Disclaimer. This template is for use under attorney supervision. The General Counsel is the policy owner; do not modify the template language without GC approval. The Illinois Biometric Information Privacy Act (740 ILCS 14/15) requires that Form A be presented as a separate, written disclosure before biometric identifiers are collected — do not co-mingle Form A with Form B, the production-services agreement, or any other document. Form A and Form B are signed as separate signature events at the in-person capture session, after the Subject has had an opportunity to read each.
How to use this template. At the start of every Aurora in-person capture session, the production crew lead (i) verifies Subject identity against a government-issued photo ID and records the ID type and last-four; (ii) confirms Subject is at least eighteen (18) years old; (iii) presents Form A and obtains Subject’s acknowledgment as a stand-alone signature; (iv) presents Form B and obtains Subject’s signature, the Sponsor representative’s countersignature (where a Sponsor is involved), and the production-crew lead’s signature; (v) attaches any applicable State Supplements based on the capture-session location and the Subject’s residence; and (vi) for any Subject who is a political candidate, officeholder, campaign, committee, party, or PAC, attaches the Political-Use Addendum. Operational handling of biometric data, retention, and destruction is governed by the AI Acceptable Use Policy → Synthetic media of persons, the Records Retention Schedule, and the executed Subscription Agreement (where Sponsor is a Neuroscale Customer).

FORM A — NOTICE AND BIOMETRIC PRIVACY DISCLOSURE

This Notice is provided as a stand-alone written disclosure under the Illinois Biometric Information Privacy Act (740 ILCS 14/15(a)), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code §503.001), the Washington biometric law (RCW 19.375.020), and analogous state regimes. NEUROSCALE LLC (“Neuroscale”) operates the “Aurora” product, which generates AI-synthesized video, audio, and lip-synced media of an authenticated subject from in-person crew-captured source material. Aurora synthesizes only the authenticated subject and does not accept user-uploaded source material.

1. Biometric identifiers Neuroscale will collect

In connection with the capture session identified in Form B, Neuroscale will collect, generate, store, and process the following biometric identifiers (each, a “Biometric Identifier”) about you:
  • Face geometry — landmark coordinates, three-dimensional surface representations, and analogous geometric feature vectors derived from the video frames captured during the session.
  • Voice prints — acoustic feature vectors, spectral representations, and analogous identifiers derived from the audio captured during the session.
  • Captured source material — the raw video and audio recordings of the session from which the Biometric Identifiers are derived.

2. Purpose of collection

Neuroscale will collect and process the Biometric Identifiers solely for the following purposes (the “Permitted Purposes”):
  • to produce AI-synthesized video, audio, and lip-synced media depicting you (each, an “Aurora Output”);
  • to deliver Aurora Outputs to you and, where applicable, to the Sponsor identified in Form B under the terms of Sponsor’s subscription with Neuroscale;
  • to operate, secure, and improve Aurora, including abuse-pattern detection, takedown workflow operation, and model-output quality evaluation;
  • to comply with applicable law, court order, subpoena, or other lawful process; and
  • to defend against any claim, audit, or regulatory inquiry concerning Aurora.

3. Retention period

Neuroscale will retain the Biometric Identifiers and the captured source material for the shorter of (i) the period necessary to satisfy the Permitted Purposes, or (ii) three (3) years from your last interaction with Neuroscale, unless extended by your separate written consent or by an active legal hold. Aurora Outputs already produced and distributed are retained as set out in Form B §3.

4. Destruction

On the earliest of (i) expiration of the retention period in §3, (ii) the Permitted Purposes being satisfied, or (iii) your written request to destroy under Form B §6.1, Neuroscale will destroy the captured source material, the Biometric Identifiers, and any model state derived solely from your captured data, in accordance with Neuroscale’s Records Disposal Procedure, subject to applicable legal-hold and recordkeeping requirements.

