Terms of Service

Persona Entertainment Oy

These Terms of Service (“Terms”) govern your access to and use of the Persona Entertainment Oy (“us”, “we”, “our”) service detailed in section 1 below (the “Service”), including our mobile applications (iOS and Android) and our web platform (collectively, the “Platforms”). By accessing or using the Service, you agree to comply with and be bound by these Terms.

1. Overview of the Service

The Service provides users access to AI-generated avatars of public figures (“talent”). Users may purchase virtual credits (“Connect Coins”) to unlock access for AI conversation packages with selected talent. Once purchased, access to AI conversation packages does not expire and remains available for as long as the Service exists, subject to Section 4.

Availability of specific avatars, talents, features, content, languages, and functionalities may change over time. We do not guarantee that any specific avatar, feature, or content will be available at all times. If we remove a talent from the Service following our standard notice period, you will retain access to any conversation package already purchased with that talent for as long as the Service exists, but new conversation packages with that talent can no longer be purchased.

If we remove a talent from the Service immediately — for example, due to the talent’s breach of contract, misconduct, legal issues, or other circumstances requiring urgent action — access to conversation packages with that talent will end immediately, and no refund or compensation will be provided for any unused Connect Coins or conversation packages associated with that talent.

2. Eligibility

You must be at least 13 years old (or higher minimum age as required in your country of residence) to use the Service. If you are under 18 years old, your parent or legal guardian must review and agree to these Terms and is responsible for your use of the Service, and you represent that you have permission from your parent or legal guardian to enter into these Terms. We may suspend or terminate accounts where we reasonably suspect a user does not meet these requirements.

3. User Accounts

To be able to use our Service, a user needs to create a user account. You agree to provide accurate, complete, and up-to-date information during the registration process and to update such information as necessary. You must not share your account or allow others to access it. You are responsible for maintaining the security and confidentiality of your account credentials and for all activity that occurs under your account, including any purchases. You must promptly notify us in writing of any suspected unauthorized access to your account.

4. Connect Coins Subscriptions and AI Conversation Packages

4.1 Connect Coins are the in-app currency used in the Service for purchasing AI conversation packages. Connect Coins packages may be purchased in the Service once the user has registered. Connect Coins are based on subscription packages which are automatically renewable for subsequent subscription periods unless terminated at the latest twenty-four (24) hours before the next renewal date. The user may change its Connect Coins package at any time during the subscription period and in this case, the old subscription will be cancelled and the new subscription starts from the purchase date.

4.2 If the user has a valid Connect Coins package subscription, the user may also purchase additional Connect Coins as a one-time purchase without an additional automatically renewable subscription.

4.3 Payments are processed through the App Store, Google Play, or our web payment processor Stripe via RevenueCat. Connect Coins have no monetary value, cannot be redeemed for cash and cannot be refunded (except where mandatory law requires otherwise), and cannot be transferred or gifted to another user under any circumstances. Connect Coins do not have an expiration date and can be used as long as the Service exists.

Access to AI avatar conversation features requires consent to AI data processing, which is requested during registration. If you withdraw this consent after purchasing Connect Coins or conversation packages, access to AI avatar features will be disabled and no refund or compensation will be provided for any unused Connect Coins or conversation packages.

4.4 Connect Coins may be used to purchase AI conversation packages with talents. The valid price of each package is available through the Service and is subject to change at our discretion.

Subscription-based AI conversation packages will automatically renew for subsequent 30-day periods unless terminated at the latest twenty-four (24) hours prior to the next renewal date and provided that the user has a sufficient amount of Connect Coins on their account. If the price of an automatically renewable AI conversation package changes, we will inform you at the latest twenty (20) days prior to the change taking effect, and you will have sufficient time to cancel the subscription prior to the new price taking effect. If the subscription is not cancelled, the new price will take effect.

AI conversation packages may also be purchased as a one-time purchase in addition to an active subscription. Unused conversation credits from a one-time purchase do not expire and remain available for use even if your subscription later expires or is terminated, and will not be refunded.

4.5 Nothing in these Terms limits any mandatory rights you may have under applicable consumer protection laws. If a refund is required by applicable law, it will be processed via the original payment method or via the applicable Platform’s refund process. If you made a purchase through the App Store or Google Play, your purchase and refund requests may be subject to that platform’s terms and processes.

