Legal
Your privacy matters to us.
Last updated: 19 August 2026
YourAvatar allows people to create and interact with AI avatars representing real people. To provide that experience, we process personal information, which can include photographs, voice recordings, memories and information contributed by authorised family members, friends or carers.
This Privacy Policy explains what information we collect, why we use it, who we share it with, how long we keep it and the rights you have.
YOURAVATAR.AI LTD operates YourAvatar. We are registered in England and Wales under company number 15481378. Our registered office is 20 Wenlock Road, London, England, N1 7GU.
For most processing described in this Policy, we act as the controller, meaning we decide why and how personal information is used. Where YourAvatar is provided through a care provider or another organisation, that organisation may have its own responsibilities for information it collects or provides to us.
This Policy may apply to:
The same person may fall into more than one category.
We keep conversation and audio information only for as long as reasonably necessary for the relevant feature, security, support or another purpose explained in this Policy. Where the Service provides controls to remove conversation history, those controls will be made available to you.
Memories and stories can involve other people. Contributors should only provide information about somebody else where it is appropriate to do so and should avoid unnecessarily sensitive or intrusive information. We may remove or restrict information if we become aware that its continued use is inappropriate or unlawful.
If you purchase a paid service, payment card details may be collected directly by the payment provider used at checkout. We may receive transaction information such as payment status, amount, subscription status, billing period and a payment reference. We do not intend to store full payment card details ourselves.
Our Cookie Policy explains our use of cookies and similar technologies.
If you contact us, we may keep your contact details, correspondence and information needed to investigate or resolve your enquiry or complaint.
Stories, memories, recordings or conversations may reveal sensitive information, including health information, racial or ethnic origin, religious or philosophical beliefs, political opinions, sexual orientation or sex life.
Photographs, video and voice recordings are personal information when they relate to an identifiable person. They are not automatically special category biometric information merely because they contain a person's face or voice.
Where we process special category information, we will only do so where UK data protection law permits it. Where explicit consent is required, we will ask for it.
We ask Contributors not to provide sensitive information about another person unless they have an appropriate reason and permission where required.
We may obtain personal information directly from you, from an Avatar Subject, Creator, Family Group Lead or authorised Family Group member, from a care provider as part of agreed onboarding, automatically when you use the Service, or from technology providers involved in delivering the Service.
Where we receive personal information about someone indirectly, we will provide appropriate privacy information where required by law. In some circumstances the law provides an exemption, for example where providing the information would involve disproportionate effort, but we will consider the circumstances carefully.
We use personal information for the following purposes:
Our legal bases depend on the purpose and circumstances. They may include performing our contract with you, complying with a legal obligation, our legitimate interests in operating a safe and effective Service, and consent where the law requires it.
Where we rely on legitimate interests, we consider whether our interests are overridden by the rights and interests of the person concerned.
We do not sell personal information.
We do not permit customer photographs, voice recordings, conversations or memories to be used to train general-purpose third-party AI models on our behalf unless we first update this Policy and, where required, obtain appropriate consent.
Where we rely on consent, you can withdraw it at any time. Withdrawal does not affect processing that was lawful before withdrawal.
If the information is necessary to create or operate an avatar, withdrawal may mean that some or all of the avatar can no longer be provided.
If the Avatar Subject can make the relevant decision themselves, their wishes take priority. A Creator, Family Group Lead, care provider or family member cannot override a valid withdrawal simply because they helped create the avatar, contributed information or paid for the Service.
If there is uncertainty about whether an Avatar Subject can make the relevant decision, or whether another person has authority to act for them, we may pause creation, access or changes until the position has been established.
We do not sell personal information. We may share or make information available where necessary to:
A care provider is not entitled to see a resident's conversations or avatar content simply because it introduced the Service. Access must have an appropriate basis and be supported by the permissions available in the Service.
Where a supplier processes personal information on our behalf, we require appropriate contractual and data protection safeguards.
YourAvatar uses artificial intelligence to generate conversational responses. AI systems may process prompts, relevant avatar information, conversation context, transcripts, voice or audio information and other information needed to generate the response.
AI-generated responses may be inaccurate, unexpected or based on an incorrect inference. Our Terms and Conditions explain these limitations.
YourAvatar is not designed to make solely automated decisions about individuals that produce legal or similarly significant effects.
Some service providers may process personal information outside the United Kingdom. Where UK law requires safeguards for an international transfer, we use an appropriate lawful mechanism, such as an adequacy arrangement, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another permitted safeguard.
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and for legal, regulatory, accounting, security or dispute-resolution requirements.
We delete or anonymise personal information when we no longer have a lawful reason to retain it.
UK data protection law generally protects information relating to living individuals. An avatar belonging to someone who has died may nevertheless contain personal information about living family members, friends, Creators and Users.
Where an Avatar Subject dies, we may continue to operate their avatar in accordance with their recorded wishes, our Terms and applicable law. We may restrict access or changes while appropriate authority is established. Information about living individuals will continue to be handled under applicable data protection law.
We use technical and organisational measures designed to protect personal information from unauthorised access, loss, alteration, disclosure or destruction. These include access controls, authentication, security monitoring and appropriate protections for data in transit and at rest. We also require appropriate security measures from suppliers.
No online system can be guaranteed to be completely secure, and we review our safeguards as the Service develops.
Depending on the circumstances, you may have rights to:
These rights are not absolute. Where the same information relates to several people, we will consider the rights and interests of everyone involved.
We may ask for information reasonably necessary to confirm your identity before acting on a request.
You can contact us about privacy, exercise a data protection right or make a complaint by writing to YOURAVATAR.AI LTD, 20 Wenlock Road, London, England, N1 7GU, or by using the contact method provided on youravatar.ai.
We will acknowledge a data protection complaint within 30 days and will investigate and respond without undue delay.
You also have the right to complain to the Information Commissioner's Office, the UK's independent data protection regulator.
We may send information about YourAvatar products and services where permitted by law. Where consent is required for electronic marketing, we will ask for it. You can opt out of marketing at any time using the unsubscribe method in the message or another preference control we make available.
Opting out of marketing does not stop important service messages about your account, security, subscription or operation of the Service.
Our website and application may use cookies and similar technologies for essential operation, security, preferences and, where permitted, analytics. Where consent is required, we will ask for it before using the relevant technology. Please see our Cookie Policy for more information.
We may update this Policy as YourAvatar develops, our technology changes or legal requirements evolve. Where a material change affects how we use personal information, we will take reasonable steps to bring it to the attention of affected users and obtain fresh consent where required.
YOURAVATAR.AI LTD
Company number: 15481378
Registered office: 20 Wenlock Road, London, England, N1 7GU
Website: youravatar.ai
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