Privacy notice

Last updated: [DATE]

1. Who we are

The controller of your personal data is [LEGAL NAME OF WHITECLOAK LABS] (WhiteCloak Labs), a [LEGAL FORM, e.g. registered association / foundation / non-profit company], [STREET, POSTAL CODE, CITY, COUNTRY]. Contact for privacy questions: privacy@whitecloaklabs.com.

This notice covers the website https://whitecloaklabs.com, the STRATA product line and its products (currently Genie, and Erudite once it launches).

2. What data we process

3. Why we process it, and on what legal basis

[A LAWYER SHOULD CONFIRM THE LEGAL BASIS FOR EACH PURPOSE]

4. Artificial intelligence

To create edits, captions and tags, Genie sends small preview images taken from your uploads, together with your instructions, to AI service providers. The suggestions can be wrong, so please review everything before it is published. We do not use your content to train our own models. [CONFIRM EACH AI PROVIDER'S DATA-USE TERMS, INCLUDING FREE TIERS, BEFORE LAUNCH, AND LIST THEM]

5. Who receives your data

We use service providers who process data on our behalf:

We do not sell your personal data.

6. Transfers outside the EU/EEA

Some providers may process data outside the EU/EEA. In that case we rely on appropriate safeguards such as standard contractual clauses. [DESCRIBE REGIONS AND SAFEGUARDS]

7. How long we keep data

8. Your rights

You have the right to access your data, to have it corrected or deleted, to restrict or object to its processing, to receive it in a portable format, and to withdraw consent. You can also complain to your data protection supervisory authority. To use these rights, write to privacy@whitecloaklabs.com. See also our data deletion instructions.

9. Security

We protect data with encryption in transit, encrypted storage of social account tokens, access controls and separation between customers' data. No system is perfectly secure. [LAWYER AND SECURITY REVIEW]

10. Age

Our services are not intended for people under [MINIMUM AGE, e.g. 18]. [ADD HOW YOUTH PROGRAMMES OF WHITECLOAK LABS ARE HANDLED, IF RELEVANT]

11. Cookies

See our cookie notice.

12. Changes and contact

We may update this notice and will publish the new version here. Questions: privacy@whitecloaklabs.com.