Privacy Policy

Last updated: April 22, 2025

Introduction

1. What Information We Collect

Information You Provide

• Account Information: when you register on the Services, such as your date of birth, email, password, phone number, linked social accounts, and any other information you add to your user profile.
  
  
• User Content: content you create, upload, or generate (photos, videos, audio, comments, templates, likes, etc.), including metadata (when, where, by whom). We may pre-upload User Content (e.g., for audio recommendations, captions, or personalization).
  
  
• Clipboard Data: with your permission, we may collect content copied to your device’s clipboard if pasted or shared via the Services.
  
  
• Email Contacts: if you choose to sync your Google contacts, we may collect Gmail addresses of your contacts.
  
  
• Information When You Contact Us: such as proof of identity, feedback, complaints, or inquiries.
  
  
• Purchase Information: if you use paid features, we or our payment partners may collect card details, billing/delivery info, and transaction details.
  
  
• Other Information: voluntary feedback, survey participation, challenges, research, promotions, or contests (e.g., gender, age, preferences).
  
  

Automatically Collected Information

• Technical Information: IP address, device IDs, advertising IDs, network type, device model, OS, region, app version, file names/types, system language, resolution, and battery info.
  
  
• Location Information: approximate location based on SIM region or IP address.
  
  
• Usage Information: engagement metrics such as content viewed, duration/frequency, ads watched, filters/stickers used, followers, likes, etc.
  
  
• Image and Audio Information: analysis of uploaded videos/images/audio (objects, scenery, face/body attributes, spoken words). Used for moderation, recommendations, ads (where permitted). Face/body data is deleted after effect processing.
  
  
• Auto-Caption Text: transcriptions and edits are collected to improve captioning features.
  
  
• Cookies: used to recognize you, remember preferences, analyze traffic, improve performance, and serve ads (where legally permitted).
  
  

Information From Other Sources

• Third-Party Services: if you sign up or log in with Apple, Facebook, Google, TikTok, etc., we may receive your username, profile picture, email, and contacts.
  
  
• Corporate Group: affiliated entities may share information about your activities.
  
  
• Others: information received via User Content, complaints, or reports from other users/third parties.
  
  

2. How We Use Your Information

• Verify your age and identity.
  
  
• Provide and administer Services (create, edit, share User Content, interact with others).
  
  
• Enable cross-product functionality using a unified account system.
  
  
• Promote your content to other users.
  
  
• Communicate with you, including service updates and changes.
  
  
• Provide tailored/personalized recommendations and marketing (where permitted).
  
  
• Enforce Terms of Service, Community Guidelines, and policies.
  
  
• Handle and process queries, complaints, or feedback.
  
  
• Improve and develop Services, including AI models and algorithms.
  
  
• Maintain internal operations (troubleshooting, testing, research, analytics).
  
  
• Detect and prevent abuse, fraud, or illegal activity.
  
  
• Provide advertising (including personalized ads, where allowed).
  
  
• Comply with legal obligations or protect vital interests.
  
  
• Other purposes disclosed at the time of collection or with your consent.
  
  

3. How We Share Your Information

• Service Providers and Business Partners: for hosting, content delivery, support, moderation, payments, analytics, or marketing.
  
  
• YouTube API Services: if you use YouTube-related features (subject to YouTube Terms of Service & Google privacy policy).
  
  
• Analytics Providers: to optimize performance and personalization.
  
  
• Corporate Group Entities: for storage, payments, R&D, support, or cross-platform features.
  
  
• Third-Party Services: if you log in or link accounts, or share CapReels content externally.
  
  
• Advertising Partners: to deliver relevant ads (personalized where consented).
  
  
• Measurement Partners: to measure ad campaign effectiveness.
  
  
• Legal Obligations: if required by law, regulators, or for fraud/security reasons.
  
  
• Business Transfers: in mergers, acquisitions, asset sales.
  
  
• With Consent: where you direct us to share information.
  
  
• International Transfers: your data may be stored in servers outside your country (e.g., U.S., Singapore, Malaysia).
  
  

4. Your Rights and Choices

• Access, view, and edit your profile via in-app settings.
  
  
• Control ads shown to you, manage linked third-party services, and adjust personalization preferences.
  
  
• Manage advertising preferences via opt-out links (e.g., NAI opt-out, About Ads).
  
  
• Opt out of marketing emails via the unsubscribe link.
  
  
• Exercise data rights (access, deletion, correction, withdrawal of consent, etc.) under local laws, as outlined in Supplemental Terms – Jurisdiction Specific.
  
  

5. Data Security

• Measures: encryption, firewalls, access controls, monitoring, internal policies.
  
  
• Updates: we regularly update our security systems.
  
  
• Limitations: internet transmission is never 100% secure, and we cannot guarantee absolute security.
  
  

6. Data Retention

• CapReels Cloud Space: uploaded content is deleted at your request or as permitted by law.
  
