Biometric Policy
Last updated: April 24, 2026
This Biometric Policy supplements our Privacy Policy and describes how Luel Inc. (“Luel,” “we,” “our,” or “us”) collects, uses, stores, and disposes of biometric identifiers and biometric information derived from content you submit and from short voice samples used to verify your identity during a recording session.
Biometric identifiers include face geometry and voice characteristics (voiceprints). These identifiers are subject to specific legal protections in Illinois (BIPA), Texas (CUBI), Washington, and other jurisdictions.
When you submit video or audio content to the Luel marketplace, that content may contain your face geometry and/or voice characteristics. We obtain your explicit, written consent at sign-up and again at the point of each submission before collecting or processing any biometric identifiers.
Purpose of Collection
- Automated quality assurance and content validation
- Deduplication and fraud prevention through content hashing
- Making the content available to AI-company buyers for training purposes, to the extent your content is licensed to a buyer
Retention & Destruction
Biometric identifiers embedded in submitted content are retained no longer than three (3) years after your last interaction with Luel, or until the initial purpose has been satisfied, whichever occurs first. After that point, we delete the identifiers or irreversibly de-identify them.
Important: Once content is licensed and transferred to an AI-company buyer, that buyer becomes an independent controller of the content. We cannot recall biometric identifiers from their systems or from models already trained on the content.
To confirm that the person recording a submission is the same person who set up the Luel account, we ask contributors to read a short phrase before each recording session. From that short phrase we derive a numerical voice embedding (a “voiceprint”) and use it to verify your identity against your own prior recordings.
Strict Limits
- Never sold to buyers or third parties
- Never shared with AI companies as part of training data
- Cannot be used to reconstruct or synthesize your voice — embeddings are one-way and lossy
- Used only to match you against yourself within Luel
Retention & Destruction
Session voiceprints are retained for at most one (1) hour after capture and are deleted earlier if (a) an identity mismatch is detected, or (b) you record a new voiceprint that supersedes the prior one. This window is intentionally short so the data exists only for as long as is needed for the immediate session.
Before collecting biometric identifiers from you, Luel: (1) informs you in writing that biometric identifiers are being collected; (2) informs you in writing of the specific purpose and length of time for which biometric identifiers are collected, stored, and used; and (3) obtains your written release.
Luel does not sell, lease, trade, or otherwise profit from your biometric identifiers or biometric information, except as part of the licensed marketplace transaction you have specifically consented to in connection with your submitted content.
We disclose biometric identifiers only: (a) to service providers operating on our behalf under written data-processing agreements; (b) to AI-company buyers to whom your content is licensed, to the extent the identifiers are embedded in that content; (c) where required by subpoena, warrant, or other legal process; or (d) with your separate consent.
Your Rights
Subject to applicable law, you may:
- Request confirmation of whether we process your biometric identifiers
- Request deletion of your biometric identifiers still under our control
- Withdraw consent to future collection (note: withdrawal does not affect prior lawful processing, and cannot recover identifiers already transferred to AI-company buyers)
Biometric identifiers are stored with reasonable security measures designed to protect them from unauthorized access, use, or disclosure. Specifically: TLS encryption for data in transit, encryption at rest, access controls and least-privilege principles, and multi-factor authentication for administrative access.
Questions, concerns, or requests in connection with this Biometric Policy can be sent to privacy@luel.ai.