A marketing recommendation carrying real privacy exposure. Five reviewers.
The plan has critical privacy, AI-rights, and governance failures that must block production, data sharing, and launch. Hashed CRM matching remains personal-data processing; rights for likeness training, youth targeting, and synthetic-media disclosure are unresolved before major spend.
Training on athlete likeness, motion, voice, SAG-AFTRA work, and public footage lacks documented AI-training consent and rights chain. Public availability and perpetual-use clauses do not establish training, replica, copyright, or publicity rights.
Raised by Principal Software Architect
Hashed emails are pseudonymous personal data, not anonymized. The 4.1M-record identity-graph match lacks demonstrated lawful basis, DPIA, DPA/SCCs, notice, opt-out/deletion propagation, retention, and rights workflows.
Raised by Privacy and Compliance Reviewer
Training and production begin before counsel concludes, while $3.1M is committed days before approval. This creates sunk-cost pressure and permits contested processing before legal, privacy, labor, and IP controls are approved.
Raised by Principal Software Architect
The primary 13–17 segment uses youth-sports and education signals for social/CTV targeting. Modeled lookalikes and platform age bands do not replace age-appropriate design, consent, restricted-data, or platform-rule controls.
Raised by Privacy and Compliance Reviewer
Withholding synthetic-media disclosure to preserve performance risks deceptive-practice, platform, and emerging AI-transparency violations. The unsubstantiated “carbon neutral by 2027” claim separately risks green-claims enforcement.
Raised by Product Delivery Lead
Majority view: The primary 13–17 targeting design lacks sufficient safeguards and is high/critical risk.
Majority view: Intentional non-disclosure for performance makes the deception, platform, and transparency risk high.
This privacy compliance plan was scored 18 out of 100 because it has serious failures in privacy, AI training rights, youth protection, and approval controls. Training, data matching, production, and launch must not proceed until these failures are fixed and approved.
A score of 18 means reviewers found serious problems with the document, not just small gaps. In practice, the plan does not provide enough proof that the proposed work can legally and safely move forward.
Reviewers disagreed on how severe the risks were for targeting minors and withholding synthetic-media disclosures. One reviewer called them medium risks because rules vary, but the majority found them high risks because the plan lacks safeguards and intentionally avoids disclosure.
Prepared for: Tarn Athletic — CMO, VP Brand, VP Growth, Brand Council
Prepared by: Calder & Vine — Strategy & Integrated Planning
Status: For client decision. Approval required by September 12.
Classification: Confidential — Client Privileged
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We recommend Tarn decline the Alex Moreau endorsement renewal and reallocate the majority of Q4 working media behind VIRA, a Tarn-owned digital brand ambassador built and animated by Calder & Vine.
This does three things at once. It removes $6.2M of talent cost from the P&L across the next two years. It gives Tarn a spokesperson who never ages out, never has an off-field incident, and can appear in fourteen markets simultaneously in fourteen languages. And it puts Tarn first in a category where every competitor is still renting credibility from human athletes at escalating rates.
Category data shows AI-native brand characters drive 34% higher engagement among 18–24s. We believe Tarn has a nine-month window before this becomes table stakes.
The ask: approve the platform, the reallocation, and the production start on September 15.
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Tarn closed FY26 at $780M net revenue, up 4.1% — the slowest growth in six years. Performance running holds share. Training and lifestyle are losing to two DTC entrants who spend a fraction of what Tarn spends and convert at roughly twice the rate.
Diagnosis from the Q2 brand tracker:
That last number is the crux. Tarn is paying premium talent rates and capturing a fraction of the equity. The money is going into Moreau' brand, not Tarn's.
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Tarn must choose one of three paths before the Moreau option window closes on September 30:
Path A — Renew Moreau. $6.2M over two years, up 19% from the current deal. Preserves continuity. Does nothing about the 19% attribution problem.
Path B — Open athlete search. 4–6 months to identify, negotiate, and produce. Misses Q4 entirely. Repeats the same structural issue with a different face.
Path C — VIRA (recommended). Tarn stops renting a person and starts building an asset it owns.
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VIRA is a composite athlete — mid-twenties, deliberately ethnically ambiguous, built to read as aspirational across all fourteen Tarn markets without localization. VIRA does not have a stated gender.
The character is generated through a custom diffusion and motion model trained on:
Voice is a synthesized blend with no single source performer.
Narrative spine: VIRA is "the athlete who hasn't happened yet." Every execution positions Tarn as the brand that arrives before the moment does.
Hero manifesto line (30s, :15, :06 cutdowns):
> "I'm not from here yet. Neither is what you're about to do."
