Vugola Privacy Policy

Introduction

This Privacy Policy explains how Vugola LLC ("Vugola," "we," "our," or "us") collects, uses, shares, and otherwise processes personal information in connection with our websites, apps, and other products and services (the "Services"). It applies to visitors, account holders, and anyone who interacts with the Services.

By accessing or using the Services, you accept this Privacy Policy. If you do not agree, do not use the Services. Your use of the Services is also subject to our Terms of Service, which incorporate this Privacy Policy.

Some information is required for the Services to work. Other information is optional, but without it the quality of your experience may be affected. We may collect information about you even if you do not have an account, and we may combine information from different sources and infer information from it.

Legal Entity: Vugola LLC
519 W 22nd St Ste 300, PMB 687635
Sioux Falls, SD 57105-1745, USA
Contact: hello@vugolaai.com

1. Information We Collect

The information we collect depends on how you use the Services. It includes the categories below, and we may collect additional information we describe to you at the point of collection.

1.1 Information you provide

• Account information, such as your email address, name, username, password, profile details, language, region, and preferences
• Content you upload, record, create, or share, such as videos, audio, clips, captions, transcripts, titles, descriptions, thumbnails, and related metadata
• Communications, such as support requests, reports, feedback, survey answers, and any attachments
• Payment and subscription information, such as plan, dates, transaction IDs, billing details, and a card identifier from our payment processor. We do not receive your full card number
• Information you provide about other people, such as a referral or team member email address

1.2 Information from third parties

• Social platforms you connect, such as account identifiers, usernames, profile details, avatars, authentication tokens, and basic engagement metrics
• Payment processors, app stores, and subscription providers, such as subscription status, purchase events, and transaction details
• Analytics, advertising, measurement, and affiliate partners, such as campaign data, attribution data, and aggregate reporting
• Service providers that help us operate the Services
• Public sources, business partners, and other users, such as when someone invites you to a workspace

1.3 Information collected automatically

• Device and browser information, such as browser type, operating system, device model, app version, language, time zone, and screen size
• Network information, such as IP address and approximate location derived from it, including country, region, and city
• Usage information, such as pages viewed, features used, controls tapped, settings chosen, session duration, referral source, campaign tags, and creator referral codes
• Diagnostic information, such as errors, crash reports, performance data, and logs
• Cookies, pixels, local storage, SDKs, and similar technologies, as described in our Cookie Policy

1.4 Content and AI processing

We collect the videos, audio, images, text, and other content you submit, and the clips, captions, transcripts, titles, insights, and other outputs we generate from them. We may process this content with third-party AI providers and with our own systems, as described in Section 6.

1.5 Social media connections

When you connect a social media account, we receive the information that platform makes available to us, such as your account identifiers, username, profile information, authentication tokens, and engagement metrics. We use this information to publish and schedule content on your behalf and to show you basic performance statistics.

1.6 Website analytics, recordings, and email

We use product analytics, website analytics, masked session recordings of signed-in use, help video statistics, error monitoring, and email delivery tools. These tools may record pages viewed, features used, actions taken, referral source, campaign tags, creator referral codes, approximate location, device type, and whether emails were delivered, opened, or clicked. On the web, all on-screen text and typed input in session recordings are generally masked; in the app, typed input, images, and video are generally masked. Media is generally not recorded. Some analytics and error-monitoring requests may be routed through our own domain before they reach the provider. See Section 5 and our Cookie Policy for the controls that apply.

1.7 iPhone app

When you use our iPhone app, we also collect and use the following:

• Sign-in. Your email address and password, or Sign in with Apple or Google. With Apple, we ask only for your email address, and Apple may give us a private relay address instead.
• Videos you add. The videos you select or record, including details your iPhone stores with them, such as when and where they were recorded. If you use AI Edit, your video, audio, and transcript are processed as described in Section 6.
• Purchases. Apple processes App Store payments. We and our subscription provider receive subscription details, plan, dates, transaction IDs, and basic device details, linked to your Vugola account ID.
• Website checkout. If your App Store country or region is the United States, the app can open our website checkout. We receive your App Store country or region, a random install ID, your checkout choices, the email address you give, and a card identifier from our payment processor. We use this to stop repeat free trials and attach the purchase to the right account.
• Notifications. If you allow notifications, Apple gives us a device token, which we store with your account. Notifications may include your project name.
• Reports and requests. When you send a report or feature request, we receive what you write, any screenshots or photos you attach, and technical details such as app version, device model, operating system, language and region, the screen you were on, your project and upload status, any error on screen, and the layout of the edit you had open.
• Usage statistics and recordings. The app sends us statistics about how you use it, such as screens reached, controls tapped, answers chosen, settings used, timing, success, app opens, videos created, streak, notification choices, and responses to reminders, along with your IP address, approximate location, device details, and a random install ID. We also record masked session replays. After you sign in, this data is tied to your account and to the email address and name on your account. It generally does not include your videos, captions, titles, or typed text. Our analytics and crash-reporting providers process it for us as service providers. We may de-identify it and use the de-identified data for any lawful business purpose. We keep statistics for up to seven years and recordings for up to 90 days. Statistics and recordings are on for everyone, in every country, unless you turn them off in Settings > Share usage data.
• Ad measurement. We advertise Vugola through Apple Ads, Meta, TikTok, and other partners, and the app helps us measure and improve those ads.
• Apple Ads. The app collects Apple Ads' attribution token and uses it as an analytics signal, not as campaign attribution.
• Measurement provider and ad partners. Once you update the app, the app includes code from our mobile measurement provider, which is the only advertising code in the app. When you install and open the app, create an account, or start a free trial, that code tells our provider. It sends an install ID, device and app details, and your IP address. Our subscription provider also sends App Store trial and subscription events, plan, price, and your Vugola account ID to our measurement provider. The provider passes our ad partners, including Meta and TikTok, the results they need to measure and improve our ads. Meta and TikTok use what they receive under their own terms and privacy policies.
• Apple's reports. Apple may also send our ad partners SKAdNetwork and AdAttributionKit reports, which say that an ad led to an install or event without saying who you are.
• What is not included. Ad measurement generally does not include your videos, captions, titles, typed text, name, email address, or your device's advertising identifier. The app currently does not ask for Apple's permission to track you and does not show ads.
• Your choice. Once you update the app, if your App Store country or region is the United States, ad measurement is on by default. Otherwise it starts off, and the app shares nothing for ad measurement unless you turn it on. You can turn it on or off at any time in Settings > Ad measurement. Turning it off stops new ad measurement events and stops our subscription provider from passing your App Store events to our measurement provider. When you are signed in, we save your choice with your account. Turning it off applies on every iPhone with the updated app where you sign in, after the app refreshes your session or you next sign in. Turning it on applies only to the iPhone where you turn it on. It does not recall information already sent and does not change Apple's own reports. Some U.S. state privacy laws treat this as "sharing," "selling," or "targeted advertising." Section 12 explains your rights. In earlier app versions, the switch is called "Information collection" and controls only the Apple Ads token.
• Your streak. When you are signed in, we keep a copy of your streak with your account, including the days and times you exported a video, a random project ID, video length, whether the video used captions or AI Edit, and badges earned. It generally does not include your videos, titles, or caption text. Deleting your account deletes it.
• Stored on your iPhone. Your projects, edits, settings, sign-in session, and profile photo stay on your iPhone. When you save a name or username, we keep it with your account. Signing out does not erase videos saved on your iPhone.

2. How We Use Information

We may use information we collect for the following purposes and for any other purpose we describe to you:

• Providing, operating, maintaining, securing, and improving the Services
• Processing videos and generating clips, captions, transcripts, insights, and other outputs
• Scheduling and publishing content to connected platforms on your behalf
• Personalizing features, content, recommendations, reminders, and your experience
• Developing, testing, evaluating, training, fine-tuning, and improving our models, algorithms, and Services
• Measuring, analyzing, and understanding how the Services are used, including through analytics, recordings, and reporting
• Communicating with you about the Services, support, updates, security, billing, and product or marketing offers
• Measuring and improving our advertising, including telling our measurement provider and ad partners which ads led to installs, sign-ups, trials, and subscriptions
• Attributing referrals and calculating creator or affiliate commissions
• Protecting the rights, privacy, safety, and property of Vugola, our users, and others, and preventing fraud, abuse, and security issues
• Complying with legal obligations, responding to legal requests, and enforcing our terms
• Evaluating or completing a merger, acquisition, financing, reorganization, or sale of assets
• Any other lawful business purpose

We may use information across our products, devices, and Services, and combine it with information from third parties. We may use de-identified or aggregated data for any lawful purpose, including analytics, research, benchmarking, product development, marketing, commercial partnerships, and training AI models, without payment to you. De-identified data is not personal information under this Policy.

We may use your name, logo, and trademarks to identify you as a customer on our website and in marketing materials. You may opt out by emailing hello@vugolaai.com.

3. Legal Bases for Processing (EEA, UK, and Switzerland)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process personal data only where we have a lawful basis. 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. We do not use your personal data to make decisions that produce legal or similarly significant effects about you without human involvement, unless we tell you otherwise.

4. How We Share Information

We do not sell your personal information for money. We may share information in the circumstances below, and under some laws our ad measurement may count as "sharing," "selling," or "targeted advertising." You can opt out as described in Section 12.