5. AI Avatars and Content

5.1 AI avatars are digital personas created in cooperation with public figures. They do not represent real-time communication with those individuals. Interaction is done with artificial intelligence, not with real people. The individuals associated with these avatars are not communicating in real time and have no involvement in generating responses. The AI avatars simulate conversational behavior and may produce fictional or imaginative responses.

The Service is for entertainment purposes only and does not provide emotional support or companionship.

5.2 Generated content may not be used for commercial purposes or to imply endorsement by the user.

5.3 AI avatars may produce incorrect or unreliable output. AI-generated content may be inaccurate, incomplete, misleading, or inappropriate. All AI-generated output is provided on an “as is” basis without warranty, and users must evaluate content before relying on it. The Service Provider is not liable for damages resulting from reliance on AI-generated content. The Service does not provide medical, legal, financial, or other professional advice. Do not rely on AI-generated output for decisions that could cause harm. Do not use the Service for emergency purposes.

5.4 You must not use AI-generated content to impersonate any person, create deceptive media, spread misinformation, or cause harm to others. You are responsible for ensuring your use of AI-generated content is lawful and ethical.

5.5 All AI-generated content is labelled as such within the Service. You must not remove, obscure, or misrepresent these labels when sharing or distributing content.

6. Intellectual Property

All content, trademarks, software, and related materials in the Service are owned by or licensed to Persona Entertainment Oy. You are granted a limited, non-exclusive, non-transferable license to use the Service for personal, non-commercial purposes. Any feedback, suggestions, or ideas you provide regarding the Service (“Feedback”) will be our exclusive property. You hereby assign all rights in the Feedback to us and agree that we are free to use such Feedback without any compensation to you.

7. Prohibited Conduct

You agree not to:

• Copy, modify, distribute, sell, lease, reverse engineer, decompile, or attempt to extract source code except to the extent permitted by mandatory law.
• Interfere with or disrupt the Platforms, servers, networks, or security of the Service.
• Use the Service to impersonate, defame, harass, threaten, or abuse any individual.
• Circumvent payment systems or access paid features without authorization.
• Upload, generate, or request harmful, abusive, hateful or illegal content.
• Use bots, scrapers, automation tools, scripts, or other unauthorized means to access the Service or collect content from the Service.
• Bypass or circumvent any access controls, technical restrictions, content protections, security features, or geo-restrictions (where applicable).

You agree that you will not record, capture, screenshot, copy, download, stream, or otherwise reproduce any part of the Service, including but not limited to:

• AI-generated conversations
• AI avatars or talent likenesses
• Visual or audio content
• Any other proprietary material provided within the Service

You further agree not to publish, share, distribute, transmit, upload, or make available any such content to third parties on social media, messaging platforms, or any other channels, whether for free or for commercial purposes. This restriction applies to the maximum extent permitted by law. It does not restrict any rights you may have under mandatory law (for example, sharing information with competent authorities or as otherwise required by law).

We may monitor, review, remove, filter, or restrict access to content or prompts, and may suspend or terminate accounts, to enforce these Terms, comply with law, or protect users, talent, and the Service (including to prevent abuse, fraud, or safety risks). You are responsible for the content you submit (prompts, inputs, requests) and must ensure you have rights to submit it and that it complies with these Terms and applicable law. We may investigate suspected violations of these Terms and, where required or appropriate, we may cooperate with law enforcement, regulators, or other authorities, including by preserving or disclosing information as required by applicable law.

We may review conversations and interactions with AI avatars, including through automated systems and, where necessary, human review, to detect and address harassment, abuse, threats, or other conduct that violates these Terms. Where we identify such conduct, we may take action including warning, restricting, suspending, or terminating your account, without prior notice where necessary to protect the safety of users, talent, or the Service.

All content within the Service is protected by intellectual property laws and is licensed solely for personal, non-transferable use within the app. Unauthorized capturing or sharing of content constitutes a violation of these Terms and may result in suspension or termination of your account, and where applicable legal action.

Liquidated Damages – Unauthorized Recording and Distribution of Avatar Conversations

If the User records, captures, stores, distributes, publishes, broadcasts, or otherwise shares any conversation, interaction, or session involving the Service’s avatar features — whether in full or in part, in any format or medium — the User shall be liable to pay liquidated damages of €20,000 per individual incident of such unauthorized recording or distribution.

