DuoCreator App and Website Privacy Policy

This policy explains how [LEGAL_NAME], trading as [TRADING_NAME] (“DuoCreator”, “we”, “us”, or “our”) handles personal data in connection with the DuoCreator iOS app, the DuoCreator product pages under [DOMAIN]/apps/duocreator/, and support or privacy communications.

Operator

[LEGAL_NAME], trading as [TRADING_NAME]

Legal form

[ENTITY_TYPE]

Established in

[COUNTRY_OF_ESTABLISHMENT]

Address

[REGISTERED_ADDRESS]

Support

[SUPPORT_EMAIL]

Privacy

[PRIVACY_EMAIL]

Telephone

[PHONE]

Data protection contact: [DPO_OR_PRIVACY_CONTACT]

EU representative: [EU_REPRESENTATIVE]

UK representative: [UK_REPRESENTATIVE]

This policy does not govern Apple's independent processing through the App Store, Apple Account, payment, device, operating system, Photos, share sheet, Speech, Apple Intelligence, or other Apple services. Apple's policies and your device settings apply to that processing.

Version 1.0 is designed around local processing and storage. We do not operate an account system or app backend and do not receive a copy of your scripts, projects, recordings, chosen images, generated text, contacts, identifiers, precise location, payment data, or usage history from the app.

Data that remains only on your device and is never transmitted to us is not collected by us. It can still be sensitive to you, so the app uses system permissions and local security protections and gives you deletion and export controls.

Camera and microphone. When you open recording features and grant permission, the app accesses camera video and microphone audio to preview and record a take. A visible recording state and timer are shown. Takes are saved in the app's local container. We do not receive the feed or recording.

Scripts, projects, takes, and settings. The app stores these locally using Apple's app storage technologies. They remain under your device and backup settings. Deleting an item in the app removes the app's managed copy, subject to normal operating-system storage behaviour. Deleting the app generally removes its local container; exported copies and device backups may remain until separately deleted.

Photos and image context. You may deliberately select images through Apple's Photos picker, up to the number the interface offers. The app loads only the selected items for the requested task. Apple's Vision APIs may extract visible text and tentative image classifications on device, and the results can be used as context for script generation. Classifications are probabilistic and should not be treated as verified facts. The app uses add-only Photos permission when you ask to save an export.

AI scripts. When available, DuoCreator uses Apple's Foundation Models to generate or transform scripts. The app does not send the prompt, selected-image context, current script, or generated response to a developer-operated server. The model can make mistakes; review output before use. If a future version introduces remote AI processing, this policy and the App Store disclosure will be updated before release.

Speech recognition. Voice Idea and Voice Follow use Apple's Speech framework after you grant microphone and speech-recognition permissions. Depending on device capability, language, region, system settings, and Apple service availability, Apple may process audio or recognition data on device or through Apple services. We do not receive that audio or transcript through our own backend. You can avoid this processing by not using voice features and can change permissions in iOS Settings.

Exports and sharing. Nothing is exported until you choose to save to Photos or open an Apple share sheet. The destination you select may process the content under its own privacy terms. We do not control third-party apps or services you choose.

Development simulator. A simulator-only demo can create black video with microphone audio to allow development testing without a physical camera. This is not remote collection and is not a production-device feature.

The app may request:

• Camera: to preview and record video.
• Microphone: to record audio and capture spoken ideas.
• Speech recognition: to transcribe a spoken idea and support optional Voice Follow.
• Photos (add-only): to save an export you select.
• Photos selection: through Apple's picker, to use only images you choose.

Permissions are controlled in iOS Settings. Refusing or revoking a permission may disable the related feature but should not prevent use of unrelated features.

The website is operationally separate from the local-only app. The following limited data may be processed:

• Connection and security logs: IP address, date and time, requested URL, user agent, response status, and security events may be processed by [WEBSITE_HOST] and [CDN_OR_SECURITY_PROVIDER] to deliver, protect, diagnose, and maintain the site.
• Launch waitlist: if you join the DuoCreator waitlist, we store your email address, the app you asked about, and the signup time with [DATABASE_PROVIDER], only to tell you when DuoCreator is available.
• Support and privacy messages: if you email us, we receive the contact details and message content you choose to send. [CONTACT_FORM_PROVIDER] and [EMAIL_PROVIDER] may process the message on our behalf.
• Analytics: the website uses [ANALYTICS_PROVIDER] to count page views in aggregate (page, referrer, country, device type). It does not set cookies and is not used to identify or track you across sites.

Do not send recordings, confidential scripts, health information, government identifiers, payment-card data, or information about another person through ordinary support email unless necessary and a secure channel is offered.

