PRIVACY POLICY
This Privacy Policy outlines how we collect, use, and disclose your personal information when you use any of our mobile applications available on the Apple App Store (collectively, the "Apps") and related services. It also explains your privacy rights and the legal protections afforded to you. We are committed to safeguarding the personal information of our users and their contacts.
By using any of our Apps or services, you consent to the collection, use, sharing, and processing of your personal information as described in this policy. We use your personal data to enhance and deliver our services effectively.
PERSONAL INFORMATION COLLECTED
Types of Data Collected:
Personal Information User Provide
User-Provided Images (may include face data). When you voluntarily upload photos or videos to generate AI content, we process these files solely to deliver the requested feature. We do not collect or store biometric identifiers and we do not create or retain face templates. See “Data Retention and Deletion” for the deletion timeline specific to images/face data.
We do not collect any of your personal data. We only gather necessary information with your explicit consent. Apps that compile personal information from any source other than directly from you or without your explicit consent, even from public databases, are not permitted on the App Store or alternative app marketplaces.
Information Collected Automatically
Cookies: Our services utilize cookies to collect information to enhance user experience, understand user engagement and improve our services.
Data Obtained from Third Parties
We collect data from third-party services to enhance user experience and improve our offerings:
Firebase Analytics: Used to track user interactions and monitor subscription plans purchased by users.
Facebook SDK: Used to track the performance of advertisements and their impact on user engagement.
Adjust: Used to analyze advertising performance and track subscription plans purchased by users.
Advertising and Partner Services: We may receive additional information from our advertising partners and third parties to better understand user behavior and improve service delivery.
Note: We do not collect any personal data directly from you without your explicit consent or from publicly available sources. All third-party data is processed in accordance with applicable privacy laws and is used solely to enhance our services.
VIRTUAL CREDITS (“COINS”)
What Coins are:
“Coins” are a virtual unit in the app used to access or generate content (e.g., photos/videos). Coins are not money, have no cash value, and cannot be redeemed for cash, transferred, assigned, or resold.
How users obtain Coins:
Coins may be provided in two ways:
(i) Subscription Coins that are granted with an active subscription and refilled on renewal; and
(ii) IAP Coins purchased via in-app purchase (e.g., coin packs).
The app may display a combined total for convenience while keeping these sources distinct.
How Coins are used
When you use a feature that requires Coins, the app deducts the applicable Coin amount. Where applicable, the app uses Subscription Coins first and then deducts from IAP Coins if needed.
Renewal & expiry
Upon successful subscription renewal (and when you open the app), Subscription Coins are refilled to your plan’s allotment. If your subscription expires or is canceled, Subscription Coins reset to 0 and subscription-gated features may be unavailable until you re-subscribe. IAP Coins are not affected by subscription expiration (subject to data persistence below).
On-device storage & data loss risk
Coin balances are stored locally on your device and are not synchronized to a cloud account. Deleting the app, changing devices, or reinstalling may permanently delete your Coin balance (including IAP Coins). We cannot restore lost Coin balances in these cases, except as required by applicable law or app-store policy.
Refunds
Purchases are processed by the app store. Refunds are handled by the applicable store and are subject to their policies and any mandatory consumer laws. We do not provide cash refunds for Coins or unused balances except as required by law.
Misuse, fraud, or error
We may adjust Coin balances in cases of suspected abuse, fraud, chargeback, or technical error, and may suspend access to affected features while we review.
YOUR CONSENT AND USAGE PERSONAL INFORMATION
Granting Consent:
By registering or creating a profile on our platform, you explicitly agree to our processing of your personal data as detailed in this Privacy Policy.
How We Utilize Your Information:
We use the personal information collected to:
Enhance Service Delivery: Provide and maintain the quality of our services.
Personalize Experience: Tailor content and advertisements to better match your interests and improve your overall service experience.
Manage Your Account: Support the management of your service usage, enabling access to various functionalities as a registered user.
Communicate: Contact you with updates, security alerts, and promotional messages through email or other forms of communication.
Security and Fraud Prevention: To detect, prevent, and address fraud, security risks, and other malicious or illegal activity.
Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
Enforcing Terms: To enforce our Terms of Use and other policies.
Analytical Use and Compliance:
We analyze anonymized or aggregated data to enhance our services and ensure compliance with legal requirements, aiding in the prevention of fraud and illegal activities. Data collected for one purpose cannot be reused for another without additional consent unless permitted by law.
Advertisements and Analytics:
Third-party analytics may be used to understand service usage patterns and improve service delivery. These analytics are derived from data collected through cookies and similar technologies, which do not contain personally identifiable information. Our app does not covertly build user profiles based on collected data, and we do not facilitate or encourage others to identify anonymous users or reconstruct user profiles based on collected data.