5. Sale, lease, trade, and disclosure

Neuroscale will not sell, lease, trade, or otherwise profit from the Biometric Identifiers. Neuroscale will not disclose the Biometric Identifiers to any third party except: (a) under your separate written consent; (b) to a service provider acting on Neuroscale’s behalf under a written contract that materially preserves the protections of this Notice and prohibits secondary use; (c) to comply with a court order, subpoena, or other lawful process; or (d) as expressly authorized by you in Form B.

6. Acknowledgment of receipt

I, the undersigned Subject, acknowledge that I have received and read this Notice and Biometric Privacy Disclosure (Form A) before any Biometric Identifiers about me were collected by Neuroscale. Subject. Signature: _______________________________ Printed Name: {{subject_name}} Title: {{subject_title}} Date: ___________________________________

FORM B — AURORA CAPTURE, CONSENT & RELEASE

This Form B is executed at the in-person capture session after Form A has been delivered and acknowledged.

1. Subject identification and 18+ attestation

a. Subject. Subject name: {{subject_name}}. Subject date of birth: {{subject_dob}}. b. 18+ attestation. Subject represents and warrants that Subject is at least eighteen (18) years of age as of the date Subject signs this Form B. The Aurora product excludes individuals under 18 from capture and synthesis. c. Identity verification. Government-issued photo ID type: {{id_type}}. ID number — last four digits: {{id_last_four}}. The production-crew lead identified in §1(e) confirms that Subject’s appearance materially matches the ID photograph. d. Sponsor (if any). Sponsor name: {{sponsor_name}}. Sponsor’s Neuroscale Customer account: {{sponsor_account}}. If “None” is entered, Subject is acting in Subject’s individual capacity and Sponsor-specific provisions of this Form B do not apply. e. Capture session. Date: {{capture_date}}. Location (street address, city, state): {{capture_location}}. Production-crew lead (Neuroscale or authorized vendor): {{crew_lead_name}}, {{crew_lead_title}}, {{crew_lead_employer}}.

2. Service description

Aurora is a Neuroscale product that generates AI-synthesized video, audio, and lip-synced media (each, an “Aurora Output”) depicting the authenticated Subject from the in-person crew-captured source material recorded at the capture session identified in §1(e). Aurora synthesizes only the authenticated Subject; Aurora does not accept user-uploaded video, audio, or photographs as source material; Aurora does not produce media depicting any individual other than the authenticated Subject.

3. Grant of rights

a. Capture grant. Subject authorizes Neuroscale, through the production crew identified in §1(e), to record video and audio of Subject during the capture session. b. Biometric-data grant. Subject authorizes Neuroscale to derive, store, and process Biometric Identifiers (as defined in Form A §1) from the captured material, solely for the Permitted Purposes set out in Form A §2. c. Synthesis grant. Subject authorizes Neuroscale to use the captured material and the Biometric Identifiers to produce Aurora Outputs and to deliver Aurora Outputs to Subject and, where applicable, to Sponsor under the terms of Sponsor’s executed subscription agreement with Neuroscale. d. Right-of-publicity grant. Subject grants Sponsor (where applicable) and Neuroscale a non-exclusive, worldwide, royalty-free license to use Subject’s name, image, likeness, voice, and persona as embodied in Aurora Outputs, solely for the purposes of producing, distributing, hosting, displaying, and making available Aurora Outputs. This license is non-transferable except to Neuroscale’s affiliates, successors, and contractors acting on its behalf and under written confidentiality. This license is subject to Subject’s revocation rights in §6.2. e. Retention of underlying rights. Subject retains all right, title, and interest in Subject’s name, image, likeness, and voice except for the limited licenses expressly granted in this Form B.