Where the EU/EEA or UK GDPR applies, we rely on:

• Contract or pre-contract steps: answering support questions, providing purchased-app support, and administering complaints.
• Legitimate interests: securing and operating the website, preventing abuse, diagnosing faults, and maintaining appropriate business records, balanced against your rights.
• Legal obligation: tax, accounting, regulatory, court, consumer-protection, and data-rights duties.
• Consent: the launch waitlist and any future optional marketing or non-essential cookies. Consent can be withdrawn as easily as it was given.

Local app content that never reaches us is not processed by us as controller. Apple and destinations you select determine their own legal bases for independent processing.

Where Canada's PIPEDA, Brazil's LGPD, or substantially similar laws apply, we process only for the stated purposes and honour the rights and accountability rules that apply to us. Where California or another U.S. state privacy law applies, we provide the disclosures and rights required for the actual categories and uses; we do not claim a law applies merely because a user lives there.

Website and support data comes directly from you, your browser or device, the hosting and security infrastructure, and Apple where Apple provides a developer support or purchase-related record. Categories can include identifiers and contact data, internet or network activity, correspondence, coarse location inferred from IP for security, and commercial support context. We do not ask for sensitive data as a normal condition of support.

We disclose personal data only as needed to:

• the hosting, database, security, email, and analytics providers listed below;
• professional advisers bound by duties of confidentiality;
• authorities or courts when lawfully required;
• a successor in a genuine merger, acquisition, reorganisation, or asset transfer, subject to lawful safeguards;
• Apple or a service you select when you initiate that interaction.

Current service providers

We do not sell personal data. We do not share personal data for cross-context behavioural advertising. There are no advertising providers. We do not use app content to train our own or a third party's general-purpose AI model.

Website and support providers may process data outside your country, including in the United States. Where transfer restrictions apply, we rely on a lawful mechanism such as an adequacy decision (including the EU-U.S. Data Privacy Framework where the provider is certified) or approved contractual clauses, and we provide information on request.

• Local app data remains until you delete it, delete the app, or the operating system manages it. We cannot remotely retrieve or erase data we never receive.
• Launch-waitlist emails are retained [DATA_RETENTION_WAITLIST]. You can ask to be removed at any time.
• Support and privacy correspondence is retained for [DATA_RETENTION_SUPPORT], then deleted or de-identified unless needed longer for a legal claim, legal obligation, fraud prevention, or an unresolved request.
• Security logs are retained for [SECURITY_LOG_RETENTION].
• Consent records are retained for [CONSENT_RETENTION] so choices can be demonstrated and honoured.
• Accounting and transaction records available to us are retained as required by applicable tax and commercial law.

We use reasonable organisational and technical measures appropriate to the data we actually handle. The app benefits from Apple's app sandbox and device protections. The website uses HTTPS, restricted administrative access, and maintained dependencies. No system is risk-free, and we do not promise absolute security.

Depending on your location and applicable law, you may have rights to information, confirmation, access, correction, deletion, restriction, objection, portability, withdrawal of consent, and review of certain solely automated decisions. California residents may have rights to know, correct, delete, limit certain sensitive-data uses, and opt out of sale or sharing where the statutory scope and thresholds apply. Canadian users may have rights of access and correction and may challenge our compliance under PIPEDA or applicable provincial law. Brazilian, Australian, Japanese, and other users may have additional rights under applicable law.

Submit a request through Your Privacy Choices or email [PRIVACY_EMAIL]. We may need proportionate information to verify the request. We will not discriminate against you for exercising a privacy right. Some requests may be limited by law, another person's rights, or the fact that we do not possess the requested app content.

EU/EEA users may complain to the supervisory authority where they live, work, or where the alleged infringement occurred. In Spain, the authority is the Agencia Española de Protección de Datos (aepd.es). UK users may contact the ICO (ico.org.uk). Canadian users may contact the Office of the Privacy Commissioner of Canada (priv.gc.ca). California residents may contact the California Privacy Protection Agency (cppa.ca.gov). Brazilian users may contact the ANPD after first approaching the controller. Other users may contact their competent authority.

DuoCreator is a general-purpose creation tool and is not directed to children. We do not operate an account or knowingly collect children's app content. A parent or guardian should supervise a minor's use where required. Do not record or publish a child without all permissions required by law and with the child's best interests in mind. If support correspondence contains a child's personal data, contact [PRIVACY_EMAIL] so it can be assessed and removed where required.

DuoCreator's AI creates or rewrites text at your request. It does not make legal or similarly significant decisions about eligibility, employment, credit, health, education, insurance, or access to essential services. You choose whether to use the output. Image labels and speech recognition can be inaccurate. See AI and Automated Features.

We may update this policy when the product, website, providers, or law changes. The page will show a new “Last updated” date. Material changes will be presented through an appropriate notice before they take effect where the law requires it. We will not retroactively repurpose personal data in a materially incompatible way without a lawful basis.

For questions or rights requests, contact [PRIVACY_EMAIL], telephone [PHONE], or write to [REGISTERED_ADDRESS].