This Privacy Policy outlines the privacy practices of Vireel App ("Vireel") in relation to the Vireel App mobile application (the "App").

At Vireel App, we are dedicated to safeguarding and honoring your privacy. We treat your privacy with the utmost seriousness and will only use your personal information to deliver the Services if we have obtained your consent for the collection and processing of such personal data in accordance with the terms set forth below.

This Privacy Policy clarifies when, where, how, and for what purposes we collect personal information about you, how we utilize that information, the circumstances under which we may disclose it to third parties, your rights regarding your personal information, and the measures we implement to keep it secure.

By registering for, downloading, or using our Services, you acknowledge and accept this Privacy Policy, which forms an integral part of our Terms of Use. We reserve the right to update or revise this Privacy Policy from time to time.

1. Information We Collect

We collect the following data from you:

a. Information You Provide Directly

When you use our Services, we collect information that you actively provide to us:

Photos: We may collect photos you take with your device’s camera while using the App, as well as photos you upload to the App from your device. Please note that you will not be able to upload camera-captured content if we do not have access to your device’s camera.

Videos: We may collect videos you record with your device’s camera while using the App, as well as videos you upload to the App from your device. Please note that you will not be able to upload camera-captured content if we do not have access to your device’s camera.

Facial feature data: We may separately collect facial feature data from your photos solely to provide you with the face-swapping functionality of Vireel App. Please note that the facial feature data we collect does not constitute biometric data.

b. Usage Data

When you use our Services, we may collect information related to your activities within the Services, such as the pages you have viewed and the duration of your visits. We may also collect the following information: IP addresses, traffic sources, device and operating system details, wireless and mobile network connection information, unique device identifiers, IDFA (Identifier for Advertisers), region, browser type, language, battery level, and time zone.

c. Cookies and Similar Technologies

Like most online services and mobile applications, we may use cookies — small pieces of code stored on your device after you visit websites or online services. When you use the relevant website or application again, these code snippets enable their owners to provide you with personalized information tailored to your needs.

We use cookies solely for authentication purposes. When you access the Services or related content, Vireel App uses session cookies — such cookies will expire and cease to function once you close the Services. By clicking the corresponding button in the notification when using our Services, you explicitly consent to our use of cookies.

When you use the Services, we may also use technologies such as pixels, web beacons, and local storage to collect information about how you use Vireel App and to provide you with relevant features.

2. How We Use Information

Vireel uses your videos, photos, and facial feature data solely to provide you with the face-swapping functionality of the App — no other uses are permitted. Vireel will never use your videos, photos, or facial feature data for facial recognition purposes. This is because Vireel does not incorporate facial recognition technologies or any other technical means for processing biometric data to uniquely identify or authenticate users.

Uploaded Content (including your videos and photos) is collected to be displayed in a library, enabling you to reuse it conveniently and enhancing your experience of using the Services. Such Uploaded Content is stored on your device and in the cloud for a specific period, and will only be made available to you during your use of the Services. By submitting this content for face-swapping, you explicitly consent to its collection and storage as outlined in this Privacy Policy. Vireel will never use your Uploaded Content for facial recognition purposes, as we do not employ facial recognition technologies or other technical methods for processing biometric data to uniquely identify or authenticate users.

If Vireel decides to modify the aforementioned purposes for processing your personal information, we will notify you of such changes prior to using your personal information for the new purposes. If required by applicable laws, we will also obtain your separate consent for such changes.

3. How We Share Information

We never sell your personal information to third parties. Such information may only be shared in circumstances where it is necessary to fulfill a legitimate business function.

We do not rent, sell, or share your facial-related data (including photos) with any third parties outside of the company or its affiliates. We will never use your personal data for training and/or developing independent AI systems or products.

We will not share, transfer, or disclose your personal information in any manner that violates this Privacy Policy or applicable laws. In the event of a potential merger, division, acquisition, asset sale, bankruptcy liquidation, or similar transaction that may involve the transfer of your information, we will require the successor or transferee to protect your personal information in accordance with laws, regulations, and standards no less stringent than those outlined in this Policy.

4. How We Store Information

Vireel will store your data only for as long as is necessary to fulfill the purposes for which the data is processed. Specific storage practices are as follows:

Photos and videos: Your photos and videos are stored on Vireel’s servers solely during your editing session. Once you complete the editing process, these data will be immediately deleted from our servers. At all other times, the photos and videos used within the Vireel App are stored locally on your mobile device. You may remove this local data at any time by either deleting the photos and videos directly from your device’s file system or uninstalling the Vireel App.

Facial feature data: This data is immediately deleted from your device after use to safeguard your privacy.

Anonymous, aggregated, or de-identified data: Such data will be stored for as long as necessary to achieve the purposes outlined in this Privacy Policy.

Data Security

Vireel processes your data using computers and/or other IT-enabled tools. We implement appropriate technical and organizational security measures to protect your information against unauthorized or unlawful processing, as well as accidental loss, destruction, or damage. For instance, Vireel engages verified contractors who may access data (as specified in Section 2 of this Privacy Policy) only after signing relevant data processing agreements. We also provide guidance and training to our personnel to ensure they process your data securely in compliance with our internal data protection policies.