4. Subject acknowledgments

a. AI-generated label and provenance. Subject acknowledges that every Aurora Output will carry a persistent, visible AI-generated label at the point of display and, on file export where supported, an embedded C2PA-style cryptographic provenance manifest. The labeling and provenance regime implements California Senate Bill 942 (Bus. & Prof. Code §§22757–22757.4, effective Jan 1, 2026), the Utah AI Policy Act (Utah Code §§13-72-101 et seq.), and EU AI Act Article 50(4), and may not be removed, modified, obscured, or stripped from any Aurora Output Subject distributes. b. Prohibited uses. Subject will not use, and will not authorize any third party to use, any Aurora Output to depict: (i) an opposing candidate, election official, or any non-consenting third party in deceptive speech or conduct; (ii) false voting-logistics content (time, place, manner, or eligibility), regardless of whether a third-party likeness is used; (iii) content that misrepresents the Aurora Output as personally recorded or produced by Subject when in fact AI-personalized; (iv) non-consensual intimate imagery covered by state non-consensual-intimate-imagery laws and the federal DEFIANCE Act framework; (v) fraud, identity theft, or impersonation; (vi) synthesis of minors; or (vii) any other unlawful purpose. The conduct prohibitions in this §4(b) are coextensive with, and incorporate by reference, the prohibited-use clauses of the AI Acceptable Use Policy → Synthetic media of persons and Section 8.9(d) of the Terms of Service. c. No misrepresentation of personal recording. Subject acknowledges that Aurora Outputs are AI-synthesized from the single capture session identified in §1(e). Subject will not represent any Aurora Output as personally recorded or produced by Subject for any specific recipient unless an individualized recording session in fact occurred for that recipient. d. Aurora’s takedown rights. Subject acknowledges that Neuroscale operates rate limiting on Aurora generation, abuse-pattern detection, and a published takedown workflow at security@neuroscale.ai and abuse@neuroscale.ai. Neuroscale may suspend or revoke Subject’s Aurora access, withdraw distributed Aurora Outputs (to the extent within Neuroscale’s technical control), and notify Sponsor where a substantiated report of violation is received.

5. Compliance acknowledgments

Subject and Sponsor acknowledge that this Form B and Form A are intended to satisfy, and shall be construed to satisfy, the following regimes:
  • Illinois Biometric Information Privacy Act, 740 ILCS 14/15(a)–(b), 15(c), and 15(d), as supplemented by the Illinois State Supplement below;
  • Texas Capture or Use of Biometric Identifier Act, Tex. Bus. & Com. Code §503.001, as supplemented by the Texas State Supplement below;
  • Washington biometric law, RCW 19.375, as supplemented by the Washington State Supplement below;
  • Tennessee Ensuring Likeness, Voice, and Image Security Act, Tenn. Code Ann. §§47-25-1101 et seq. (the “ELVIS Act”), as supplemented by the Tennessee State Supplement below;
  • California Civil Code §3344 (right of publicity), and California Labor Code §927 / Assembly Bill 2602 (digital-replica written-notice requirements), as supplemented by the California State Supplement below;
  • New York Civil Rights Law §§50, 51, and 50-f, as supplemented by the New York State Supplement below;
  • EU AI Act Article 50(4) (deep-fake disclosure obligation for end-users in the EU); and
  • Analogous state and non-US biometric-privacy and digital-replica regimes that apply to Subject’s residence or the capture-session location.

6. Subject rights

a. Right to delete. Subject may at any time request deletion of the captured source material, the Biometric Identifiers, and any model state derived solely from Subject’s captured data, by written notice to privacy@neuroscale.ai with the subject line “Aurora — Deletion Request”. Neuroscale will execute the deletion within thirty (30) days, subject to any active legal hold and to Neuroscale’s recordkeeping obligations. b. Right to revoke. Subject may revoke this Form B prospectively at any time by written notice to privacy@neuroscale.ai with the subject line “Aurora — Revocation”. Revocation halts future production of Aurora Outputs from Subject’s Biometric Identifiers. Revocation does not require Neuroscale to retract Aurora Outputs already distributed before the effective date of revocation, except where applicable law (including the ELVIS Act, AB 2602, or successor digital-replica laws) requires retraction. c. Right to inquire. Subject may request the categories of data Neuroscale holds about Subject in connection with Aurora and the recipients to which Aurora Outputs have been delivered, by written notice to privacy@neuroscale.ai. d. No retaliation. Where Subject is an employee, contractor, or candidate of Sponsor, Sponsor represents that Sponsor will not retaliate against Subject for declining to enter into this Form B, for revoking under §6(b), or for exercising any right under this §6.

