Vugola Privacy Policy

1. Introduction

This is the Privacy Policy of Vugola, a product of Vugola LLC ("Vugola," "we," "our," or "us"). Vugola provides an AI-powered video clipping and social media automation platform, helping creators transform long-form content into engaging short-form clips. This Privacy Policy explains how we process personal data of individuals who use our services, including our platform, websites, and other products and services ("Services").

At Vugola, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy.

Your use of Vugola's Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

Legal Entity: Vugola LLC
Contact: hello@vugolaai.com

2. Information We Collect

2.1 Account Information

When you create an account, we collect:

• Email address
• Name
• Password (stored securely using industry-standard encryption)
• Profile details you choose to provide

2.2 Social Media Connection Data

When you connect social media accounts for publishing, we collect:

• Account identifiers and usernames
• Profile information (such as display name and avatar)
• Authentication tokens (stored encrypted)
• Basic engagement metrics necessary to provide our Services

2.3 Content Data

To provide our video processing services, we collect:

• Videos you upload for processing
• Generated clips and outputs
• Captions, metadata, and transcripts
• Scheduling and posting preferences

2.4 Usage and Device Data

We automatically collect:

• Browser type and device information
• IP address and approximate location
• Usage patterns and feature interactions
• Performance and diagnostic data

3. How We Use Your Information

We process your personal data for the following purposes:

• Providing, maintaining, and improving our Services
• Processing videos and generating AI-powered outputs
• Scheduling and publishing content to connected platforms on your behalf
• Developing and enhancing our features and technology
• Ensuring platform security and preventing abuse
• Communicating with you about updates, support, and service-related matters
• Complying with legal obligations and enforcing our terms

3.1 Our Legal Bases for Processing (EEA, UK, and Switzerland)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we only process your personal data where we have a lawful basis to do so under the GDPR (and the UK GDPR). The basis depends on the purpose:

Where we rely on consent, you can withdraw it at any time without affecting processing carried out before withdrawal. Where we rely on a legitimate interest, you have the right to object, and you can contact us at hello@vugolaai.com to do so. We do not use your personal data to make decisions that produce legal or similarly significant effects about you without human involvement.

4. Data Security

Data security is of great importance to us. We implement appropriate technical, organizational, and administrative security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. Our security measures include:

• Encryption of data in transit using HTTPS/TLS
• Encryption of sensitive data at rest
• Secure storage on industry-leading cloud infrastructure
• Restricted access controls for personnel
• Regular security assessments and monitoring

While we work to protect your data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining appropriate safeguards.

5. Third-Party Services and Subprocessors

We work with trusted third-party service providers (also called subprocessors) to deliver our Services. Each provider acts on our instructions under a written contract, is permitted to process your data only for the purposes we specify, and may not use it for its own purposes. The table below lists the providers we currently rely on, what they process, and where they are primarily located.

Each category above may include one or more providers, each with its own privacy policy governing their handling of your data. We update these categories when our providers change. If you would like the names of the specific providers we currently use, contact us at hello@vugolaai.com.

5.1 Google API Services and YouTube

When you connect a YouTube channel, Vugola uses YouTube API Services to publish videos you create in Vugola to your own channel, to identify which channel you connected, and to show basic performance statistics for videos you published. By using Vugola's YouTube features, you agree to be bound by the YouTube Terms of Service.

Vugola's use of information received from YouTube API Services adheres to the Google API Services User Data Policy, including the Limited Use requirements. We access only your channel's identity (to confirm the connected account) and the public statistics of videos Vugola published; we use this data solely to provide the publishing and analytics features you request, and we do not sell or transfer it.

You can revoke Vugola's access to your YouTube data at any time by disconnecting the account in Vugola or through your Google security settings. To delete YouTube data stored by Vugola, disconnect the account or delete your Vugola account. We process Google user data in accordance with the Google Privacy Policy.

5.2 AI Processing of Your Content

To create clips, captions, and transcripts, the videos and audio you upload (and the transcripts generated from them) are processed by the third-party AI providers we engage for transcription and content analysis (the AI category described above). This processing is necessary to provide the Services you request.

We send these providers only the content and information needed to perform the task. We do not permit these providers to use your uploaded content, audio, or transcripts to train their own models, and we rely on the providers' API terms and our agreements with them, which provide that data submitted through their APIs is not used to train their models. We do not sell or transfer this content, and we do not use it to train any general-purpose AI model of our own. If you do not want your content processed by these providers, please do not upload it, because this processing is core to how the Services work.

6. Data Sharing

We do not sell your personal data, and we do not "share" it for cross-context behavioral advertising as those terms are defined under U.S. state privacy laws. We do not run third-party advertising on the Services.

