Scope & Applicability
This Policy applies to all officers, directors, employees, independent contractors, consultants, agents, representatives, creators, brand partners, vendors, and any third party (collectively, “Covered Persons”) who create, commission, distribute, publish, or otherwise disseminate content through, in connection with, or facilitated by the Orno platform that incorporates, in whole or in part, AI-generated or synthetic media as defined herein. This Policy governs all content formats, including but not limited to video, audio, images, text, interactive media, livestream overlays, virtual avatars, voice clones, and any other medium now known or hereafter developed.
This Policy operates in conjunction with, and does not supersede, the FTC Compliance & Disclosures Policy, the Terms of Service, the Master Services Agreement, and all other binding policies of Orno. To the extent of any conflict, the more restrictive standard shall govern. Compliance with this Policy does not relieve Covered Persons of obligations under applicable law, including but not limited to consumer-protection statutes, right-of-publicity laws, defamation laws, and intellectual-property rights of third parties.
Defined Terms
“Artificial Intelligence” or “AI”
means a machine-based system that, for explicit or implicit objectives, infers from the input it receives how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments, as defined in Article 3(1) of Regulation (EU) 2024/1689.
“Generative AI”
means any AI system designed to generate text, images, audio, video, code, or other content based on user prompts, including but not limited to large language models (LLMs), diffusion models, generative adversarial networks (GANs), variational autoencoders (VAEs), and neural radiance fields (NeRFs).
“Synthetic Media”
means any image, audio, video, or text content that has been wholly or substantially generated or materially altered through the use of AI or machine-learning techniques, such that a reasonable person would perceive the output as depicting real events, persons, or statements that did not actually occur or were not actually made.
“Deepfake”
means AI-generated or AI-manipulated audio, video, or image content that realistically depicts a person’s likeness, voice, or actions in a manner that would falsely appear to a reasonable viewer or listener to be authentic, including face-swaps, voice clones, lip-sync manipulations, and full-body generation.
“Training Data”
means any data, content, images, audio, video, text, or other materials used to train, fine-tune, reinforce, or otherwise develop an AI or machine-learning model, including datasets used for pre-training, supervised fine-tuning, reinforcement learning from human feedback (RLHF), and retrieval-augmented generation (RAG).
“C2PA”
means the Coalition for Content Provenance and Authenticity standard (ISO/IEC 24036, formerly C2PA specification) for embedding cryptographically signed provenance metadata in digital content, enabling verification of content origin, creation method, and modification history.
“Provenance”
means verifiable metadata documenting the origin, creation method, modification history, and authenticity of digital content, including but not limited to C2PA manifests, watermarks, fingerprints, and blockchain-based attestations.
Permitted Uses
Subject to the disclosure, labeling, and consent requirements set forth in Sections 7 and 8, the following uses of AI and Generative AI are permitted within the Orno platform ecosystem without prior approval:
Permitted Without Prior Approval
- Drafting assistance: Use of AI tools for drafting scripts, captions, descriptions, emails, and other written content, provided the final output is reviewed, edited, and published under the Creator’s or Brand’s editorial judgment;
- Automated captioning & transcription: AI-generated closed captions, subtitles, and transcriptions for accessibility purposes;
- Research & ideation: Use of AI for brainstorming, trend analysis, audience research, and content-strategy planning;
- Basic editing & enhancement: AI-powered color correction, noise reduction, background removal, upscaling, auto-cropping, and similar non-substantive editorial enhancements that do not materially alter the depiction of persons, products, or events;
- Thumbnail generation: AI-assisted thumbnail creation using the Creator’s own likeness or original artwork, with appropriate disclosure;
- Music & sound design: AI-generated royalty-free music beds, sound effects, and ambient audio, provided no third-party artist’s style, voice, or composition is imitated without license.
Even for permitted uses, Covered Persons must comply with the disclosure obligations in Section 7 where the AI-generated content constitutes a material portion of the final output or where disclosure is required by applicable law (including EU AI Act Article 50).