7. Sponsor representations (where applicable)

By countersigning below, Sponsor represents and warrants, as a continuing representation that survives any termination of this Form B with respect to Aurora Outputs already produced: a. Sponsor’s use of Aurora and Aurora Outputs is governed by Sponsor’s executed Master Subscription Agreement and Terms of Service with Neuroscale, including Section 8.9. b. Where Sponsor is a political candidate, officeholder, campaign, committee, party, or PAC, or otherwise produces Aurora Outputs for an election-related public communication, the Political-Use Addendum to this Form B is attached, executed, and incorporated by reference. c. Sponsor will not request or direct Neuroscale to produce any Aurora Output that would violate this Form B or the Terms of Service.

8. General

a. Governing law. This Form B is governed by the laws of the Commonwealth of Virginia, without regard to its conflicts-of-laws principles, except that the state-supplemental provisions below are governed by the respective state’s law. b. Independent counsel. Subject has had the opportunity to consult independent counsel before signing. c. Entire agreement. This Form B, together with Form A, the applicable State Supplements, and (where applicable) the Political-Use Addendum and Sponsor’s executed Subscription Agreement, constitutes the entire agreement between the parties with respect to the capture session identified in §1(e) and supersedes any prior understanding regarding that capture session. d. Counterparts; electronic signatures. This Form B may be executed in counterparts, and electronic signatures (including signatures captured through DocuSign or analogous platforms) have the same legal effect as ink signatures.

9. Signatures

Subject. Signature: _______________________________ Printed Name: {{subject_name}} Title: {{subject_title}} Date: ___________________________________ Sponsor representative (if applicable). Signature: _______________________________ Printed Name: {{sponsor_rep_name}} Title: {{sponsor_rep_title}} Date: ___________________________________ Neuroscale production-crew lead. Signature: _______________________________ Printed Name: {{crew_lead_name}} Title: {{crew_lead_title}} Employer: {{crew_lead_employer}} Date: ___________________________________

STATE SUPPLEMENTS

Each State Supplement is attached and executed where the capture-session location, Subject’s residence, or the anticipated distribution surface of Aurora Outputs implicates that state’s law.

Illinois Supplement — Biometric Information Privacy Act (740 ILCS 14)

a. Specific written informed consent. Subject’s signature on Form A and Form B constitutes Subject’s specific written informed consent under 740 ILCS 14/15(b)(3) to the capture, storage, and use of Subject’s Biometric Identifiers for the Permitted Purposes set out in Form A §2. b. Written policy and retention schedule. Form A §3 and §4 constitute Neuroscale’s written retention schedule and destruction guidelines required by 740 ILCS 14/15(a). The retention period does not exceed the earlier of (i) the date the Permitted Purposes have been satisfied or (ii) three years from Subject’s last interaction with Neuroscale. c. No sale of Biometric Identifiers. Neuroscale will not sell, lease, trade, or otherwise profit from Subject’s Biometric Identifiers, consistent with 740 ILCS 14/15(c). d. Subject acknowledgment. Subject acknowledges that the foregoing provisions and the destruction protocol in Form A §4 satisfy 740 ILCS 14/15(a)–(d) with respect to the Biometric Identifiers collected in the capture session identified in Form B §1(e).

Texas Supplement — Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code §503.001)

a. Informed consent. Subject’s signature on Form A and Form B constitutes informed consent under §503.001(b)(1) to the capture of Subject’s biometric identifiers for a commercial purpose. b. No sale. Neuroscale will not sell, lease, or otherwise disclose Subject’s biometric identifiers except as expressly permitted by §503.001(c) and consistent with Form A §5. c. Destruction. Subject’s biometric identifiers will be destroyed within a reasonable time (and in no event later than the period set out in Form A §3) consistent with §503.001(c-1).

