PRIVACY POLICY

SUMMARY OF KEY POINTS

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. SOCIAL MEDIA ACCOUNT CONNECTIONS
7. YOUTUBE API SERVICES
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Name and email address
• Passwords (hashed, never stored in plain text)
• Google account information (if you sign in via Google OAuth)

Payment Information. Payments are processed by Stripe. We do not store your credit card number, expiration date, or CVV on our servers. We store your Stripe customer ID and subscription ID to manage your subscription.

Content Creation Data. When you use our AI video generation features, we collect and store:

• Generated videos, scripts, images, and audio files
• Category selections, custom topics, and generation settings
• Credit usage and generation history

Voice and Likeness Data. If you use our voice cloning or AI digital avatar features, we collect:

• Voice cloning audio samples you upload
• Face images you upload for AI avatars

This data is used solely to provide the voice cloning and avatar generation features you request. It is not used for biometric identification purposes.

Social Media Login Data. We may provide you with the option to register with us using your existing Google account. If you choose to register in this way, we will collect certain profile information about you from Google, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information. The information we collect includes:

• Log and Usage Data. IP address, browser type, device information, date/time stamps associated with your usage, and other diagnostic data.
• Device Data. Browser user agent, operating system, and device type.
• Device Fingerprint. Canvas-based device fingerprint, used solely to prevent free credit abuse (e.g., duplicate account detection). This data is not used for advertising or cross-site tracking.
• Cookies. Essential session cookies for authentication and maintaining your login state. We do not use advertising or tracking cookies.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user. Including AI-generated videos, scripts, images, voice synthesis, voice cloning, and AI digital avatars.
• To process payments and manage subscriptions. We process payment-related information through Stripe to handle your subscription billing.
• To publish content on your behalf. If you connect social media accounts and enable auto-posting, we use your authorized tokens to publish generated content to your connected platforms.
• To send transactional communications. We may send you account-related emails (e.g., welcome emails, subscription confirmations, password resets) via our email service provider.
• To protect our Services. Including fraud monitoring, abuse detection (such as duplicate free credit claims via device fingerprinting), and rate limiting.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Stripe — Payment processing. Your payment information is processed by Stripe according to Stripe's Privacy Policy.
• Amazon Web Services (AWS) — Cloud infrastructure, AI services (Amazon Bedrock, Amazon Polly, Amazon Nova Reel), and file storage (S3). Your generated content and uploaded media are stored on AWS servers.
• ElevenLabs — Voice cloning and synthesis. Voice audio samples you upload are sent to ElevenLabs to create voice models and generate speech.
• Google — Authentication provider. When you sign in via Google OAuth, limited profile information is exchanged.
• Resend — Email delivery service. Your email address is shared with Resend to deliver transactional emails (e.g., welcome emails, password resets).
• Social Media Platforms (TikTok, YouTube, X/Twitter) — If you connect your social media accounts for auto-posting, we use OAuth tokens to publish content on your behalf. We store encrypted access tokens for connected accounts.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your Google account. When you choose to do this, we will receive certain profile information about you from Google. The profile information we receive may include your name, email address, and profile picture.

We will use the information we receive only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, other uses of your personal information by Google. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.

6. SOCIAL MEDIA ACCOUNT CONNECTIONS

EaseReel allows you to connect third-party social media accounts (TikTok, YouTube, X/Twitter) for the purpose of auto-posting generated content. When you connect a social media account:

• We use an OAuth popup window flow to obtain your authorization. We do not see or store your social media password.
• We store encrypted OAuth access tokens and refresh tokens (using AES-256-GCM encryption) to maintain the connection.
• We collect your social media username/display name and profile information as provided by the platform's API.
• We use these tokens solely to publish content you have authorized for publishing.
• You may disconnect any social media account at any time, which will revoke our access and delete the stored tokens.

7. YOUTUBE API SERVICES

EaseReel uses YouTube API Services to analyze publicly available video data for niche research and trending topic analysis. This helps creators identify underserved content opportunities by examining aggregated signals such as view counts, channel sizes, and growth trends.

By using EaseReel, you agree to be bound by the Google Privacy Policy.

What data we access:

• Publicly available YouTube video metadata (titles, view counts, like counts, publish dates)
• Publicly available YouTube channel statistics (subscriber counts)
• YouTube search results for specific content niches

What we do NOT do:

• We do not store, display, or redistribute any YouTube video content
• We do not access any user's private YouTube data
• We do not use YouTube data for advertising or user tracking purposes

We only use aggregated statistical signals derived from publicly available data to calculate niche competitiveness scores. You can revoke EaseReel's access to your data via the Google security settings page.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information, in the United States and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses: We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Generated content (videos, images, audio) may be automatically deleted after 30 days. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information.

If you delete your account, we will remove your personal data within 30 days, except where retention is required by law. Data stored in backup archives will be securely isolated from further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• Encryption of data in transit (TLS/HTTPS)
• Hashed passwords (never stored in plain text)
• AES-256-GCM encryption for stored OAuth tokens
• Rate limiting and abuse prevention mechanisms
• Secure cloud infrastructure (AWS)

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@sensiblysmartllc.com.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the EEA, UK, Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided below.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at support@sensiblysmartllc.com.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of certain US states, you may have additional rights regarding your personal information.

Categories of Personal Information We Collect

*We collect voice samples and face images for content generation purposes only, not for biometric identification. These are categorized under H (Audio/Visual).

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to application users and other consumers.

Your Rights

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling

How to Exercise Your Rights

To exercise these rights, contact us at support@sensiblysmartllc.com. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf.

Appeals

If we decline to take action regarding your request, you may appeal our decision by emailing us at support@sensiblysmartllc.com. We will inform you in writing of any action taken or not taken in response to the appeal. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided below.

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. At any time, you have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner or the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with the manner in which we address any complaint, you can contact the Information Regulator (South Africa).

16. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@sensiblysmartllc.com or contact us by post at:

Sensibly Smart LLC
447 Broadway
New York, NY 10013
United States

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. To request to review, update, or delete your personal information, please email us at support@sensiblysmartllc.com with a data subject access request.