  
• General Data: kept as long as we have a legitimate business interest (e.g., improving Services, ensuring security, or defending legal claims).
  
  
• Legal Compliance: some data may be retained longer if required by law or regulation.
   When data is no longer needed, we securely delete or anonymize it.
  
  

7. Information Relating to Minors

• If you are under the minimum age, do not use the Services.
  
  
• If we learn we have collected data from a minor below the legal age, we will delete it promptly.
  
  
• Parents/guardians who believe their child’s data was collected may contact us via Contact Us.
  
  

8. Privacy Policy Updates

• Updates will be communicated by changing the “Last Updated” date, posting the new version, or providing other legally required notice.
  
  
• We encourage you to review the Privacy Policy regularly.
  
  
• Continued use of Services after updates means you accept the revised Policy.
  
  

9. Contact Us

• US inquiries: capreels.support@capreels.com
  
  
• Non-US inquiries: capreels.support@capreels.com or via online form: www.capreels.com/privacy/submit-your-request
  
  

10. Supplemental Terms – Jurisdiction Specific

Argentina

• Rights: access, rectification, deletion under Law No. 25,326 and Decree No. 1558/2001.
  
  
• Complaints: users may file with AAIP (AAIP Website).
  
  

Australia

• Certain corporate affiliates outside Australia may access your data remotely to provide functionality.
  
  

Brazil

• Rights under LGPD, including confirmation, access, correction, anonymization, portability, objection, consent withdrawal, and automated decision review.
  
  
• Verification: identity verification may be required before fulfilling rights requests.
  
  
• Limitations: some requests (e.g., deletion) may be denied for legal or security reasons.
  
  
• International Transfer: data may be shared globally within the corporate group or with third parties.
  
  
• Language: Portuguese version prevails.
  
  
• DPO Contact: dpobrasil@capreels.com
  
  

Canada

• Quebec users: must be at least 14 years old to use Services.
  
  
• Rights: access, update, correction, withdrawal of consent.
  
  
• Marketing: users may unsubscribe at any time.
  
  
• Retention: data retained only as long as necessary; securely disposed afterward.
  
  
• Transfers: data may be processed outside Canada (e.g., U.S., Malaysia, Singapore).
  
  
• Contact: Privacy Office via Contact Us section.
  
  

European Economic Area (“EEA”), Switzerland, and UK

Legal Bases for Processing

• Contractual necessity: to provide the Services, allow account creation, User Content sharing, interactions, and communication.
  
  
• Legitimate interests: to improve and develop Services, ensure safety/security, enforce Terms, detect fraud/abuse, and conduct analytics.
  
  
• Consent: for personalized advertising, marketing communications, and certain data sharing. You may withdraw consent anytime (does not affect processing done before withdrawal).
  
  
• Legal obligations: to comply with applicable laws and government requests.
  
  
• Vital interests: to protect your or others’ life and safety.
  
  

Your Rights under GDPR

1. Access: confirm if we process your data and receive a copy.
   
   
2. Rectification: correct inaccurate or incomplete data.
   
   
3. Erasure (“Right to be Forgotten”): request deletion of your data.
   
   
4. Restriction: limit processing in certain cases (e.g., disputing accuracy).
   
   
5. Portability: receive your data in a machine-readable format or request transfer to another provider.
   
   
6. Withdrawal of Consent: stop processing based on consent at any time.
   
   
7. Objection: object to processing based on legitimate interests or direct marketing.
   
   
8. Automated Decisions: not to be subject to profiling or automated decisions that significantly affect you.
   
   
9. Complaint: file with your local Data Protection Authority (DPA).
   
   

International Data Transfers

• Adequacy Decisions: transfers to countries recognized by the EU/UK as providing adequate protection.
  
  
• Standard Contractual Clauses (SCCs): for transfers where no adequacy decision exists.
  
  

GDPR Representatives

• UK Representative:
   Cosmo Technology Private Limited
   2 Temple Back East, Temple Quay, Bristol, BS1 6EG, United Kingdom
  
  
• EEA / Switzerland Representative:
   Mikros Information Technology Ireland Limited
   Mespil Business Centre, Mespil House, Sussex Road, Dublin 4, Ireland
  
  

Egypt

• You declare that you are over 18 years old.
  
  
• If you are under 18, your parent/legal guardian must read and accept this Privacy Policy and Terms of Use for you to access CapReels.
  
  
• Parents/guardians declare that the child is at least 13 years old before consenting.
  
  

Indonesia

• Age & Consent: You must be 21 years old, married, or not under guardianship.
  
  
  1. If under 21, unmarried, or under guardianship → you must obtain parental/guardian approval.
     
     
  2. Parents/guardians are responsible for compliance with this Privacy Policy and all actions of the minor.
     
     
• Withdrawal of Consent: you may request:
  
  
  1. Disclosure of personal data collected.
     
     
  2. Deletion/disposal of your personal data from our servers.
     
     
• Data Breach Notification: in the event of a personal data breach, CapReels will notify you and provide details.
  
