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 AI-powered features requested by you, including face-swapping and other AI image and video generation features. This data 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 AI-powered features requested by you, including but not limited to face-swapping, AI image generation, AI video generation, and AI editing. 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. Uploaded Content is temporarily stored only for the duration necessary to provide the requested service. Once processing is completed, such content is deleted from our servers unless you choose to save it locally on your device, and will only be made available to you during your use of the Services. By submitting this content for AI processing, 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 personal data with third parties for marketing, advertising, or independent purposes.

However, we may share your photos, videos, and related content with third-party AI service providers solely for the purpose of generating AI content requested by you, as described in Section 3.1 below. 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.

3.1 AI Function Data Processing and Third-Party Sharing

To enable AI content generation, when you actively upload images, videos, audio files, or text prompts within the app, we may transmit your content, via encryption, to the following third-party service providers for model inference and technical processing:

Alibaba Group and its affiliated cloud service entities (such as Alibaba Cloud): Provide infrastructure and model inference services.

Google LLC and its affiliated service entities: Provide cloud computing and technical support services.

ByteDance and its affiliated technical service entities: Provide model inference support.

Our Protection Commitment:

Service Purpose Only: The above service providers process data solely on our behalf and only for fulfilling your proactive requests.

Non-Training Purposes: Service providers may not use your data for any model training, marketing, or other independent commercial purposes.

Data Retention Control: We have agreed with service providers that we will not retain related data for extended periods after processing, and we will not retain your original content except for fulfilling functional requirements.

Compliance Guarantee: We ensure that the relevant service providers have equivalent or higher levels of data protection measures and have signed strict privacy agreements.

User Authorization: We will obtain your authorization through a clear in-app interface before any data transmission. If you refuse authorization, we will be unable to provide you with the corresponding AI generation functionality.

3.2 Cloud Infrastructure and Data Transmission

To ensure reliable and secure service operation, user-uploaded content may be transmitted through our servers and processed using trusted cloud infrastructure providers (such as AWS, Google Cloud, Alibaba Cloud, or equivalent providers).

These cloud service providers act solely as data processors providing hosting and infrastructure services. They are not permitted to access, retain, use, or process user data for any independent purposes, including AI model training, analytics, or marketing.

We implement appropriate technical and organizational safeguards to protect user data during transmission and storage.

3.3 International Data Transfers

Depending on your location, your data may be processed in jurisdictions outside of your country of residence. We implement appropriate safeguards to ensure that such transfers comply with applicable data protection laws.

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.Safety and Objectionable Content Policy (UGC)

Strict Prohibition of Objectionable Content

To ensure a safe and respectful experience for all users,Vireel maintains a zero-tolerance policy toward objectionable content. You are strictly prohibited from using our AI tools to generate, upload, or share content that includes:

Sexually Explicit Material: This includes pornography, nudity, depictions of sexual acts, or graphic sexual imagery.

Sexually Suggestive Content: Content intended to be sexually provocative or sensational, including "NSFW" AI-generated videos.

Non-Consensual Sexual Imagery (Deepfakes): The creation or distribution of sexually explicit depictions of real individuals without their consent.

Child Exploitation: Any content that sexualizes, endangers, or exploits minors is strictly forbidden and will be reported to appropriate authorities.

Violence and Hate Speech: Content that depicts extreme gore, promotes self-harm, or encourages harassment and discrimination against protected groups.

AI Safety Guardrails and Moderation

In compliance with Apple’s safety standards for AI-driven platforms, we implement the following protections:

Proactive Filtering: We utilize advanced automated filters to intercept prohibited text prompts and monitor AI-generated frames for inappropriate visual content.

Enforcement and Termination

Users found to be in violation of these safety guidelines will face immediate consequences:

Immediate Removal: Any content deemed objectionable will be deleted from the platform without prior notice.

Permanent Ban: We reserve the right to permanently terminate the accounts of users who attempt to generate or distribute prohibited material. There is no appeal process for severe violations involving illegal content or child safety.

7. 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.

8. Third-Party Account Login

8.1 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.

8.2 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.

9. Children’s Privacy

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

General Age Requirement

Vireel’s Services are intended strictly for individuals aged 18 years or older. We do not knowingly collect, solicit, or process personal information from individuals under the age of 18.

Any access to or use of the Services by individuals under 18 is strictly prohibited and constitutes a violation of our Terms of Use and this Privacy Policy.

If we become aware that a person under 18 has provided personal information to us, we will take immediate steps to delete such information and terminate the associated account.

Age Requirement for EU Residents

Regardless of local minimum age thresholds under the EU General Data Protection Regulation (GDPR) or other applicable laws, Vireel’s Services are strictly limited to individuals aged 18 years or older.

We do not permit individuals under the age of 18 to access or use the Services under any circumstances.

If we become aware that personal information has been collected from, or content has been submitted by, an individual under the age of 18, we will promptly delete such information and terminate the associated account in accordance with applicable data protection laws.

10. 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.

11. 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]