We may disclose your information only in the following circumstances:

• With service providers and subprocessors who help us operate the platform (see Section 5), who act on our instructions under contract and may not use your data for their own purposes
• With our analytics providers, which act as our service providers to measure and improve the Services and are contractually restricted from using your data for their own purposes; where required, these run only after you consent through our cookie banner, and you can decline or withdraw consent at any time
• To the platforms you connect, when you ask us to publish or schedule content on your behalf
• With your explicit consent or at your direction
• To comply with applicable law, legal process, court orders, or governmental requests
• To protect the rights, privacy, safety, or property of Vugola, our users, or others, and to enforce our terms
• In connection with a merger, acquisition, financing, or sale of assets, with notice to you as required by law

To control non-essential analytics, use the cookie banner on our site, your browser settings, or, in the United States, a Global Privacy Control (GPC) signal, which we honor. You can also contact us at hello@vugolaai.com.

7. Your Rights and How to Exercise Them

Depending on where you live, you may have some or all of the following rights regarding your personal data. We honor these rights for every user where the law requires it, and we extend the core rights below to all users as a matter of practice.

• Access: Request a copy of the personal data we hold about you, and information about how we use and share it
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal data
• Portability: Request a copy of your data in a portable, machine-readable format
• Withdrawal: Withdraw consent by disconnecting accounts, opting out of tracking, or contacting us
• Objection: Object to or restrict certain processing of your data
• Opt-out: Opt out of targeted advertising, the sale or sharing of your personal information, and certain profiling (we do not sell your personal data or use it for cross-context behavioral advertising)

How to Submit a Request

To exercise any of these rights, email us at hello@vugolaai.com with the subject line "Privacy Rights Request" and tell us which right you want to exercise. You may also use the account controls and the "Your Privacy Choices" tools described in this Policy to manage your data and opt-outs directly.

Identity Verification

To protect your privacy and security, we will take reasonable steps to verify your identity before acting on a request. Verification usually means confirming that you control the email address associated with your account, and for sensitive requests we may ask for additional information to match you to the data we hold. We will only use information you provide for verification to verify your identity and respond to your request.

Authorized Agents

You may use an authorized agent to submit a request on your behalf. We may require the agent to provide proof that you gave them signed permission to act for you, and we may still ask you to verify your own identity directly with us or to confirm that you authorized the request.

Response Times

We will respond to your request within the timeframe required by applicable law. For most US state privacy requests this is within 45 days of receipt. When reasonably necessary, we may extend this period by an additional 45 days (90 days total) and will tell you within the first 45 days if we need the extension and why. For requests under the GDPR and UK GDPR, we will respond within one month, extendable by up to two further months for complex or numerous requests, and we will notify you of any extension.

Right to Appeal

If we decline to act on your request, we will explain why. If you live in a state that grants an appeal right (including Colorado, Connecticut, Texas, and Virginia), you may appeal our decision by replying to our response or by emailing hello@vugolaai.com with the subject line "Privacy Request Appeal." We will respond to your appeal within the period required by your state's law (generally 45 to 60 days) and explain the actions we take or do not take and the reasons for our decision. If we deny your appeal, you may contact your state Attorney General to submit a complaint.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not deny you our Services, charge you a different price, or provide you a different level of service because you exercised your rights.

8. Data Retention and Deletion

Retention Period

We retain your personal data for as long as necessary to provide our Services, fulfill the purposes described in this Privacy Policy, or as required by law. Specific retention periods are as follows:

• Account data: Retained for the duration of your account and up to 30 days after deletion request
• Uploaded videos and generated clips: Deleted within 30 days of account deletion or upon your request
• Payment and billing records: Retained for 7 years as required by financial regulations
• Usage and analytics data: Retained for up to 24 months, then anonymized or deleted
• Support communications: Retained for up to 2 years

When data is no longer needed, we securely delete or anonymize it.

How to Delete Your Account

To request deletion of your account and associated data:

1. Send an email to hello@vugolaai.com with "Account Deletion Request" as the subject
2. Include the email address associated with your account
3. We will process your request within 30 days

Upon account deletion:

• Personal data is removed within 30 days
• Uploaded videos and generated content are permanently deleted
• Aggregated, anonymized data may be retained for analytics
• Some data may be retained as required by law

9. Children's Privacy

Our Services are intended for users who are 18 years of age or older. The Services are not directed to children, and we do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a user under 18, we will terminate the account and delete that information promptly. If you believe a minor has provided us with personal data, please contact us at hello@vugolaai.com.

10. International Data Transfers

Vugola is based in the United States, and the providers listed in Section 5 are located primarily in the United States. If you access the Services from outside the United States, your personal data will be transferred to, stored, and processed in the United States and potentially other countries, which may have data protection laws different from those in your country.

When we transfer personal data from the European Economic Area, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, we rely on appropriate safeguards, including:

• The European Commission's Standard Contractual Clauses (SCCs), together with any supplementary measures needed, for transfers from the EEA
• The UK International Data Transfer Addendum to the SCCs (or the UK IDTA) for transfers from the United Kingdom
• The Swiss addendum to the SCCs for transfers from Switzerland
• Where a provider is certified under the EU-US Data Privacy Framework (and its UK Extension and Swiss-US Framework), reliance on that certification for transfers to that provider

You can request more information about these safeguards, including a copy of the relevant clauses, by contacting us at hello@vugolaai.com.

