GDPR & Biometric Data Addendum

This Schedule forms part of the Author, Avatar & Publishing Agreement and incorporates the Illinois Biometric Information Notice and the User Privacy Policy – Avatar & Biometric Addendum.

Part 1 – Illinois Biometric Information Notice

1. What This Notice Covers

LearningFrontier.AI (“LearningFrontier”, “we”, “us”) uses artificial intelligence to create interactive avatars of authors.

This process may involve the collection and use of biometric identifiers and biometric information, including:

• Facial geometry derived from images or video
• Voiceprints derived from audio recordings

2. Purpose of Collection

Biometric data is collected and used solely for the following purposes:

• Creating and operating an AI-based avatar representing an author
• Enabling text, voice, and face-to-face AI interactions on the LearningFrontier platform
• Maintaining the quality, safety, and consistency of the avatar experience

Biometric data is not used for advertising, profiling unrelated to the platform, or training general-purpose AI models.

3. Consent

Biometric data is collected only with the prior written consent of the individual concerned.

For authors, consent is provided through execution of the LearningFrontier Author, Avatar & Publishing Agreement and this GDPR & Biometric Data Addendum.

4. Retention and Destruction Policy

LearningFrontier retains biometric data only for as long as necessary to fulfil the purposes described above. Specifically:

• Biometric data is retained while the relevant author avatar is active on the platform
• Upon termination of the author relationship, biometric data is deactivated immediately
• All biometric data is permanently deleted no later than twelve (12) months after termination, unless earlier deletion is requested or retention is required by law

5. No Sale or Disclosure

LearningFrontier does not:

• Sell biometric data
• Lease or trade biometric data
• Disclose biometric data to third parties except to vetted service providers acting strictly on our instructions

6. Safeguards

LearningFrontier uses reasonable technical and organisational measures to protect biometric data against unauthorised access, disclosure, or loss.

7. Questions and Requests

Questions about this notice or requests relating to biometric data may be directed to: privacy@leanfrontier.ai

Part 2 – User Privacy Policy: Avatar & Biometric Addendum

AI Avatars, Voice, and Face Interactions

LearningFrontier.AI offers AI-based interactions that may include text, voice, and face-to-face conversations with simulated author avatars.

Nature of AI Avatars

AI avatars on LearningFrontier:

• Are artificial simulations
• Are not the real author
• Do not provide personal opinions or professional advice

Voice and face interactions are synthetic representations generated by AI systems.

Personal and Biometric Data

To provide these features, LearningFrontier may process:

• Audio data (voice recordings and derived voice models)
• Image or video data (facial representations)
• Interaction metadata generated during use of the platform

Where applicable, facial and voice data may be considered biometric or sensitive personal information under data protection laws.

Purpose of Processing

This data is processed solely to:

• Enable AI-based avatar interactions
• Ensure safety, quality, and consistency of the experience
• Maintain and improve platform functionality

LearningFrontier does not use this data to:

• Train general-purpose AI models
• Advertise or market unrelated products
• Sell or share data as defined under the California Consumer Privacy Act (CCPA)

Legal Basis and User Rights

Depending on your location, processing is based on:

• Consent
• Performance of a contract
• Legitimate interests in operating the platform

Users may have rights to:

• Access their personal data
• Request deletion
• Limit or object to certain processing

Requests can be submitted to: privacy@leanfrontier.ai

Service Providers

LearningFrontier may use trusted service providers to support AI, cloud infrastructure, and security. These providers:

• Act solely on LearningFrontier’s instructions
• Are contractually prohibited from using data for their own purposes

No Sale or Sharing of Sensitive Data

LearningFrontier does not sell or share biometric or sensitive personal information within the meaning of CCPA or CPRA.

Retention

Data is retained only for as long as necessary to provide the service and is deleted or anonymised when no longer required.