The advent of deepfake technology presents significant legal challenges and societal implications. This thesis provides a comparative analysis of the image rights and its intersection with privacy, intellectual property, and other laws in the context of deepfakes. The study explores legislative frameworks in different jurisdictions, including the United States (California), the United Kingdom, France, and China, to understand how they address the emerging challenges posed by these technologies. This list of countries was chosen based on the specifics of each legal system and the differences in legal approaches. In our opinion, it is the analysis of different approaches to the recognition, categorizing and regulation of image rights that will help legislators to understand the possible pros and cons, pitfalls, and on this basis to ensure a balance of interests in the regulation of image rights.The thesis examines the concept of the image rights and its derivatives (e.g. right of publicity) as it relates to deepfakes, focusing on how this right is recognized and protected in various jurisdictions. In California, the right of publicity is well-established, providing detailed protection of personal attributes for commercial use. The UK, while lacking any formal image rights, offers protection through a patchwork of laws like copyright, trademark, and defamation. France approaches the issue through its strong emphasis on personal rights, particularly the right to one's image. China, experiencing rapid digital growth, incorporates image right within its comprehensive Civil Code, reflecting its commitment to personal dignity and autonomy.Deepfakes raise critical questions about consent, autonomy, and the potential for harm. These technologies can undermine personal identity and privacy, creating ethical and legal dilemmas. The thesis analyzes how existing legal constructs around the image rights respond to these challenges, considering the balance between protecting individual rights and allowing for freedom of expression and innovation.The research finds that the image rights, while essential, are not uniformly recognized or applied, leading to inconsistencies in protection against the misuse of digital twins and deepfakes. The thesis proposes a balanced legislative approach that harmonizes individual rights protection with societal interests. This includes recommendations for clear definitions, scope of protection, consent mechanisms, and appropriate legal recourse for violations.The methodology of the thesis involves a comprehensive comparative legal analysis. This approach includes:1. Review of existing legislation;2. Case law analysis;3. Societal and ethical considerations.The uniqueness of this work lies in its holistic approach, combining legal analysis with societal and ethical perspectives. It addresses an emerging area of technology and law, providing insights into how different legal systems are adapting to the challenges posed by deepfakes. This thesis stands out for its international scope and the depth of its interdisciplinary examination, offering valuable contributions to legal scholarship and policy discourse in the digital age.