Washington Supplement — RCW 19.375

a. Notice and consent. Subject’s signature on Form A and Form B constitutes notice and consent to Neuroscale’s enrollment of Subject’s biometric identifier in a database under RCW 19.375.020(1), for the Permitted Purposes set out in Form A §2. b. Commercial purpose. Subject acknowledges that the use of Aurora Outputs is a commercial purpose within the meaning of RCW 19.375. c. No sale or disclosure. Neuroscale will not sell, lease, or otherwise disclose Subject’s biometric identifiers in a manner inconsistent with RCW 19.375.020(3)–(4) or with Form A §5.

Tennessee Supplement — Ensuring Likeness, Voice, and Image Security Act (Tenn. Code Ann. §§47-25-1101 et seq.)

a. Express consent to use of voice and likeness. Subject expressly authorizes Neuroscale and Sponsor (where applicable) to use Subject’s voice and likeness, including in AI-generated form, for the Permitted Purposes set out in Form A §2 and the synthesis grant in Form B §3, consistent with Tenn. Code Ann. §47-25-1107. b. Statutory recognition. Subject acknowledges that Tenn. Code Ann. §47-25-1102 creates a property right in voice and likeness, and that the consent granted under this Tennessee Supplement is the form of consent contemplated by §47-25-1107 to authorize the otherwise-prohibited conduct. c. Term. This Tennessee Supplement remains in effect until revoked by Subject under Form B §6(b), subject to the post-revocation carve-out in that section.

California Supplement — Civil Code §3344; Labor Code §927 / AB 2602

a. Right-of-publicity consent. Subject’s signature on Form B constitutes prior written consent under California Civil Code §3344(a) to Neuroscale’s and Sponsor’s use of Subject’s name, voice, signature, photograph, or likeness, including in AI-generated form, for the Permitted Purposes. b. AB 2602 written notice (where applicable). Where the use of Aurora Outputs falls within the scope of California Labor Code §927 / AB 2602 (digital replicas of an individual in audiovisual works produced or distributed in California in employment-related contexts), Subject acknowledges that Form B §2 (“Service description”), §3 (“Grant of rights”), and §4(a) (“AI-generated label and provenance”) collectively constitute the required written description of the intended use of the digital replica and Subject’s specific consent thereto, and Subject confirms an opportunity to consult independent counsel as set out in Form B §8(b). c. California Consumer Privacy Act. Where Subject is a California resident, this California Supplement also serves as a written notice for purposes of Cal. Civ. Code §1798.100(b) regarding Neuroscale’s collection and use of Subject’s biometric information; categories of information collected are set out in Form A §1, and purposes are set out in Form A §2.

New York Supplement — Civil Rights Law §§50, 51, and 50-f

a. Written consent under §§50 and 51. Subject’s signature on Form B constitutes the written consent contemplated by New York Civil Rights Law §§50 and 51 to Neuroscale’s and Sponsor’s use of Subject’s name, portrait, picture, or voice, including in AI-generated form, for the Permitted Purposes. b. §50-f digital-replica acknowledgment. Subject acknowledges that New York Civil Rights Law §50-f addresses the rights of deceased performers’ digital replicas, and Subject’s signature on this New York Supplement constitutes the express, written agreement contemplated by §50-f to the extent applicable to any post-mortem use of Aurora Outputs incorporating Subject’s likeness. Subject may further specify post-mortem rights and limitations through Subject’s estate-planning instruments.

OPTIONAL ADDENDUM — POLITICAL USE

This Addendum is attached and executed where Subject is a political candidate, officeholder, campaign, committee, party, or PAC, or where Aurora Outputs will be used in an election-related public communication. Where Sponsor is a Neuroscale Customer, Sponsor countersigns this Addendum in addition to Form B §7.