11. Cookies and Tracking Technologies

We use cookies and similar technologies (such as local storage and tracking pixels) to operate, secure, analyze, and improve our Services. We group these technologies as follows:

• Essential cookies: Maintain your session, keep you logged in, and protect the platform against abuse. These are strictly necessary for the Services to function and are always on.
• Preference cookies: Remember your settings and choices, such as your cookie-consent preference.
• Analytics and product cookies: Help us understand how visitors find and use the Services so we can improve them. We use a product analytics tool and, on parts of our site, session replay (which records pages, clicks, and navigation to help us diagnose issues and improve usability; we configure it to mask form inputs and sensitive fields). We also use a privacy-focused website analytics tool.

Your Cookie Choices

How non-essential cookies and trackers are handled depends on where you are:

• European Economic Area, United Kingdom, and Switzerland: When you first visit, we show a consent banner and we do not load our analytics tools (including session replay) until you give your prior opt-in consent. If you decline, those trackers stay off. You can change or withdraw your consent at any time by reopening the cookie settings from the banner or the link in our site footer; withdrawing consent stops future tracking.
• United States and other regions: We load analytics by default, but we respect opt-out preference signals. If your browser or extension sends a Global Privacy Control (GPC) signal, we treat it as a valid request to opt out of any sale or sharing of personal information and to turn off non-essential analytics and session replay for that browser. You can also opt out at any time through the cookie settings link in our footer or by using the "Your Privacy Choices" controls described below.

Essential cookies cannot be disabled because the Services will not work without them. Disabling non-essential cookies may affect some features.

For full details on the specific cookies and trackers we use, their purposes, and how to manage them, please see our dedicated Cookie Policy. For information about how we handle the personal data these technologies collect, the rest of this Privacy Policy applies.

12. Security Breach Notification

In the event of a data breach that affects your personal information, we will notify affected users and relevant authorities in accordance with applicable laws and regulations. We will provide information about the nature of the breach and steps you can take to protect yourself.

13. European Users (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR), including:

• Right to be informed about how your data is processed
• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Rights related to automated decision-making

To exercise these rights or lodge a complaint, contact us at hello@vugolaai.com. You also have the right to lodge a complaint with your local data protection authority.

14. US State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Texas, or Virginia, your state's privacy law gives you specific rights over your personal information. We honor these rights for all residents of those states. To exercise any of them, follow the process in Section 7 (Your Rights and How to Exercise Them), including identity verification, the authorized-agent path, our response timelines, and your right to appeal.

Your Rights

Subject to your state's law and certain exceptions, you have the right to:

• Know and access: Confirm whether we process your personal information and obtain a copy of it
• Correct: Request that we correct inaccurate personal information
• Delete: Request that we delete personal information we collected from you
• Portability: Obtain a copy of your personal information in a portable, readily usable format
• Opt out of targeted advertising: Direct us not to process your personal information for targeted advertising
• Opt out of sale or sharing: Direct us not to sell or share your personal information
• Opt out of certain profiling: Direct us not to use your personal information for profiling that produces legal or similarly significant effects
• Non-discrimination: Not be discriminated against for exercising these rights
• Appeal: Appeal our refusal to act on your request, as described in Section 7

California residents also have the right to limit the use of sensitive personal information. We do not use or disclose sensitive personal information for purposes that require us to offer a "limit" option under the CCPA/CPRA.

Do Not Sell or Share My Personal Information; Your Privacy Choices

We do not sell your personal information for money, and we do not share it for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA and the Colorado, Connecticut, Texas, and Virginia privacy laws. We also do not use your personal information for targeted advertising.

Because we do not sell or share personal information or serve targeted advertising, there is nothing for you to opt out of in those categories. Even so, we provide a "Your Privacy Choices" control through the cookie settings link in our website footer, where you can manage analytics and tracking preferences. We honor the Global Privacy Control (GPC) signal as a valid opt-out request from your browser, as described in Section 11 (Cookies and Tracking Technologies).

Categories of Information and How We Use It

The categories of personal information we collect, the purposes for which we use them, and the categories of recipients are described in Sections 2 (Information We Collect), 3 (How We Use Your Information), 5 (Third-Party Services), and 6 (Data Sharing) of this Privacy Policy. We collect this information from you directly, from your use of the Services, and from the social and content platforms you choose to connect.

How to Exercise Your Rights and Verification

To submit a request, email hello@vugolaai.com with the subject line "Privacy Rights Request," or use the controls described above. We will verify your identity and respond as described in Section 7. You may also designate an authorized agent to act on your behalf, subject to the verification steps in Section 7.

Appeal

If we decline to act on your request, you may appeal as described in Section 7 (Right to Appeal). If you are a Colorado, Connecticut, Texas, or Virginia resident and we deny your appeal, you may contact your state Attorney General to submit a complaint.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make material changes, we will notify you by email or through a prominent notice on our platform prior to the changes taking effect. Your continued use of our Services after such notice constitutes acceptance of the updated Privacy Policy.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Vugola LLC
Email: hello@vugolaai.com
Website: https://vugolaai.com

By using Vugola, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein.