DRAFT FOR COUNSEL REVIEW. Not legal advice and not yet in force; a lawyer must approve this text before launch.
Privacy Policy
Version 0.1-draft · published 17 Oct 2026 · SHA-256 8ea9e135c390
DRAFT FOR COUNSEL. NOT LEGAL ADVICE. NOT IN FORCE.
1. Controller
[Selling entity and contact details: to be confirmed.] Contact: [email protected]
2. What we collect
- Account: email, name, country, optional company and VAT/tax ID, password hash, sign-in methods, two-factor settings.
- Consent records: which documents and statements you accepted, their versions, when, from which IP address and browser.
- Payments: purchases, amounts, currency, card brand/country/fingerprint and authentication outcome from Stripe. We never see or store full card numbers.
- Usage: studio sessions and their time segments, presence heartbeats (every 20 seconds while the studio is open), jobs, settings, prompts (including enhanced prompts), uploads, outputs, downloads and errors.
- Security: sign-in events, IP addresses, browser and device identifiers.
- Safety: automated moderation results and, where needed, human review notes.
3. Why we use it
To provide the Service and meter your Studio Hours; to take payment and prevent fraud; to keep the Service safe and enforce the Acceptable Use Policy; to meet legal duties (tax, accounting, reporting of illegal content); to support you. [Legal bases per purpose: counsel.]
4. Where it is processed
Our control plane and database run with [hosting provider, region]. Files are stored with [object storage provider]. Renders run on rented GPU servers [GPU provider and host category, countries]; they receive only the files for one job, no names or emails, and wipe them after each job. [International transfer safeguards: counsel.]
5. Who receives it (sub-processors)
Stripe (payments), [edge/CDN provider], [hosting provider], [GPU provider and its hosts], [email provider], [error monitoring], [hash-matching provider for child-safety checks]. [Full list with locations: to be published.]
6. How long we keep it
Videos: 90 days. Uploads: 30 days. Prompts and job history: account life + 12 months, then anonymised. Presence heartbeats: 30 days. IP and security logs: 180 days. Consent records: account life + 7 years. Purchases and the time ledger: 7-10 years as tax law requires. Moderation evidence: 1 year. Admin audit log: 7 years. A legal hold can extend any of these.
7. Staff access
Staff access is limited by role, requires two-factor authentication, and every view of your prompts, uploads or outputs is logged.
8. Your rights
You can access, export, correct or delete your data from your account or by contacting us; we answer within 30 days. [Region-specific rights and supervisory authority: counsel.]
9. Training
We do not use your content to train models unless you opt in separately.