01Introduction
This Privacy Policy explains how Neuroflix (“Neuroflix”, “we”, “us” or “our”) collects, uses, stores, shares and protects your personal data when you use our website, applications and services (the “Service”). It should be read together with our Terms of Service.
Using Neuroflix necessarily involves processing a real person’s face and voice to generate an AI version of them, so this policy gives that sensitive data particular attention. By using the Service, you acknowledge the practices described here.
02Who is responsible for your data
Neuroflix is the controller of the personal data processed through the Service. We are based in Singapore and handle personal data in line with the Singapore Personal Data Protection Act (PDPA), and, where they apply to you, the EU/UK General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA).
For any privacy question or request, contact us at general@neuroflix.sg.
03Information we collect
We collect the following categories of personal data:
- Account information. When you sign up, our authentication provider collects your name, email address and login credentials, and we store an account identifier to link your projects to you.
- Content you upload. Your speaking take (video and audio), reference photos of yourself, the scripts and details you type, and any optional closing clip you choose to add.
- Facial and voice data. Your photos and recordings contain biometric-type data, namely your facial imagery and the sound of your voice, which we process to generate your likeness. See the next section.
- Generated output. The images, clips, captions and finished videos created for you.
- Usage and device data. Limited technical information such as IP address, browser and device type, pages viewed, and product interactions, collected to operate, secure and improve the Service.
04Facial and voice data
To create your video, we process the face and voice contained in your uploads. Depending on your jurisdiction, this may be treated as sensitive or special-category personal data. We rely on your explicit consent as the legal basis for processing it, which you give when you upload your content and confirm you have the right to do so.
We only process a face and voice you consent to.
When you upload, you confirm the person shown is you, or a real adult who has personally given you permission to make an AI version of them. We use that facial and voice data solely to generate your video.
We do not use your likeness to build facial-recognition systems, sell it, or train our own or third parties’ foundation models on it. You can withdraw consent and delete this data at any time, as described in your rights below.
Responsibility for obtaining any third party’s consent rests with you, as set out in the Terms of Service.
05How we use your information
We use personal data to:
- provide the Service: generate, edit, caption, render and deliver your videos from the inputs you give us;
- create and secure your account and authenticate your access;
- operate, maintain, debug and improve the Service, and analyse aggregate, non-identifying usage trends;
- communicate with you about the Service, including service notices and support;
- enforce our Terms, prevent abuse and misuse, and comply with legal obligations.
We do not use your uploaded content or likeness to train our own generative models.
06Our legal bases
Where the GDPR applies, we rely on: your consent for processing facial and voice data and any optional communications; performance of a contract to provide the Service you request; legitimate interests in operating, securing and improving the Service (balanced against your rights); and legal obligation where the law requires us to retain or disclose data. Under the PDPA, we collect, use and disclose personal data with your consent and for purposes a reasonable person would consider appropriate. You may withdraw consent at any time.
07AI processing and model providers
The generation itself is performed by third-party AI providers. To create your video, your inputs, including your recording, photos and prompts, are transmitted to these providers strictly so they can produce the requested output. We share only what is needed for generation, and we do not permit your inputs to be used to train their foundation models for their own purposes, to the extent their terms allow us to control this. Their handling of data is also governed by their own privacy terms.
08Service providers we use
We rely on a small set of trusted providers who process data on our behalf, under contractual confidentiality and security obligations:
- Authentication: to manage sign-up, login and account security.
- Storage and database: to store your uploads, generated assets and project data.
- AI generation: to generate the speaking clips, pose images and cutscene animation.
- Transcription: to align your speech to the script and produce captions.
- Hosting, background processing and rendering: to run the application and render the final video.
- Product analytics: to understand aggregate usage and improve the Service.
These providers act as our processors and may process data in locations outside your country, subject to the safeguards described below.
10Data retention and deletion
We keep personal data for as long as your account is active or as needed to provide the Service, and afterwards only as long as necessary for the purposes described here, to comply with legal obligations, resolve disputes and enforce our agreements. You can delete individual projects and their uploads, or your entire account, at any time. When you do, we delete or de-identify the associated personal data within a reasonable period, except for limited copies retained in routine backups for a short time or where retention is legally required.
11How we protect your data
We use technical and organisational measures appropriate to the sensitivity of the data, including encryption in transit, access controls that scope your data to your account, and reputable infrastructure providers. No method of transmission or storage is completely secure, so we cannot guarantee absolute security; if we become aware of a breach affecting your personal data, we will notify you and the relevant authorities as required by law.
12International data transfers
We and our providers may process and store personal data in countries other than your own, which may have different data-protection laws. Where we transfer personal data internationally, we put appropriate safeguards in place, such as standard contractual clauses or transfers to jurisdictions recognised as providing adequate protection, and take reasonable steps to ensure your data remains protected to a comparable standard.
13Your rights and choices
Subject to applicable law, you may have the right to:
- access the personal data we hold about you, and request a copy;
- correct inaccurate or incomplete data;
- delete your data, including your facial and voice data;
- withdraw consent at any time (without affecting processing already carried out);
- object to or restrict certain processing, and request portability of data you provided;
- opt out of the “sale” or “sharing” of personal data (note that we do not sell your data).
To exercise any of these, email general@neuroflix.sg. We will respond within the timeframe required by law and may need to verify your identity first. You also have the right to lodge a complaint with your local data-protection authority.
15Children’s privacy
The Service is not intended for anyone under 18, and we do not knowingly collect personal data from minors or permit the creation of content depicting a minor. If you believe a minor has provided us with personal data, contact us and we will delete it.
16Changes to this policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the “last updated” date above and, where appropriate, provide additional notice. Your continued use of the Service after the changes take effect means you accept the updated policy.
17Contact us
Questions, concerns or requests about your privacy? Reach us at general@neuroflix.sg.