PERSONLIS — Version 2.0 — 15 September 2026
While alive, you can decide what to ask PERSONLIS to do with your avatar after your death. Your instructions are considered alongside statutory rights and the checks described here. A family relationship alone does not automatically transfer control of the account.
The avatar is an AI-generated simulation: it is not the person depicted, does not possess their thoughts and its responses are not new expressions of that person’s wishes. See the AI Notice.
Communicate your choice between deletion and retention in writing to legal@personlis.com. Include your full name, account email, choice and, if requesting retention, the people you authorise and the instructions you wish to leave. Do not send passwords.
The Provider reviews the communication, verifies that it comes from the person concerned and may request necessary clarification or evidence before acknowledging that it has been taken in hand. Keep the communication and reply. If you receive no response, contact legal@personlis.com again.
The designated-person list in your personal space records people and instructions; by itself it does not replace an explicit choice between retention and deletion communicated to the Provider.
If you choose deletion, after verifying the death and applicable instructions the Provider initiates account closure and removal of materials. Necessary checks, legitimate requests, retention obligations and any authority orders remain applicable.
If you choose retention, you may identify who is authorised to use the avatar and what instructions they must follow. Retention and use remain subject to the Terms, plan conditions, consents and applicable rights. They are not a promise of perpetual availability or indefinite free use.
Your choice about your account does not give you authority to dispose of other people’s faces, voices or data within the materials without the necessary entitlement.
Within plan limits, you can add and update designated people in the personal archive area. Available fields include first name, surname, date of birth, relationship, email, phone, use instructions and a note. Inform people before sharing their data.
Access uses the email and password you directly entrust to the designated person. Designation does not create separate accounts and no automatic invitation after death is provided. Anyone signing in uses the same account’s features: the stated permissions are instructions to follow, not separate technical access arrangements.
Designated people must be at least 18, know your instructions and follow them and the Terms. Designation does not transfer account ownership or your personal consents and does not remove the Provider’s need to verify requests after death.
You can change or revoke the directive by emailing legal@personlis.com and clearly identifying what you replace or revoke. The Provider verifies the communication and considers the most recent instructions whose origin and validity are established. If instructions conflict or are unclear, it requests clarification before acting.
You can edit or remove names in your personal space. If a change affects a directive already communicated, update it by email too. Removing a name does not change the password already entrusted to that person: if you revoke authorisation, change shared credentials and contact support if needed.
Anyone reporting a death or requesting deceased-person data should email legal@personlis.com, identifying the account and reason for the request. The Provider handles the case manually and specifies the necessary evidence, such as a document concerning the death and information establishing the requester’s identity and entitlement. Do not send identity documents or death certificates before they are requested for the specific case.
A report alone does not trigger account transfer or deletion. The Provider may suspend the avatar during verification. After checking the death, instructions, identity and applicable rights, it decides on the resulting measures. Possessing credentials does not replace verification of entitlement for a request made to the Provider.
Following verified notice of death, where no directive exists, the Provider suspends the avatar and subsequently initiates deletion after necessary checks, subject to legitimate requests and legal obligations. There is no fixed twelve-month waiting period.
Control does not pass automatically to relatives. People who believe they have an entitlement can contact legal@personlis.com: the case is assessed under the law, without treating a right to obtain particular data as a general right to use the avatar.
GDPR Recital 27 leaves Member States scope to set their own rules for deceased-person data. In Italy, Article 2-terdecies of the Privacy Code permits the rights specified there to be exercised by people with their own interest, those protecting the person as their representative, or those with family reasons deserving protection.
For information society services, where legally permitted, you may prohibit exercise of some or all of those rights in writing to the data controller. The prohibition must be unambiguous, specific, freely given and informed, and can be changed or revoked. Under paragraph 5 it cannot prejudice third parties’ property rights arising from the death or their right to defend their interests in court.
Choosing deletion or retention and imposing this prohibition are separate matters. To communicate a prohibition, email legal@personlis.com specifying the rights concerned: it does not arise automatically from designation or a deletion choice. Reference: Article 2-terdecies, Privacy Code published by the Italian data protection authority.
When account deletion is initiated, section 15 of the Terms and the Privacy Notice apply: system cleanup, technical processing time and any manual action to complete removal of residual data within 60 days of deletion, except necessary retention for legal obligations or disputes. Recovery of an account or content already removed is not guaranteed.
Conversations and materials may contain living people’s data: their protections continue to apply. A designated person may stop using the avatar; that decision does not automatically entitle them to have everything deleted for everyone else. Deletion requests are assessed against valid instructions, the requester’s entitlement and the law.
For directives, changes, revocations, death reports and data requests: legal@personlis.com. For help using the service: help@personlis.com.
Nobody is obliged to talk to an avatar. You can end a conversation at any time. PERSONLIS is not psychological support or an emergency service.
Provider and data controller: LAPOFEIMH DI PEGNA FABIO LUIGI, Via Castellaro 25, 47843 Misano Adriatico (RN), Italy — VAT No. 04776290407.