A. Political-Use representations

Subject and Sponsor jointly represent and warrant that: a. TCPA prior express consent. Before delivering any Aurora Output via robocall, autodialed call, pre-recorded voice, or SMS, Subject and Sponsor will obtain prior express consent of each recipient consistent with 47 U.S.C. §227(b)(1) and the FCC’s February 8, 2024 Declaratory Ruling (FCC 24-17), which confirmed that the TCPA’s “artificial or prerecorded voice” prohibition reaches AI voice-cloning and AI-generated voice regardless of source product, including for political, charitable, informational, and transactional purposes. b. FEC disclaimers. Where Subject or Sponsor is a federal candidate or federal committee, all Aurora Outputs distributed as “public communications” will include the disclaimers required by 52 U.S.C. §30120 and 11 C.F.R. §110.11, in addition to the AI-generated label and C2PA provenance manifest implemented by Aurora. c. State political-disclosure compliance. Subject and Sponsor will comply with all applicable state political-disclosure regimes, including placement, on-screen duration, and committee-attribution requirements, under New York Election Law §14-106, Florida Statutes §106.145, California Assembly Bill 2355, and analogous AI-in-elections disclosure statutes in Michigan, Arizona, and other states. Aurora’s default labeling does not relieve Subject or Sponsor of state-specific placement and content requirements. d. EU AI Act Article 50(4). For any Aurora Output delivered to a recipient in the EU, Subject and Sponsor will comply with the disclosure obligation in EU AI Act Article 50(4). e. Conduct prohibitions. Subject and Sponsor will not use any Aurora Output (i) to depict an opposing candidate, election official, or non-consenting third party; (ii) for false voting-logistics content (time, place, manner, or eligibility); (iii) to misrepresent the Aurora Output as personally recorded by Subject for a specific recipient when no such individualized recording occurred; or (iv) in violation of 52 U.S.C. §30124 (fraudulent misrepresentation of campaign authority) or any analogous state law.

B. Independence and survival

The obligations of Subject and Sponsor under this Political-Use Addendum are independent of, and additional to, Aurora’s labeling and provenance defaults. The obligations survive any expiration, termination, or revocation of Form B with respect to Aurora Outputs already distributed.

C. Signatures

Subject (political). Signature: _______________________________ Printed Name: {{subject_name}} Title: {{subject_title}} Office sought or held (if any): {{subject_office}} Date: ___________________________________ Sponsor representative (campaign / committee). Signature: _______________________________ Printed Name: {{sponsor_rep_name}} Title: {{sponsor_rep_title}} FEC committee identifier (if any): {{fec_committee_id}} Date: ___________________________________

Variables

Mustache-style placeholders are filled at execution by the production-crew lead from the Aurora capture-session record. The canonical variable list:
VariableDescription
{{subject_name}}Subject’s legal name, as it appears on the government-issued photo ID
{{subject_title}}Subject’s title or capacity in which Subject signs
{{subject_dob}}Subject’s date of birth
{{id_type}}Government-issued photo ID type (e.g., U.S. Passport, state Driver’s License)
{{id_last_four}}Last four characters of the ID number
{{sponsor_name}}Sponsor’s legal name; “None” if Subject is acting in individual capacity
{{sponsor_account}}Sponsor’s Neuroscale Customer account identifier
{{sponsor_rep_name}}Sponsor representative’s legal name
{{sponsor_rep_title}}Sponsor representative’s title
{{capture_date}}Date of the capture session
{{capture_location}}Capture-session location (street address, city, state)
{{crew_lead_name}}Production-crew lead’s legal name
{{crew_lead_title}}Production-crew lead’s title
{{crew_lead_employer}}Production-crew lead’s employer (Neuroscale or authorized vendor)
{{subject_office}}Subject’s office sought or held (Political-Use Addendum only)
{{fec_committee_id}}FEC committee identifier (Political-Use Addendum only)

Cross-references

Version history

VersionDateDescriptionAuthorApproved by
1.02026-05-14Initial version. Multi-part consent and release executed at the Aurora in-person capture session; Form A (Notice and Biometric Privacy Disclosure), Form B (Capture, Consent & Release), State Supplements (IL, TX, WA, TN, CA, NY), Optional Political-Use Addendum.Cameron WolfeIshan Jadhwani