Restricted Uses (Requiring Disclosure & Consent)
The following uses of AI are permissible only with (a) Clear and Conspicuous disclosure to the audience in accordance with Section 7, (b) prior written consent of any identifiable person whose likeness, voice, or persona is implicated, and (c) prior written approval from Orno’s Compliance Officer:
- AI-generated avatars, digital twins, or virtual representations of real persons (including the Creator themselves) used in commercial communications;
- Voice cloning or synthesis replicating the voice of any identifiable person;
- AI-generated product demonstrations, testimonials, or reviews where the output could be reasonably perceived as depicting a real experience;
- AI-assisted face or body modification (e.g., de-aging, face-swapping, body alterations) beyond conventional beauty filters;
- AI-generated dialogue or statements attributed to real persons, even where clearly labeled as AI-generated;
- Use of AI to generate content that imitates, parodies, or references the distinctive style of another identifiable creator without their consent;
- AI-generated content depicting products in use-cases or environments that were not actually tested or experienced.
Prohibited Uses
The following uses of AI and Synthetic Media are absolutely prohibited on the Orno platform, and any violation shall constitute an immediate, incurable material breach of this Policy and the Terms of Service:
Absolute Prohibitions — Criminal Liability May Attach
THE FOLLOWING ACTIVITIES MAY CONSTITUTE CRIMINAL OFFENSES UNDER APPLICABLE LAW, INCLUDING BUT NOT LIMITED TO 18 U.S.C. § 1030 (COMPUTER FRAUD), 18 U.S.C. § 1343 (WIRE FRAUD), 47 U.S.C. § 230 EXCEPTIONS, STATE DEEPFAKE STATUTES, AND THE EU AI ACT ARTICLE 5 PROHIBITIONS. ORNO WILL REFER ALL SUSPECTED CRIMINAL CONDUCT TO LAW ENFORCEMENT.
- Non-consensual intimate imagery: Creation, distribution, or possession of AI-generated sexually explicit, intimate, or nude depictions of any person without their express written consent, regardless of whether the output is labeled as synthetic;
- Identity fraud & impersonation: Use of AI to impersonate, misrepresent, or falsely attribute statements to any real person for the purpose of deception, defamation, or commercial advantage;
- Consumer fraud: Use of AI-generated content to deceive consumers regarding product attributes, performance, origin, endorsements, or testimonials in violation of 15 U.S.C. § 45 or analogous state consumer-protection statutes;
- CSAM-adjacent content: Any AI-generated content depicting, suggesting, or sexualizing minors in any manner whatsoever, including but not limited to content that would constitute child sexual abuse material under 18 U.S.C. §§ 2251–2260A or analogous law;
- Election misinformation: AI-generated content that falsely depicts candidates, election officials, or voting processes with the intent or foreseeable effect of suppressing voter turnout, spreading disinformation about election procedures, or influencing electoral outcomes through deception;
- Fake endorsements: AI-generated content creating the false impression that a person, brand, or organization endorses a product, service, candidate, or cause without their actual authorization;
- Manipulation of evidence: AI-generated or altered content presented as authentic evidence in any legal, regulatory, or investigative proceeding;
- Undisclosed synthetic reviews: AI-generated consumer reviews, ratings, or testimonials published without disclosure of their synthetic origin, in violation of the FTC’s Rule on the Use of Consumer Reviews and Testimonials (16 C.F.R. Part 465);
- Circumvention of AI safeguards: Use of jailbreaking, prompt injection, adversarial inputs, or other techniques to cause AI systems to produce content that violates this Policy or applicable law.
Disclosure & Labeling Requirements
In accordance with Article 50 of the EU AI Act (Regulation (EU) 2024/1689), FTC advertising guidance, California AB 2013, and this Policy, all AI-generated or synthetic content disseminated through the Orno platform shall be disclosed and labeled as follows:
Mandatory Disclosure Standards
- Textual label: Content that is wholly or substantially AI-generated shall bear a Clear and Conspicuous label stating “AI-Generated” or “Created with AI” in the caption, description, or on-screen overlay, positioned before any call-to-action and visible without requiring user interaction (scrolling, expanding, clicking);
- Audio disclosure: For audio or video content incorporating AI-generated speech, voice synthesis, or voice cloning, a verbal disclosure shall be made at the outset of the content;
- Platform labels: Where platforms provide native AI-content labels (e.g., YouTube’s “Altered or synthetic content” label, Meta’s “Made with AI” label), such native labels shall be enabled in addition to, and not in lieu of, the disclosures required by this Policy;
- Metadata: Where technically feasible, AI-generated content shall include machine-readable metadata (C2PA manifest, IPTC AI metadata, or equivalent) indicating the synthetic origin of the content;
- EU AI Act compliance: Content distributed to EU audiences shall comply with Article 50(4)’s requirement that synthetic audio, image, video, or text content be marked in a machine-readable format and disclosed to natural persons.
The obligation to disclose exists regardless of the proportion of AI-generated content in the final output. Where AI tools are used for substantive creative contributions (beyond mere correction or formatting), disclosure is required. In cases of doubt, Covered Persons shall err on the side of disclosure.
Consent for Likeness & Right of Publicity
No AI-generated or synthetic content shall depict, replicate, imitate, or evoke the likeness, voice, mannerisms, or persona of any identifiable living or deceased individual without prior, written, informed consent from such individual (or, in the case of a deceased individual, from their estate or authorized representative). This requirement is grounded in the common-law and statutory right of publicity applicable in all U.S. jurisdictions, including but not limited to California Civil Code § 3344 (living persons) and § 3344.1 (deceased personalities), New York Civil Rights Law §§ 50–51, and Indiana’s Right of Publicity Statute (Ind. Code § 32-36-1-1 et seq.).
Consent Requirements
- Consent must be specific to the particular AI use case, medium, duration, and geographic scope;
- Consent must be documented in writing (including electronic signature) and retained for the duration of use plus seven (7) years;
- Blanket or implied consent is insufficient—each materially different use requires separate authorization;
- Consent is revocable upon thirty (30) days’ written notice, after which all synthetic depictions of the revoking party must be removed from circulation;
- Compensation terms for AI-generated likeness usage must be separately negotiated and documented;
- Where a Creator consents to AI generation of their own likeness, the consent documentation must specify permitted modifications, contexts, and any limitations on alteration.
Training Data & Intellectual Property
Orno and its Covered Persons shall not, directly or indirectly, use any Creator Content (as defined in the Terms of Service) as Training Data for any AI or machine-learning model without the prior, written, informed, and specific consent of the Creator who owns or controls such content. This prohibition applies regardless of the technical method of ingestion (web scraping, API access, manual collection, or otherwise) and regardless of the intended use of the resulting model (internal, commercial, research, or open-source).
Training Data Principles
- Opt-in only: Use of Creator Content for AI training requires affirmative, specific consent—silence, inaction, or failure to opt out shall not constitute consent;
- Transparency: Any request for training-data consent must specify the model(s), purpose(s), and commercial application(s) for which the data will be used;
- Revocation: Creators may revoke training-data consent at any time; upon revocation, Orno shall use commercially reasonable efforts to exclude the relevant content from future training runs, acknowledging that removal from previously trained models may not be technically feasible;
- No scraping: Automated scraping, crawling, or bulk downloading of Creator Content from any platform for AI-training purposes is strictly prohibited;
- Third-party models: Covered Persons using third-party AI services (e.g., OpenAI, Anthropic, Stability AI, Midjourney) must ensure that Creator Content is not submitted to such services in a manner that grants the service provider training rights, unless the Creator has separately consented.
Nothing in this Section shall be construed to waive, diminish, or limit any intellectual-property right of any Creator under copyright law, trademark law, or the right of publicity. Orno acknowledges that the use of copyrighted material as Training Data without authorization may constitute copyright infringement, and this Policy does not constitute legal advice regarding the fair-use analysis applicable to any particular use case.