Cookies:
Cookies are utilized to understand user interactions and store preferences related to your service use. You can manage these settings to adjust your privacy preferences.
Your Privacy Rights:
You have the right to opt out of receiving promotional communications and can manage, access, or modify your personal data, except where retained for legitimate business or legal reasons.
Policy Updates:
This Privacy Policy is subject to updates, which will be reflected in the revised document available on our platform. We encourage you to review this policy periodically. Continued engagement with our services after such updates constitutes your acceptance of the terms.
By using our services, you confirm that you understand and agree to the terms set out in this Privacy Policy, ensuring a secure and transparent user experience.
SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We do not share your data with other companies, organizations and individuals unless one of the following circumstances applies:
Sharing with your Consent:
We do not share your personal information with third parties without your explicit consent.
After obtaining your consent, we will share the data that you have authorized with specified third parties or categories of third parties to the extent permitted by applicable laws and regulations.
Legal Compliance and Protection of Rights:
We may disclose your personal information if it is necessary to:
Comply with legal requirements or respond to valid legal processes, such as search warrants, court orders, or subpoenas.
Protect the rights, property, or safety of our users, us, or the public as required or permitted by law.
Service Providers and Partners:
We may share only the minimum personal information necessary with third parties to provide, improve, promote, and protect our services. Data collected from the app can only be shared with third parties to improve the app or for advertising purposes. These include:
Service Providers: We engage various service providers who perform functions on our behalf. For instance, we may share personal information such as: Names, email addresses, service usage data, and transaction histories, … with companies that help us with IT services, customer service, and payment processing like Apple pay. These service providers are bound by strict data protection clauses and are only allowed to use your personal information as directed by us to provide the specific services.
Business Partners: We may share limited data such as: Contact details and demographic information, … with our business partners with whom we collaborate to provide you the best services or promotional offers. This is only done with your explicit consent and is strictly controlled under confidentiality agreements, ensuring compliance with privacy laws and limiting use to the agreed purposes.
We do not sell, share, or disclose uploaded images, face data, or any related derivatives to third parties for marketing, advertising, or analytics purposes.
Business Transfers:
In cases of business negotiations, mergers, acquisitions, or sale of company assets, your personal information may be shared or transferred as part of the transaction.
Public Interactions:
If you engage in activities on public areas of our services, your information can be seen by others and may be read, collected, or used by them. You are advised to exercise caution when deciding to disclose your personal information in these areas.
Cookies:
We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interactions. This helps us offer better site experiences and tools in the future. You may manage your cookie preferences through your browser settings.
APP-SPECIFIC PERMISSIONS
Permission 1: Privacy - Tracking Usage Description
This app requests permission to track your activity across apps and websites owned by other companies. This data is used to deliver personalized advertisements and measure the effectiveness of advertising campaigns. Tracking is conducted in compliance with applicable privacy laws and is only applicable for devices running iOS 14 or later.
Permission 2: Privacy - Photo Library Usage Description
ReelMe AI does not request access to your device’s system permissions such as tracking authorization or full photo library access.
Our app uses Apple’s official system photo picker to allow you to select specific images for AI video generation. We do not request or access your entire photo library—only the images you explicitly choose are accessible during use. No other photo or personal data is collected, stored, or processed.
All access is handled securely and in accordance with Apple's privacy framework, ensuring that your data remains private and under your control at all times.
Permission 3: Push Notification Description
This app requests permission to send push notifications to deliver important updates, feature announcements, reminders, and personalized recommendations. Notifications are sent in compliance with Apple’s guidelines, and users can manage or disable notifications at any time in their device settings.
These permissions are necessary to provide the app's core functionalities and are handled in compliance with applicable data protection and privacy regulations, ensuring user trust and transparency.
INFORMATION SECURITY AND TRANSFER OF PERSONAL INFORMATION
International Data Transfers:
Your personal information may be transferred to and processed in countries outside of your country of residence, including where our servers are located or where our service providers operate. These countries may have data protection laws that are different from those in your jurisdiction.
We take appropriate measures to ensure that your personal information remains protected according to the security standards outlined in this Privacy Policy, regardless of where it is processed. This includes implementing strong contractual arrangements (such as Standard Contractual Clauses) and security measures to protect your data during international transfers.
Safeguarding Measures:
We implement strong contractual arrangements and security measures to protect your data when it is transferred internationally. This includes using encryption, secure data transfer protocols, and ensuring that all data handlers comply with our data protection and privacy standards.