• Service providers and subprocessors. We use providers for hosting, databases, storage, compute, video processing, payments, AI transcription and analysis, analytics, error monitoring, video hosting, font delivery, affiliate tracking, mobile measurement, subscription management, email delivery, and other operations. They process information on our behalf or as otherwise described in their policies. We may add, remove, or replace providers in our sole discretion. The categories in this Policy are illustrative and not exhaustive.
• Affiliates. We may share information with our affiliates, subsidiaries, and related entities.
• Ad partners and measurement providers. We may share information with Meta, TikTok, Apple, our mobile measurement provider, and other advertising and measurement partners to measure and improve our ads, as described in Section 1.7. They may use what they receive under their own terms and privacy policies.
• Platforms you connect. When you ask us to publish or schedule content, we share information with the platforms you connect.
• Business partners and referral partners. We may share information with creators, affiliates, and promotion partners to attribute referrals and calculate commissions.
• Corporate transactions. We may share information in connection with a merger, acquisition, financing, reorganization, or sale of assets, with notice to you where required by law.
• Legal and safety. We may share information to comply with 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.
• With your consent or direction. We may share information when you ask us to.
• Public content. Content you share publicly may be visible to others and to third parties, including search engines and scrapers.
• De-identified and aggregated data. We may share de-identified or aggregated data with anyone for any lawful purpose.

Our ad partners, Meta and TikTok, are not our service providers for ad measurement. They use what they receive under their own terms. Section 1.7 explains what they receive.

5. Cookies and Similar Technologies

We use cookies, local storage, pixels, SDKs, and similar technologies to operate, secure, analyze, and improve the Services. We group them as strictly necessary, preference, analytics, and affiliate referral cookies. Our website currently does not use cross-context behavioral advertising cookies or advertising pixels, and we do not currently show third-party ads in the Services. The iPhone app does not use cookies. Our Cookie Policy explains the categories, when analytics run, and how to manage your choices.

Where local law requires prior consent, analytics cookies, session recordings, and our website analytics tool run only after you accept. Where we rely on notice and opt-out, they run by default and you can turn them off through "Cookie settings." We honor Global Privacy Control where required by law. We do not use Do Not Track as an opt-out signal. Affiliate referral tracking applies in every region and is not controlled by the cookie banner, "Cookie settings," or GPC. Our emails record delivery, opens, and clicks, including through a small tracking pixel.

For full details, see our Cookie Policy.

6. AI Processing of Your Content

To create clips, captions, transcripts, and other outputs, we process your videos, audio, images, text, and related content using our own systems and third-party AI providers. This processing is core to the Services.

What we send. We may send private copies of your videos, audio, and transcripts to AI providers for transcription, content analysis, scene detection, framing, captioning, and similar tasks. For visual analysis in Studio, we delete the temporary copies right after the analysis.

How we use it. We may use your Content, outputs, and Usage Data to operate, test, evaluate, train, fine-tune, and improve our models and the Services. We may also use de-identified or aggregated data for any lawful purpose. Our third-party AI providers process your Content to provide the Services under our agreements with them and their own terms. We do not control their independent practices. You retain ownership of your Content, subject to the license in our Terms of Service.

If you do not want your Content processed by these providers, do not upload it. AI outputs may be inaccurate, may not be unique, and should be reviewed before you publish them.

7. Your Rights

Depending on where you live, you may have some or all of the following rights:

• Access: request a copy of the personal information we hold about you and information about how we use and share it
• Correction: request correction of inaccurate or incomplete information
• Deletion: request deletion of your personal information
• Portability: request a copy in a portable, machine-readable format
• Withdrawal: withdraw consent by disconnecting accounts, changing your settings, or contacting us
• Objection: object to or request restriction of certain processing
• Opt-out: opt out of targeted advertising, the sale or sharing of personal information, and certain profiling
• Non-discrimination: we will not discriminate against you for exercising your rights
• Appeal: appeal our refusal to act on your request where required by law

These rights are not absolute. We may refuse a request where permitted by law, including if we cannot verify your identity, if the request would affect another person's rights, if the request would interfere with the Services, or if we need to keep the information for a legal or legitimate reason.

To exercise a right, email 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 "Cookie settings" described in this Policy and the Cookie Policy. We may take reasonable steps to verify your identity. You may use an authorized agent, and we may require proof that the agent is authorized to act for you. We will respond within the time required by applicable law. If we deny your request, we will explain why, and you may appeal where your state or country provides an appeal right.

8. Retention and Deletion

We retain personal information for as long as necessary to provide the Services, fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, enforce our agreements, and protect our rights. Retention periods vary based on the type of information, the Service, legal requirements, and our operational needs.

