1. Information We Collect
Account Information: When you create a Viral Reel account, we collect your email address, username, profile information, and any additional details you voluntarily provide.
Text Descriptions: We process text descriptions you provide about your videos to generate AI-enhanced captions and hashtags.
2. Legal Basis for Processing (GDPR)
We process your personal data based on the following legal grounds:
- Contract Performance: Processing videos and providing core app functionality
- Legitimate Interest: App improvement, security, and customer support
- Consent: Marketing communications and optional analytics (where required by law)
- Legal Obligation: Compliance with tax laws, anti-fraud measures, and legal requests
3. How We Use Your Information
- LUT Color Grading: Apply professional transformation and mood LUTs to enhance your video's visual quality
- AI Caption Enhancement: Process your text descriptions to generate viral-optimized captions and hashtag suggestions
- Service Improvement: Analyze usage patterns to enhance LUT quality and AI caption performance
- Customer Support: Respond to inquiries and provide technical assistance
- Security & Fraud Prevention: Detect and prevent unauthorized access and fraudulent activity
- Legal Compliance: Meet regulatory requirements and respond to legal requests
4. Video Processing & Color Grading Services
LUT-Based Processing: Videos are processed using professional Look-Up Tables (LUTs) to apply color transformations and mood adjustments. Processing occurs locally on your device.
Temporary Storage Only: Videos are stored solely during active LUT processing (typically 30 seconds to 2 minutes) and then removed once the user downloads the video to their photos.
AI Text Processing: Only your text descriptions are sent to AI services for caption enhancement. Video content itself is never analyzed by AI systems.
No Training Use: We do not use your videos or text descriptions to train our AI models. Your content is processed solely to provide you the color grading and caption enhancement services.
Content Ownership: You retain full ownership of all original and color-graded videos. We claim no rights to your content beyond the limited processing license described in our Terms of Service.
5. Data Sharing & Third Parties
We do not sell, rent, or share your personal information with third parties for marketing purposes. Limited sharing occurs only in these specific circumstances:
- AI Caption Services: OpenAI or similar providers for text-based caption enhancement (text descriptions only, never video content)
- Analytics Services: Anonymous usage data with Apple Analytics and Google Analytics (opt-out available)
- Payment Processing: We reserve the right to set up apple App Store, Google Play Store, and Stripe for subscription management
- Legal Requirements: When required by valid legal process, court order, or to protect legal rights
6. Your Privacy Rights
Regardless of your location, you have the following rights regarding your personal information:
- Access: Request a copy of personal data we hold about you
- Correction: Update or correct inaccurate personal information
- Deletion: Request deletion of your account and associated data
- Data Portability: Receive your data in a structured, machine-readable format
- Restrict Processing: Limit how we process your personal information
- Withdraw Consent: Revoke consent for processing where consent is the legal basis
- Object to Processing: Object to processing based on legitimate interests
Exercise Your Rights: Contact us at edward@bytelogic.ltd or use in-app privacy controls. We will respond within 30 days.
Authorized Agent: You may designate an authorized agent to make requests on your behalf by providing written authorization.
7. Security Measures
We implement comprehensive security measures to protect your data:
- Incident Response: 24/7 monitoring with documented incident response procedures
- Employee Training: Regular security and privacy training for all team members
- Zero-Trust Architecture: No inherent trust within our network infrastructure
8. Data Retention & Deletion
Account Data: Retained while your account is active and for 30 days after deletion (for recovery purposes)
Videos: Automatically deleted within 24 hours of processing completion using secure deletion protocols
Usage Analytics: Anonymized data retained for up to 25 months for service improvement
Support Records: Customer support interactions retained for 12 months for service quality
Legal Hold: Data may be retained longer when required by legal obligations or to defend legal claims
9. Children's Privacy (COPPA Compliance)
Viral Reel is not intended for children under 13 years old. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately at privacy@viralreel.ai and we will promptly delete such information.
Age Verification: By using our app, you represent that you are at least 13 years old (or the minimum age required in your jurisdiction).
10. International Data Transfers
Your information may be transferred to and processed in countries other than your own, including the United States and European Union. We ensure adequate protection through:
- Adequacy Decisions: Processing in countries with adequacy decisions from your jurisdiction
- Standard Contractual Clauses: EU-approved SCCs for data transfers outside the EEA
- UK International Data Transfer Agreement: For transfers from the UK
- Binding Corporate Rules: Internal data protection standards across all locations
11. Cookies & Tracking Technologies
Essential Cookies: Required for app functionality, authentication, and security
Analytics Cookies: Help us understand app usage (can be disabled in app settings)
No Advertising Tracking: We do not use cookies for advertising or cross-site tracking
App Tracking Transparency: We comply with Apple's ATT framework and request permission before any cross-app tracking
12. Data Breach Notification
In the unlikely event of a data breach that poses a risk to your rights and freedoms:
- We will notify relevant authorities within 72 hours (as required by GDPR)
- We will notify affected users without undue delay
- We will provide clear information about the breach and our response measures
- We will implement additional security measures to prevent future incidents
13. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or for legal reasons. We will:
- Post the updated policy in the app with a new "Last updated" date
- Send push notifications for material changes
- Email notifications to users for significant changes (where legally required)
- Provide 30 days notice before significant changes take effect
- Maintain an archive of previous policy versions for transparency
14. Contact Us & Data Protection Officer
For any questions about this Privacy Policy, data protection matters, or to exercise your privacy rights:
General Inquiries: edward@bytelogic.ltd
Response Time: We will respond to privacy requests within 30 days (or as required by local law).
15. Regulatory Authorities
You have the right to lodge a complaint with data protection authorities if you believe we have not handled your personal data in accordance with applicable law:
UK: Information Commissioner's Office (ICO) - ico.org.uk
EU: Your local Data Protection Authority
California: California Privacy Protection Agency - cppa.ca.gov
