1. Privacy Policy

1. Introduction

Welcome to Castor Talent AI, Inc. ("Company," "we," "us," or "our"). We respect your privacy and are committed to protecting the personal and biometric data you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at castortalent.ai and use our digital twin and talent licensing platform.

2. Information We Collect

We collect information that identifies, relates to, describes, or is capable of being associated with you:

  • Personal & Account Information: Name, email address, phone number, company/agency affiliation, and payment/banking details required for royalty distributions and licensing transactions.

  • Biometric & Training Data: High-resolution images, video recordings, facial geometry, and voice samples uploaded explicitly by you for the creation, verification, and licensing of your authorized digital twin.

  • Usage & Technical Data: IP addresses, browser type, operating system, device identifiers, referring URLs, and pages viewed during your session.

3. Cookies & Tracking Technologies

We use cookies, local storage, and essential security scripts to ensure site functionality, analyze traffic, and secure our network:

  • Essential & Functional Cookies: Necessary for account authentication, security, and storing your platform session state.

  • Analytics Cookies: Help us understand how visitors interact with the site so we can improve site navigation and visual layout performance.

  • Bot Protection & Security (Cloudflare Turnstile): We use Cloudflare Turnstile to protect our forms and digital likeness registry from automated spam and scraping abuse. Turnstile evaluates non-invasive browser and session telemetry to verify human users without placing tracking cookies across third-party sites. For more details, please review the Cloudflare Privacy Policy.

4. How We Use Your Information & Legal Bases

We process your data for the following core commercial purposes:

  • Digital Twin Generation & Management: Administering the Biometric Rights License (BRL) framework, rendering verified digital twins, and preventing unauthorized likeness usage or deepfakes.

  • Service Execution: Transmitting encrypted training assets to authorized generative AI rendering partners strictly for client campaigns you have explicitly approved.

  • Royalty Processing: Calculating and disbursing licensing revenue to creators and talent representatives.

Legal Basis for Processing (GDPR/UK GDPR): We process general personal data to fulfill our contractual obligations with you. We process Biometric Data exclusively under your explicit, revocable consent (GDPR Article 9(2)(a)).

5. Data Sharing, Security & Retention

  • No Sale of Personal Data: We do not sell, rent, or trade your personal or biometric data to data brokers or third-party advertisers.

  • Authorized Partners: We securely transmit encrypted assets to trusted infrastructure and generative AI execution partners solely to fulfill approved licensing contracts.

  • Enterprise Security: All assets are protected using industry-standard encryption in transit (TLS/SSL) and at rest (AES-256), cryptographic provenance tracking (C2PA standard), and strict access controls.

  • Data Retention & Right to Delete: We retain training assets for as long as your account remains active under a Biometric Rights License. You retain the absolute right to revoke consent and request complete deletion of your source training files and digital twin at any time.

6. California Privacy Rights (CCPA / CPRA Notice)

California Consumer Privacy Act (“CCPA”) Privacy Policy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. For these purposes, "Consumer"

 means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the 

USA for a temporary or transitory purpose. "Device" means any device that can access the Service such as a 

computer, cell phone, or digital tablet.

The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us but reflects our good-faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

By:

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

By Under CCPA, personal information does not include:

Publicly available information from government records

Deidentified or aggregated consumer information

Information excluded from the CCPA's scope, such as:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

Personal Information is covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We may obtain the categories of personal information listed above from the following categories of sources:

Directly from You. For example, from the forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.

Indirectly from You. For example, from observing your activity on our Service.

Automatically from You. For example, through cookies, we or our Service Providers set on your Device as you navigate through our Service.

From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that we use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

To operate our Service and provide you with our Service.

To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our Service.

To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about us, We will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, We will use that information to process your payment and facilitate delivery.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise outlined in the CCPA.

For internal administrative and auditing purposes.

To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, prosecuting those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of your Personal Data" section.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D: Commercial information

Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed but reflects our good-faith belief to the best of our knowledge that some of that 

information from the applicable category may be and may have been disclosed.

When we disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold but reflects our good-faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D: Commercial information

Category F: Internet or other similar network activity

Share of Personal Information

We may share your personal information identified in the above categories with the following categories of third parties:

Service Providers

Payment processors

Our affiliates

Our business partners

Third-party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt into the sale of personal information may opt out of future sales at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

Service Providers

The right to notice. You have the right to be notified of which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to request. Under CCPA, you have the right to request that we disclose information to you about Our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:

The categories of personal information we collected about You

The categories of sources for the personal information we collected about You

Our business or commercial purpose for collecting or selling that personal information

The categories of third parties with whom we share that personal information

The specific pieces of personal information we collected about You

If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to You:

The categories of personal information categories sold

The categories of personal information categories disclosed

The right to say no to the sale of Personal Data (opt-out). You have the right to direct us not to sell your personal information. To submit an opt-out request please contact us.

