1. Data Controller
The data controller responsible for processing your personal data is BrainCode Sp. z o.o., ul. Floriańska 6/2, 03-707 Warszawa, Poland.
You may contact us at legal@braincode.xyz regarding this Privacy Policy or your data protection rights.
2. Data We Collect
We may collect the following categories of data:
- Account data (name, email).
- Uploaded Content and Generated Content: This includes uploaded video files (which may contain images, personal data, or voices), input text scripts/prompts (which may contain personal or confidential information), and the final generated video file (including the AI voiceover and subtitles).
- Usage data (pages visited, features used, minutes of content generated).
- Device/technical data (IP address, browser type).
- Communications with us (support requests, feedback).
We do not intentionally collect special categories of data. Please avoid uploading sensitive information unless necessary.
3. Purposes and Legal Bases
We process personal data for: (a) providing and improving the Services, including the processing of video and text to generate the final product (performance of contract), (b) account management and customer support (performance of contract/legitimate interests), (c) analytics and service enhancement (legitimate interests), (d) communications and notices (performance of contract/legitimate interests), and (e) compliance with legal obligations.
Where required, we rely on your consent (e.g., for certain cookies or marketing). You can withdraw consent at any time without affecting prior lawful processing.
4. Processing of Uploaded Content and AI Models
We store the uploaded video files and text scripts to facilitate the voiceover and subtitle generation process, and the final generated content is stored for your access until you delete it.
Crucially, we do not use the uploaded video files or input text scripts/prompts to train, enhance, or improve our proprietary artificial intelligence models or related technologies. Your content is used solely for the purpose of fulfilling the specific service request (generating the requested video).
5. Data Sharing and Processors (Third-Party AI)
We do not sell your personal data. We may share data with trusted service providers (processors) who support hosting, analytics, and customer support, subject to data processing agreements and appropriate safeguards.
Third-Party AI Processors: To deliver the core Services, we rely on external AI services. The input text scripts (prompts) and the uploaded video files are securely transferred to third-party Large Language Models (LLM) and voice generation platforms, including services like Google Gemini and ElevenLabs, solely for the purpose of processing your request (generating voice, subtitles, and syncing). These third-party processors are bound by confidentiality agreements or their own privacy policies which prevent them from using your content for training their models.
We may disclose data if required by law, court order, or to protect our legal rights and the security of users.
6. International Transfers
Since we utilize services like Google Gemini and ElevenLabs, personal data (specifically, your input text/prompts and video metadata) may be transferred and processed outside the EU/EEA. We ensure suitable safeguards, such as reliance on their respective data transfer mechanisms (e.g., European Commission Standard Contractual Clauses), to ensure your data receives protection equivalent to the GDPR.
7. Data Retention
We retain personal data, including your uploaded video files, input text, and final generated video content, only as long as necessary for the purposes described herein or as required by law.
Retention of Content: Your uploaded and generated video content will be retained on our active systems until you specifically delete the file(s) from your account or until your account is deleted.
Upon account deletion, all associated data is removed from active systems; residual backups may persist temporarily and are then securely deleted.
8. Your Rights
Subject to applicable law, you have the right to access, rectify, erase, restrict processing, object to processing, and data portability. You also have the right to withdraw consent at any time, where consent is the legal basis.
You may lodge a complaint with your local supervisory authority. In Poland, this is the President of the Personal Data Protection Office (UODO).
9. Security
We implement technical and organizational measures appropriate to the risk, including encryption in transit, access controls, and secure storage. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
10. Cookies and Analytics
We use cookies and similar technologies for essential functionality, analytics, and to improve the user experience. Where required, we obtain your consent. You can manage cookies through your browser settings.
11. Children’s Data
The Services are intended for users aged 18 and above. We do not knowingly collect personal data from children.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via the site or email. Your continued use of the Services after changes take effect constitutes acceptance of the updated policy.
13. Contact
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at legal@braincode.xyz.