  
• Data Retention: normally retained while providing services; in some cases, retained for 5 years (or longer if required by law or legal claims). After retention, data is anonymized.
  
  

Israel

• You declare that you are over 18 years old.
  
  
• If you are under 18, your parent/legal guardian must read and accept this Privacy Policy and Terms of Use for you to use CapReels.
  
  
• Parents/guardians declare that the child is at least 13 years old before use.
  
  

Mexico

• Data Controller: CapReels Pte. Ltd., 1 Raffles Quay, #26-10, South Tower, Singapore 048583.
  
  
• Purposes of Processing:
  
  
  • Primary: necessary for providing Services.
    
    
  • Secondary: personalized ads, surveys, better user experience. Users may opt out of secondary purposes in Settings.
    
    
• Sharing Data: may share personal data with third parties beyond processing — only with your consent.
  
  
• Language: Spanish version of this Privacy Policy prevails over English.
  
  
• User Rights (ARCO):
  
  
  • Access
    
    
  • Rectification
    
    
  • Cancellation
    
    
  • Objection
    
    
  • Consent Withdrawal
    
    
  • Limitation of use and disclosure
    
    
• Rights requests may be submitted via:
  
  
  • Online form: www.capreels.com/privacy/submit-your-request
    
    
  • Email: capreels.support@capreels.com
    
    
• If under 18, rights may be exercised by a parent/guardian.
  
  

Philippines

• User Rights: information, objection, access, rectification, erasure/blocking, damages, data portability, and the right to lodge complaints before the National Privacy Commission (NPC).
  
  
• Verification of identity/account details may be required before requests are processed.
  
  

Russia

• Legal grounds: consent, contract performance, legitimate interests, or legal obligations.
  
  
• Consent: by signing up and using Services, you consent to data processing under this Privacy Policy.
  
  
• Storage: personal data may be transferred to and stored in Malaysia and Singapore.
  
  
• Public profiles: consent is required for public distribution of data. Users may switch accounts to private in Manage My Account.
  
  

South Africa

• Users must be 18+.
  
  
• If under 18, a parent/guardian must read and agree to the Privacy Policy and Terms of Use.
  
  
• Parents/guardians confirm that the child is at least 13 years old.
  
  

South Korea

• Data Sharing: User Content (e.g., videos) may be used in ads/marketing campaigns.
  
  
• Personalized Ads: may be shown to users to keep Services free.
  
  
• Data Retention:
  
  
  • Order/payment records: 5 years
    
    
  • Consumer complaints: 3 years
    
    
  • Advertising records: 6 months
    
    
  • Website visit logs: 3 months
    
    
• Destruction: data deleted irreversibly when no longer needed.
  
  
• User Rights: access, rectification, deletion, suspension of processing.
  
  
• Transfers Abroad: data may be entrusted to affiliates, IT/cloud providers, some abroad. Users may opt out unless transfer is necessary to provide Services.
  
  
• Minors: Services not directed at children under 14.
  
  

Türkiye

• Legal Bases: processing required by law, contract necessity, legal obligations, public data, establishment/defense of rights, legitimate interests, or explicit consent.
  
  
• User Rights (per Article 11 of the Law No. 6698):
  
  
  • Learn whether data is processed.
    
    
  • Request details on processing.
    
    
  • Learn recipients of data transfers.
    
    
  • Request correction/deletion.
    
    
  • Object to automated decisions.
    
    
  • Claim compensation for damages.
    
    
• Requests processed within 30 days; free unless extra cost applies.
  
  
• Language: Turkish version prevails.
  
  
• Cookies: consent obtained unless exempt.
  
  

United Arab Emirates (UAE)

• By using Services in UAE, you consent to data processing and sharing under this Privacy Policy.
  
  
• Governing Law: UAE law.
  
  
• Dispute Resolution:
  
  
  • Small claims → DIFC Small Claims Tribunal.
    
    
  • Other disputes → mediation under DIFC-LCIA Rules, then arbitration in Dubai if unresolved.
    
    

United States

• Your Rights: may include right to know, access, portability, deletion, correction.
  
  
• Requests: via email capreels.support@capreels.com or mail to CapReels Pte. Ltd., Singapore.
  
  
• Authorized agents may submit requests with proof of authority.
  
  
• Parents/Guardians may exercise rights over teen accounts.
  
  
• Appeals: users may appeal decisions.
  
  
• Opt-Out of Sale/Sharing:
  
  
  • “Your Privacy Choices” in app settings.
    
    
  • Global Privacy Control (GPC) browser signal.
    
    
• Profiling: no profiling with significant effects.
  
  
• Sensitive Data: processed only for Services (e.g., payments, ID verification).
  
  
• Do Not Track: not supported.
  
  

Vietnam

• Age & Consent: must be 16+ or have parental/guardian approval.
  
  
• Parents/guardians are responsible for compliance if the user is under 16.
  
  
• If no consent is granted, underage users must stop using Services.