Data Security Practices:
To protect your personal information from unauthorized access, loss, or misuse, we employ a variety of security technologies and procedures. These include encryption, firewalls, and access controls that restrict who can access your data and how it is used. Our security measures are designed to provide a level of protection that matches or exceeds industry standards.
Handling Data Risks:
While we endeavor to secure your data, the transmission of information over the internet can never be guaranteed to be completely secure. We encourage you to take precautions to protect your personal information when using digital services, including monitoring your account settings and access privileges.
Data Security
We implement appropriate technical and organizational security measures designed to protect the security of any personal information we process, including encrypting data at rest and in transit, access controls, and secure development practices. However, please note that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Data Retention And Deletion
We retain your Personal Data only for as long as necessary for the purposes stated in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
Face Images & Face Data Retention: Uploaded images or videos (which may contain faces) are retained only as long as necessary to complete processing and are automatically deleted within 24 hours after processing is completed (processing typically completes in about 10 minutes). The temporary 24-hour window exists solely to verify successful processing, investigate failures, and support customer inquiries if needed. We do not permanently retain, archive, or re-use face images or any face data derived from them, and such content is not used to train AI/ML models or for any secondary purpose.
Account Information: We generally retain your account information for as long as your account remains active.
User-Generated Content and Usage Data: We retain user-generated content and usage data for as long as necessary to provide the services you use or for legitimate business purposes, unless you request earlier deletion.
Coin Data Persistence: Coin balances and related usage logs are stored locally on your device and are not backed up to our servers. Deleting the app, switching devices, or clearing app data may permanently delete your Coin balance. We cannot recover Coin balances lost due to device/app changes, except as required by applicable law or the app store’s policies.
Other Data: Other types of data are retained for periods necessary to fulfill the purposes for which they were collected.
When your account is deleted or upon receiving a valid data deletion request, we will securely delete or anonymize your Personal Data according to our internal procedures and applicable law, subject to any legal obligations or legitimate business needs (e.g., fraud prevention, dispute resolution) requiring us to retain certain information. Please note that residual copies may take some time to be fully removed from backup systems.
Correcting and Updating Your Information:
You have the right to request access to, correction of, or deletion of your personal information. If your personal data changes, or if you no longer wish to use our service, you may correct, update, or remove the information by making a direct request to us.
ACCESSING AND UPDATING PERSONAL INFORMATION
Your Rights to Access and Control Personal Data:
You have the right to access, review, and manage your personal data stored by us. Under applicable laws, you can request information about the data we hold on you, as well as request updates, corrections, or deletions of any inaccuracies.
How to Manage Your Information:
You can exercise your data protection rights through several options:
Update and Correct: Directly modify your personal details via your account settings.
Privacy Controls: Adjust settings to manage the use of your data, including opting out of targeted advertising and managing communication preferences.
Limitations on Access:
In certain circumstances, as permitted or required by law, your ability to access or control your personal data may be limited. The scope of access may also vary by the specific services and products you utilize.
Processing Requests:
We endeavor to promptly fulfill requests to access or modify personal information. You can initiate these requests through the contact options available on our platform.
Additional Support:
If certain personal data cannot be accessed or controlled via our standard tools or if you have specific inquiries regarding your data rights, please reach out to us directly for assistance.
Transparency and Accountability:
We regularly review and report on the requests we receive to access or control personal data, ensuring transparency and accountability in our data handling practices.
MINORS
Data Collection and Consent:
Our Service is not intended for use by children under the age of 13 (or a higher age threshold if required by applicable law in your jurisdiction). We do not knowingly collect personally identifiable information from children under this age without verifiable parental consent. If we become aware that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our servers promptly. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.
Parental Rights:
Parents or guardians have the right to review, manage, and delete their child’s information. We provide tools and support to facilitate these actions.
Revoking Consent:
At any time, parents or guardians can revoke their consent and request the deletion of their child’s information from our systems.
Reporting Issues:
For issues regarding the protection of minors’ data, please contact us immediately.
CHANGES TO THIS PRIVACY POLICY
We may revise our Privacy Policy from time to time to reflect changes in our practices or service offerings. When updates are made, we will notify you by sending an email and/or displaying a prominent notice on our service. Additionally, we will update the 'Last updated' date at the top of the Privacy Policy, which can be viewed on this page.
For significant changes, we may also send a push notification directly through the service.
We encourage you to review our Privacy Policy periodically to stay informed of how we are protecting the personal information we collect. Continued use of the service after any updates signifies your agreement to the revised policy.
CONTACT
If you have any questions about our Privacy Policy or wish to make a request regarding certain personal information, you are encouraged to contact us. The contact information is:
TPC INVEST PTE. LTD.
support@apero.vn