This clause applies to, but is not limited to:

• Screen recording or audio recording of avatar sessions
• Screenshots or visual captures shared with third parties
• Publishing or posting avatar conversation content on social media, websites, forums, or any public or semi-public platform
• Sharing recordings privately with third parties via messaging applications, email, or any other channel
• Re-uploading, re-streaming, or re-broadcasting avatar session content in any form

The liquidated damages reflect a genuine pre-estimate of the harm caused to the Service Provider, including but not limited to reputational damage, loss of competitive advantage, and breach of confidentiality. Payment of liquidated damages does not preclude the Service Provider from seeking additional compensation where actual damages exceed €20,000.

The prohibition on recording and distribution applies regardless of the User’s intent or purpose, and regardless of whether the recorded content is altered, edited, or presented in modified form. For the avoidance of doubt, this liquidated damages clause governs the User’s liability to the Service Provider and does not affect or limit the Service Provider’s liability to the User as set out in Section 11. The enforceability of this clause is subject to applicable mandatory consumer protection laws, and a court may reduce the amount if deemed disproportionate under applicable law.

8. Privacy

Your use of the Service is governed by our Privacy Policy, which details how we collect, process, and store your personal data. The up-to-date Privacy Policy is available here: personaavatar.com/pages/privacy. By using the Service, you acknowledge that you have read our Privacy Policy.

AI Feature Processing: When you use AI avatar generation features, images, voice recordings, or audio you provide are processed by AI systems solely to generate synthetic avatar content. This data is not used to identify you, build a facial recognition database, or train AI models on your personal data.

AI Processing: We use Unith Research Labs, S.L technology to generate AI avatar content. These providers act as our data processors and process only the data necessary for content generation.

We do not perform facial recognition, biometric identification, or biometric categorization. We do not compare your image against any database of faces.

9. Termination

We may modify, suspend, or discontinue the Service (in whole or in part) at any time, subject to applicable law. Where required by applicable law, we will provide notice. We may suspend or terminate access to the Service with or without notice if you violate these Terms. You may discontinue use of the Service at any time. If you want to discontinue the use of the Service, your Service will remain active until the end of your valid subscription. Upon termination, all licenses granted to you under these Terms will immediately terminate, and you must cease all use of the Service. Any accrued rights or obligations will survive termination, including those related to payment and intellectual property.

10. Disclaimers

The Service (including AI avatars and any AI-generated output) is provided on an “as is” and “as available” basis. To the maximum extent permitted by applicable law, we disclaim all warranties and conditions of any kind, whether express, implied, or statutory, including any implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement. We do not warrant that the Service will be error-free, uninterrupted, secure, or available at any particular time or location, or that defects will be corrected. You acknowledge that the Service may be affected by maintenance, updates, technical limitations, network or device issues, third-party services (including app stores, payment providers, and AI technology partners), and events beyond our reasonable control, and that content, features, and availability of specific talent or AI avatars may change over time. Nothing in these Terms excludes or limits any rights or remedies you may have under mandatory consumer protection laws.

The Service may contain links to third-party websites, advertisers, services, special offers, or other events or activities that are not owned or controlled by us. We do not endorse or assume any responsibility for any such third-party sites, information, materials, products, or services. If you access any third-party website, service, or content, you understand that these Terms and our Privacy Policy do not apply to your use of such sites.

11. Limitation of Liability

Nothing in these Terms limits liability that cannot be excluded under mandatory law. To the maximum extent permitted by law, we shall not be liable for indirect, incidental, or consequential damages. Our total aggregate liability arising out of or relating to the Service will not exceed the amounts you paid to us for the Service in the six (6) months preceding the event giving rise to the claim.

12. Governing Law

These Terms are governed by the laws of Finland, excluding its conflict-of-laws rules.

You have the right to bring claims in the courts of your place of residence.

If the dispute cannot be resolved through negotiations between the parties, you, as a consumer, have the right to refer the matter to the Consumer Disputes Board (kuluttajariita.fi) for resolution. Before taking the matter to the Consumer Disputes Board, you should contact Consumer Advisory Services, because otherwise the Consumer Disputes Board may decline to consider the case.

13. Changes to These Terms

We reserve the right to update these Terms at any time. If changes are material, we will provide reasonable notice (for example by in-app notice or email). Continued use of the Service after changes take effect constitutes acceptance of the updated Terms. If you do not agree to the updated Terms, you must stop using the Service and cancel any subscriptions.

For questions, contact: support@personaavatar.com