that video with the same care as the other Twin biometric data described in this Section — we do not sell it and do not share it with the AI providers in Section 4 or use it to generate any output today; we keep it as a base for possible future improvements to the "My Twin" feature (such as making your twin's expressions more accurate), and you can request its deletion at any time. Recording this video is entirely optional — choosing audio only has no effect on your twin. 6. Storage and retention We keep your account data and content for as long as your account is active. If you request account deletion, we delete your uploaded photos, generation results, trained avatar files, and other content from storage, and we anonymise the personal identifiers on your account record. This includes the voice sample, the "My Twin" consent video, the optional video recorded during the voice-sample step, and the narration audio (synthesised or recorded by you) associated with your twins and generations, which we delete in the same way. We retain payment records, token ledger entries, and other transaction records after deletion where required for accounting, tax, or fraud-prevention purposes, for no longer than applicable law requires. 7. Your rights Depending on your jurisdiction, you have the right to access the personal data we hold about you, request correction of inaccurate data, request deletion of your data, withdraw consent at any time (without affecting the lawfulness of processing carried out before withdrawal), object to certain processing, and request a copy of your data in a portable format. To exercise any of these rights, contact us through the "Settings" section of the Service or at contato@felizo.org; we will respond within the time required by applicable law. 8. Additional notice for Brazil (LGPD) and Argentina If you are located in Brazil, this Policy is also intended to comply with the Lei Geral de Proteção de Dados (Lei n.º 13.709/2018, "LGPD"). You have the rights listed in Section 7 under the LGPD, and you may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) if you believe your rights have been violated. If you are located in Argentina, this Policy is also intended to comply with the Ley de Protección de Datos Personales (Ley n.º 25.326). 9. Children The Service is intended for users who are 18 years of age or older. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, contact us and we will delete it. 10. Contact For any question about this Policy or your data, contact us through the "Settings" section of the Service or at contato@felizo.org. 11. Version Last updated: 2026-07-16.