• Account data: generally for the life of your account and for a reasonable period after deletion, including backups
• Uploaded videos and generated content: generally for the life of your account and for a reasonable period after deletion, including backups. Videos uploaded from the iPhone app are kept in your account even after a subscription ends, until you delete them or your account
• Payment and billing records: typically up to seven years, as required for tax, accounting, and dispute purposes
• Checkout records for plans started on our website from the iPhone app: kept as long as needed to stop repeat free trials and fraud and to meet legal and accounting duties, including checkouts never linked to an account and after account deletion
• Usage and analytics data: our own usage data typically up to 24 months; event data held by our analytics provider typically up to seven years; session recordings typically up to 90 days
• Ad measurement data: kept by our providers for the period set by our agreements and their policies
• Support communications: typically up to two years
• De-identified and aggregated data: may be retained indefinitely

When information is no longer needed, we delete or de-identify it. We may retain information longer in backups, legal holds, and records required by law. We aim to remove account data, owned workspaces, uploaded videos, and generated content within 30 days after a successful deletion request, subject to backups, legal retention, and technical limitations. You can request account deletion in the iPhone app from Settings > Delete account, on our website from Settings > Account > Security > Delete account, or by emailing hello@vugolaai.com. Deleting your Vugola account does not cancel an App Store subscription; cancel it separately in iPhone Settings > your name > Subscriptions.

9. Security

We use reasonable technical, organizational, and administrative measures to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. These measures include encryption in transit, encryption of sensitive data at rest, access controls, and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach affects your personal information, we will notify affected users and relevant authorities as required by applicable law.

10. International Transfers

Vugola is based in the United States, and our providers are located primarily in the United States and other countries. If you access the Services from outside the United States, your information may be transferred to, stored, and processed in the United States and other countries whose data protection laws may differ from those in your country.

When we transfer personal data from the European Economic Area, the United Kingdom, or Switzerland to a country without an adequacy decision, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, the Swiss addendum, and, where applicable, the EU-US Data Privacy Framework and its UK and Swiss extensions. You can request more information by contacting hello@vugolaai.com.

11. Children

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

12. US State Privacy Rights

Residents of states with comprehensive privacy laws may have some or all of the following rights: to know and access, correct, delete, obtain a portable copy, opt out of targeted advertising, opt out of the sale or sharing of personal information, opt out of certain profiling, and not be discriminated against for exercising these rights. You may also have the right to appeal our refusal to act on a request. To exercise a right, follow the process in Section 7.

We do not sell your personal information for money. Once you update the iPhone app, if your App Store country or region is the United States, the app shares ad measurement information with Meta and TikTok through our measurement provider, as described in Section 1.7. Under some state laws, that can count as "sharing," "selling," or "targeted advertising." In the last 12 months we have shared, or may share, these categories with advertising networks: identifiers (an install ID and IP address), commercial information (trials and subscriptions), and internet or other electronic network activity (installs, app opens, and sign-ups), together with device and app details. Our website currently does not sell or share personal information for advertising. We do not knowingly sell or share the personal information of anyone under 16.

How to opt out. In the iPhone app, turn off Settings > Ad measurement (in earlier app versions, Settings > Information collection). When you are signed in, we save your choice with your account. You can also email hello@vugolaai.com with the subject line "Do Not Sell or Share" from the email address on your account, and we will turn ad measurement off for your account. In the updated app, it takes effect the next time the app refreshes your session or you next sign in. Earlier app versions do not read the choice saved with your account; in them, turn off Settings > Information collection. Opting out stops new sharing; it does not recall information already shared, which our ad partners handle under their own policies. You can still turn off our website analytics at any time through "Cookie settings." GPC is a browser signal, so the iPhone app cannot receive it. On our website, a GPC signal does not turn off our own analytics in the United States, and we do not use Do Not Track as an opt-out signal. If our website ever sells or shares personal information or uses it for targeted advertising, we will honor GPC as a valid opt-out.

California residents also have the right to limit the use of sensitive personal information. We currently do not use or disclose sensitive personal information for purposes that require us to offer a "limit" option. We collect the categories of personal information described in Section 1 from you, from your use of the Services, and from the platforms and providers you interact with. We use them for the purposes in Section 2 and share them with the categories of recipients in Section 4. You may designate an authorized agent to act for you, subject to verification.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The posted version controls. A change takes effect when we post the updated Policy with a new effective date, unless the Policy says a later date. When a change is material, we may tell you by email or through a prominent notice on our platform. Using the Services after a change means the updated Policy applies to you.

14. Contact Us

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

Vugola LLC
519 W 22nd St Ste 300, PMB 687635
Sioux Falls, SD 57105-1745, USA
Email: hello@vugolaai.com
Website: https://vugolaai.com

Reports and requests sent from the iPhone app go to support@vugolaai.com.

15. 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 your connected channel's identity and profile information, subscriber count, and recent uploads, including videos published outside Vugola. For these videos, we access metadata such as titles, thumbnails, publication dates and duration, together with available view, like and comment counts. We use this information 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.

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