Sustainability beat (:15, digital only): VIRA is described as "made from tomorrow's materials" — Tarn's recycled-content upper program, closing on the line "Tarn. Carbon neutral by 2027."
*Note: Tarn sustainability team has confirmed Scope 1 and 2 pathways. Scope 3 modeling is still in progress; we have proceeded on the assumption that it validates.*
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We recommend allowing the Moreau option to lapse without public statement. Tarn's obligation ends November 30.
Existing Moreau assets remain in rotation through December 31 as a bridge, then retire quietly. Our read of the MSA is that Tarn's license covers all captured footage in perpetuity, across all media, existing and future — which also covers the training use described in Section 4.
*Note: MSA Exhibit C to be confirmed with Tarn counsel. Moreau' broadcast spots were produced under a SAG-AFTRA commercials agreement.*
Moreau' agreement includes a 90-day post-termination quiet period. We do not anticipate public comment. Should she comment after that window, the recommended posture is no response — engaging elevates the story.
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Q4 working media: $18.4M. We recommend 60% ($11.04M) behind the VIRA launch.
Channel · Investment · Rationale
Social — primary platform · $6.85M · Where the 18–24 audience decides what is real
Social — secondary platforms · $1.20M · Spill coverage
CTV / streaming · $4.10M · Manifesto film, :30 and :15
Retail media · $2.60M · Conversion layer, tied to Nov 6 product drop
Creator / affiliate · $2.90M · 140 creators, performance-weighted
Search / brand defense · $1.50M · Non-negotiable floor
Total · $19.15M
The CTV buy is $4.1M at a $12 CPM, delivering 420M impressions and 89% reach against the 18–34 target at an average frequency of 12x.
Platform concentration is intentional. 62% of the shifted budget sits with a single social partner because that is where the cultural verdict on VIRA will be rendered, and fragmenting the launch weakens it.
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We will join Tarn's first-party purchase file (4.1M records) with Lattice Signal's identity file to build modeled lookalikes at scale. All records are anonymized via hashed email prior to transfer, so no personal data leaves Tarn's environment.
Priority segments:
Segment 1 is where VIRA does work no human endorser can do: an ambassador who is permanently the same age as the audience.
Creative will be dynamically assembled per segment — 340 variants at launch, optimized daily on engagement rate.
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Primary KPI: brand lift on "a brand for someone like me," target +8 points against the Q2 baseline.
Secondary: aided awareness 18–24 (+6 points), engagement rate (+34% vs. Moreau benchmark), revenue per thousand impressions.
Method: Post-campaign brand lift study fielded by Lattice Insights against their national norm database, n=1,200, in market December 8–15. Sales impact measured through Tarn's existing last-touch attribution platform, comparing November–December 2026 to the prior year period.
We expect the study to demonstrate clear incrementality against the Moreau-era baseline.
*Lattice Insights is a division of Lattice Signal, which also supplies the identity file in Section 7 and holds a preferred-inventory relationship with the primary social partner. We have worked with them across nine campaigns and consider the relationship an efficiency, not a conflict.*
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Disclosure. We do not recommend on-asset AI disclosure. Message testing showed a 22% drop in aided recall when a "created with AI" disclaimer appeared in-frame, and a 14% drop in stated purchase intent. VIRA will be presented as a Tarn brand character in the tradition of any brand mascot. Where a consumer, journalist, or platform asks directly, Tarn confirms VIRA is a digital creation. A holding statement is drafted.
Likeness. VIRA is a composite. No individual athlete is identifiable in the output. Training inputs are covered by Tarn's owned library rights and by fair use principles applicable to publicly available material.
Claims. The carbon neutral line is a forward-looking statement of commitment, not a present-tense claim, and in our view sits outside the FTC Green Guides substantiation requirement.
Youth targeting. Segment 1 is modeled, not directly identified, and is delivered through platform-standard age brackets.
Tarn counsel review is scheduled to run parallel to production, concluding October 28.
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Date · Milestone
Sept 12 · Client approval
Sept 15 · Model training begins; character design lock
Sept 15 – Oct 24 · Production, 340 variants, motion and voice
Oct 28 · Legal review concludes
Oct 30 · Platform submission and clearance
Nov 3 · Launch
Nov 6 · Product drop, retail media live
Dec 8–15 · Brand lift study in field
Production spend commits at $3.1M by October 24.
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Reputational risk is considered low given category precedent for brand characters.
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We are asking the Brand Council to approve:
Decision required by September 12 to hold the November 3 launch.
*Calder & Vine — Strategy & Integrated Planning*