Output IP & Ownership
Orno acknowledges that the copyrightability of AI-generated outputs remains an evolving and unsettled area of law. The U.S. Copyright Office has issued guidance (Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence, 88 Fed. Reg. 16190 (March 16, 2023)) indicating that works generated entirely by AI without human authorship are not eligible for copyright protection, while works incorporating both human-authored and AI-generated elements may receive protection only as to the human-authored portions.
Ownership Principles
- Covered Persons shall not represent AI-generated outputs as solely human-authored works for purposes of copyright registration, moral-rights claims, or intellectual-property disputes;
- Where AI-generated content is incorporated into a larger human-authored work, the Creator or Brand shall maintain clear documentation of which elements are AI-generated and which are human-authored;
- Orno makes no representation or warranty regarding the copyrightability, registrability, or enforceability of AI-generated outputs;
- License grants to Orno under the Terms of Service and Master Services Agreement extend to AI-generated content created by Covered Persons in connection with Orno campaigns, to the extent such content is subject to any cognizable intellectual-property right;
- Covered Persons assume all risk that AI-generated outputs may infringe third-party intellectual-property rights, and the indemnification obligations of the Terms of Service apply to such infringement claims.
Provenance & Watermarking
Orno strongly encourages, and in certain circumstances requires, the use of content-provenance technologies to establish the authenticity, origin, and modification history of content distributed through the platform. Specifically:
- C2PA adoption: Covered Persons are encouraged to use C2PA-compliant tools and workflows that embed cryptographically signed provenance manifests in content, documenting the creation tool, AI involvement, and edit history;
- Watermarking: AI-generated images and videos should incorporate invisible digital watermarks (e.g., SynthID, Steg.AI, or equivalent) where supported by the generation tool, to enable downstream detection of synthetic origin;
- Preservation of metadata: Covered Persons shall not strip, alter, or falsify provenance metadata, watermarks, or C2PA manifests from any content, whether AI-generated or human-authored;
- Platform verification: Orno may implement automated provenance-verification tools to detect and flag AI-generated content that lacks appropriate disclosure or metadata;
- Future mandates: Orno reserves the right to mandate C2PA compliance or equivalent provenance standards for all content submitted to the platform, upon reasonable notice to Covered Persons.
Brand Campaign AI Disclosure
Brand partners commissioning sponsored content through Orno shall disclose to Orno and to participating Creators, prior to campaign commencement, any requirement or expectation that AI-generated content will be used in the campaign. Campaign briefs shall specify:
- Whether AI-generated content is permitted, required, or prohibited for the campaign;
- Specific AI tools or platforms approved for use;
- Disclosure and labeling requirements beyond those mandated by this Policy;
- Whether AI-generated likeness of any person (Creator, brand ambassador, or third party) is contemplated;
- Intellectual-property ownership and licensing terms specific to AI-generated deliverables;
- Whether the Brand’s own advertising standards or industry self-regulatory requirements impose additional AI-disclosure obligations (e.g., NAD/BBB National Programs, ASA/CAP Code).
Brands that fail to disclose AI-related campaign requirements shall bear sole responsibility for any regulatory non-compliance, consumer deception, or intellectual-property infringement arising from the undisclosed use of AI in the campaign, and shall indemnify Orno and all participating Creators for any resulting claims, penalties, or damages.
Audit & Takedown
Orno reserves the right to deploy automated and manual detection tools—including but not limited to AI-content classifiers, watermark detectors, provenance verifiers, and reverse-image search systems—to identify undisclosed AI-generated or synthetic content distributed through the platform. Upon identification of potentially non-compliant content, Orno may:
- Issue an immediate takedown notice requiring removal within twenty-four (24) hours;
- Apply platform-level labels identifying the content as potentially AI-generated;
- Suspend distribution, monetization, or amplification of the content pending investigation;
- Require the Covered Person to provide evidence of human authorship, consent documentation, or disclosure compliance;
- Demonetize or claw back compensation paid for campaigns involving non-compliant AI content; and
- Escalate to law enforcement where the content constitutes or facilitates criminal conduct (e.g., non-consensual deepfakes, fraud, CSAM-adjacent material).