The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct Our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or Our Service Providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and 

privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:

Denying goods or services to you

Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

Providing a different level or quality of goods or services to you

Suggesting that you receive a different price or rate for goods or services or a different level or quality of goods or services


Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by sending us an email:  ___________ castortalent.ai 

Provide sufficient information that allows us to reasonably verify you are the person about whom We collected personal information or an authorized representative

Your request to us must:

Provide sufficient information that allows us to reasonably verify you are the person about whom We collected personal information or an authorized representative

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

Verify your identity or authority to make the request

And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from You, we will stop selling your personal information. To exercise your right to opt out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt-out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt-out is specific to the browser you use. You may need to opt out of every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The NAI's opt-out platform: http://www.networkadvertising.org/choices/

The EDAA's opt-out platform http://www.youronlinechoices.com/

The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt-out will place a cookie on your computer that is unique to the browser you use to opt-out. If you change browsers or delete the cookies saved by your browser, you will need to opt-out again.

Mobile Devices

Your mobile device may give you the ability to opt-out of the use of information about the apps you use to serve you ads that are targeted to your interests:

"Opt-out of Interest-Based Ads" or "Opt-out of Ads Personalization" on Android devices

"Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

We do not respond to Do Not Track signals.

However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact Us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from Our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before We collect and use that information.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties direct marketing purposes.

If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

To request the removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

7. European & International User Rights (GDPR / UK GDPR)

European Resident Rights under the General Data Protection Regulation (“GDPR”)

GDPR gives you the following rights:

Request Access to your Personal Data. This allows you to receive a copy of your Personal Data and  verify that we are lawfully processing that information.

Request Correction of Your Personal Data. This allows you to have any incomplete or inaccurate Personal Data we hold completed / corrected. Please note that we may need to verify the accuracy of the new Personal Data you provide.

Request Deletion / Erasure of Your Personal Data. You may have the right to request that Personal Data we hold about you be deleted / erased.

Object to Processing Your Personal Data. You may have the right to preclude processing of your Personal Data.

Request Restriction of Processing Your Personal Data. This allows you to ask that we suspend the processing of your Personal Data in the following scenarios: 

if you want us to establish the data’s accuracy; 

where our use of the data is unlawful, but you do not want us to delete/erase it; 

where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request Transfer of Your Personal Data. Where technically feasible, we will provide you, or a third party you designate, your Personal Data in a structured, commonly used and machine-readable format.

Withdraw Your Consent.  You may withdraw your consent at any time. If you do so, we may be unable to provide certain products or services to you. But we will advise you of this when you withdraw your consent.

IF YOU WISH TO EXERCISE ANY OF THESE RIGHTS, PLEASE NOTIFYING US AT erik@castortalent.ai. WE WILL RESPOND PROMPTLY, IN ANY EVENT WITHIN A REASONABLE LENGTH OF TIME.

8. Children’s Online Privacy Protection Act (COPPA Notice)

Our website and platform are strictly intended for individuals who are at least 18 years of age (or minors represented by a legal guardian or licensed talent agency). We do not knowingly collect, solicit, or maintain personal or biometric information from children under the age of 13. If we learn that a child under 13 has submitted data to us without verified parental consent, we will delete that information immediately.

9. Contact Us

For privacy questions, exercising your data rights, or submitting revocation notices, contact our team at: erik@castortalent.ai

Talent Login Agency Login

2. Terms of Service

Effective Date: 4/5/2026 

1. Acceptance of Terms

By accessing or using the Castor Talent AI, Inc.  platform (castortalent.ai), you agree to be bound by these Terms of Service. If you do not agree, please refrain from using our platform.

2. User Accounts & Age Eligibility

You must be at least 18 years old (or represented by an authorized legal guardian or agency partner) to register a talent profile or license a digital twin. You are responsible for maintaining account security and ensuring all training data uploaded is legally owned or controlled by you.

3. Intellectual Property & Biometric Rights

Castor Talent AI, Inc.  does not claim ownership of your facial geometry, voice, or physical identity. By uploading training data, you grant Castor AI a specific, revocable license to manage, protect, and marketplace your digital twin under our proprietary Biometric Rights License (BRL) framework. You retain final control over usage categories and brand blocklists.

4. Prohibited Conduct

Users may not utilize Castor Talent AI, Inc. to generate non-consensual deepfakes, illegal or defamatory material, or content that infringes upon the intellectual property, privacy, or publicity rights of any third party. Scraping, reverse-engineering, or deploying automated bots against our platform is strictly prohibited.

5. Governing Law & Dispute Resolution

These Terms and any disputes arising from your use of the platform shall be governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict of law principles. Exclusive jurisdiction and venue for any legal proceedings shall lie in the state and federal courts located in Wyoming.

4. Contracts 

Manage Your Active Licenses Transparency is at the core of the Castor Talent AI, Inc. ecosystem. This secure portal is for active Talent and verified Agency partners to review their current Biometric Rights Licenses (BRLs), monitor active brand campaigns, and track incoming royalty streams.

Please log in to your dashboard to review your signed agreements, update your usage blocklists, or download your cryptographic chain-of-custody certificates.