5. Your Rights Regarding Information

You have the following rights in relation to your personal data processed by Vireel App, in compliance with applicable data protection laws:

Right of Access and Data Portability

You have the right to access the personal data we process about you. This includes requesting details such as the purpose of collection and processing, the retention period, and the third parties with whom your data may be shared. You also have the right to receive your personal data in a structured, commonly used, and machine-readable format. Additionally, you may transmit this data to another data controller if the processing is based on your consent or a contract, and the processing is carried out by automated means.

Right to Rectification

You may request Vireel to correct any inaccurate personal data concerning you. You also have the right to complete any incomplete personal data as needed.

Right to Erasure

You can request the erasure of your personal data if the processing is no longer necessary for the purposes for which it was collected, or if there are no legal grounds to continue processing.

Right to Restrict Processing

In circumstances prescribed by law, you may request the restriction of your personal data processing. Examples include contesting the accuracy of the data being processed, or where Vireel no longer requires the data for its original purpose but you need it retained for specific reasons (e.g., to pursue a legal claim). In such cases, processing will be restricted rather than erased.

Right to Withdraw Consent

You may withdraw your consent for the collection and processing of your personal data at any time by contacting us. Withdrawal of consent does not affect the lawfulness of processing conducted prior to the withdrawal. Upon receiving your withdrawal request, Vireel will process it promptly and cease further processing of your personal data, unless required by law to continue.

Right to Object to Processing

You have the right to object to the processing of your personal data in certain scenarios as specified by applicable laws:

When processing is related to the performance of a task carried out in the public interest or the exercise of official authority vested in Vireel;

When we process your data to pursue our legitimate interests or those of a third party, and you believe your interests or fundamental rights and freedoms override such legitimate interests.

If you submit an objection to processing, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds for continuing the processing that override your rights.

Special Note on Direct Marketing

If we process your personal data for direct marketing purposes, you have the unconditional right to object to such processing at any time, without needing to provide a justification. Upon receiving your objection, we will immediately cease processing your data for direct marketing. Please refer to relevant sections of this Privacy Policy to learn if we process your data for direct marketing.

6. Payment Information

The handling of your personal information related to in-app purchases — including billing, processing, and management — is the sole responsibility of our e-commerce provider, Apple. Apple maintains the absolute security and protection of your payment details. The processing of this information is governed by the agreement between you and Apple. Please note that Vireel does not have access to, nor does it process or use, your credit or debit card information.

Rules and policies regarding in-app purchases are available directly within the Apple App Store.

In addition to Image Data (as defined in Section 1), Vireel and our authorized third-party partners may use cookies, Software Development Kits (SDKs), and other tracking tools to automatically collect the Personal Data described above.

7. Third-Party Account Login

7.1 Third-Party Account Login Process

When you log in to the App using third-party accounts (including but not limited to Meta, Google, or Apple), we will request access to basic information associated with your third-party account. This may include your username, email address, and public profile information. To complete the login authentication process, we will also share your App-specific ID, access token, and referral URL with the corresponding third-party platform. You may revoke our access permissions at any time through the settings of your third-party account, which will terminate further information sharing between that platform and Vireel.

7.2 Advertising and Analytics Practices

We may combine the information collected directly from you with your interaction data on our platform and data from other third-party contexts (such as browsing history, purchase activity, etc.) to analyze your interests and preferences. This analysis is solely intended to provide you with more relevant advertisements, optimize ad recommendation accuracy, and evaluate ad effectiveness.

8. Children’s Privacy

Protecting the privacy of children is a top priority for Vireel.

General Age Requirement

Vireel’s Services are only available to individuals aged 13 or older. Any use of or access to the Services by persons under the age of 13 is strictly prohibited and constitutes a violation of our Terms of Use and this Privacy Policy. If you are under 18, you must obtain the prior permission of your parent or legal guardian before providing any personal information to Vireel. We reserve the right to request reasonable proof of such permission, and you must submit the requested proof within a reasonable timeframe — no later than three (3) business days from the date of our request. If we do not receive a response or valid proof of your eligibility (including age and guardian permission, if applicable), we reserve the right to terminate your access to the Services.

Age Requirement for EU Residents

Pursuant to the requirements of the EU General Data Protection Regulation (GDPR), EU residents must be at least 16 years old to use our Services. To the extent prohibited by applicable law, we do not permit EU residents under the age of 16 to use the Services, unless they have obtained the prior permission of a parent or legal guardian in accordance with the above provisions.

If we inadvertently collect personal information from, or identify content belonging to or related to, a child under the age of 13 (or under 16 for EU residents), we will promptly delete such information in accordance with applicable data protection laws.

9. Changes to Our Privacy Policy

Vireel may update or revise this Privacy Policy from time to time. Such changes may be necessary to comply with applicable laws, regulations, or to reflect updates to the functionality of our Services. We encourage you to review this page periodically to stay informed of any modifications.

After any amendments to this Privacy Policy take effect, we will notify you of the changes through prominent displays within the App or other appropriate communication channels when you use the Services. If you continue to use the Services more than one (1) week after receiving such notification, you will be deemed to have accepted the revised Privacy Policy — unless applicable law requires Vireel to obtain your explicit consent for the changes. Explicit consent may be required, for example, if the changes involve modifications to the nature of data processing or the core purposes for which your personal data is processed.

10. Contact Information

We hope this Privacy Policy clarifies how Vireel collects, uses, stores, and protects your personal information. Vireel is committed to making every reasonable effort to safeguard your personal data.

If you have any questions, concerns, or inquiries regarding this Privacy Policy or our Services, please contact us at: [email protected]