Covered Persons who receive a takedown notice may submit a counter-notice within five (5) business days, providing evidence that the content complies with this Policy. Orno shall review counter-notices in good faith and restore compliant content within a reasonable timeframe. Repeated violations shall result in escalating enforcement, up to and including permanent platform removal.
Liability Allocation
Liability Warning
COVERED PERSONS ARE SOLELY RESPONSIBLE FOR ENSURING THAT THEIR USE OF AI-GENERATED CONTENT COMPLIES WITH ALL APPLICABLE LAWS, INCLUDING COPYRIGHT LAW, RIGHT OF PUBLICITY, DEFAMATION LAW, CONSUMER-PROTECTION STATUTES, AND THIS POLICY. ORNO DOES NOT PROVIDE LEGAL ADVICE AND MAKES NO REPRESENTATION THAT ANY PARTICULAR USE OF AI IS LAWFUL. THE RAPIDLY EVOLVING LEGAL LANDSCAPE SURROUNDING AI-GENERATED CONTENT CREATES SUBSTANTIAL LEGAL UNCERTAINTY, AND COVERED PERSONS ASSUME ALL RISK ASSOCIATED WITH SUCH UNCERTAINTY.
Liability for AI-generated content is allocated as follows:
- Creator liability: Creators are liable for all AI-generated content they create, publish, or distribute, including but not limited to claims of copyright infringement, right-of-publicity violations, defamation, consumer deception, and violation of platform terms;
- Brand liability: Brands are liable for AI-generated content they commission, approve, direct, or provide creative briefs for, including where the Brand’s instructions cause or contribute to non-compliant AI usage;
- Joint liability: Where both Creator and Brand contribute to non-compliant AI content, liability shall be joint and several, subject to contribution rights as between the parties;
- Orno’s role: Orno acts as a platform facilitator and does not endorse, verify, or guarantee the compliance of AI-generated content. Orno’s liability is limited to the extent expressly set forth in the Terms of Service and Master Services Agreement;
- Indemnification: The indemnification obligations set forth in the Terms of Service and Master Services Agreement apply to all claims arising from the use of AI-generated content, including claims by depicted persons, rights holders, consumers, and regulatory authorities.
Enforcement & Amendments
Violations of this Policy shall be subject to the enforcement framework set forth in Section 15 of the FTC Compliance & Disclosures Policy, including but not limited to: immediate content takedown; suspension or termination of platform access; withholding, clawback, or forfeiture of compensation; referral to regulatory authorities (FTC, state attorneys general, EU data protection authorities); pursuit of injunctive relief; and assessment of liquidated damages.
Given the rapidly evolving nature of AI technology, regulation, and industry practice, Orno reserves the right to amend, supplement, or restate this Policy at any time and from time to time, effective upon publication of the amended Policy on the Orno website. Material amendments shall be communicated to active Covered Persons via email or platform notification not less than fifteen (15) days prior to the effective date. Continued use of the Orno platform after the effective date of any amendment shall constitute acceptance of the amended Policy.
Covered Persons are encouraged to monitor legislative and regulatory developments regarding AI content, including but not limited to the EU AI Act implementation timeline (phased enforcement beginning August 2024 through August 2027), FTC enforcement actions, state deepfake legislation, and the Copyright Office’s ongoing rulemaking regarding AI and copyright. This Policy shall be interpreted in light of the most current regulatory guidance available at the time of any alleged violation.
Orno LLC
Office of the Compliance Officer
555 Winderley PlaceMaitland, FL 32751
United States of America
Email: compliance@orno.io
Legal: legal@orno.io
This Policy is effective as of the date first written above and shall remain in effect until expressly rescinded, superseded, or amended in accordance with this Section. By publishing, uploading, streaming, or otherwise disseminating any content through the Orno platform, each Covered Person acknowledges receipt of, consents to, and is bound by every term of this Policy.