Last updated: [LAWYER: date]
This policy explains what personal data Umfug collects, why, who we share it with, and the rights you have over it. Please read it alongside our Terms of Service.
Umfug ("Umfug", "we", "us") is a conversational AI service that pays a share of its profit to the creatives mentioned in conversations and to a water charity.
The data controller responsible for your personal data is [LAWYER: legal entity name + registered address]. If you have any questions about this policy or your data, contact us at [LAWYER: privacy contact email].
Account and identity. When you create an account, our authentication provider (Clerk) collects your email address, name, and login identifiers.
Your conversations. We process the prompts and messages you send in order to generate responses. To do this, your text messages are sent to our AI model provider (DeepSeek) and, where a prompt requires current information, to our web-search provider (Tavily). You can also upload images and files (currently image files, PDFs, Word documents, and plain text). Uploaded images and the related prompt are processed by Google (Gemini API) to answer questions about them, describe them, or edit/generate images from them. Our attribution system also analyses your messages to identify the names of creatives mentioned in them.
Attribution and usage data. We record the attribution tokens generated by your activity (which creatives are mentioned, and prompts that support the water charity), along with usage counts and your trial or subscription status.
Billing data. When you subscribe, our payments provider (Stripe) processes your payment. Umfug does not store your full card details — these are handled by Stripe. We store your subscription status and related billing records.
Creator data. If you register as a creative to receive payouts, we collect the name you are claiming, your stated relationship to it, the public property (such as a website or social profile) you use to prove you control that name, your legal name, and your payout country. To verify you, we check that you control that public property and run an automated identity check that searches publicly available information about the creative. Your bank and payout details are stored by our payouts provider (Wise), not by Umfug — we store only a reference to your Wise recipient record.
Technical data. We use essential cookies to keep you logged in, and we keep basic logs needed to run and secure the service. For abuse prevention, we process your IP address to apply rate limits.
We use your data to:
We share data with the service providers ("processors") that help us run Umfug, only as needed to provide the service:
We do not sell your personal data. We do not show advertising in Umfug.
AI model training. [LAWYER/FACT: confirm whether DeepSeek, Google (Gemini), and Tavily retain or train on API inputs under our plan. State our position and whether user conversations are used for model training by us or our processors.]
Some of our providers process data outside the United Kingdom and the European Economic Area. In particular: your text messages are processed by DeepSeek, which operates outside the UK/EEA [LAWYER: DeepSeek is a China-based provider with no UK/EU adequacy decision — confirm SCCs + transfer risk assessment before launch]; your uploaded images are processed by Google (Gemini), which operates in the United States; and our database, hosting, and error-monitoring providers may also transfer data internationally. Where data is transferred outside the UK/EEA, we rely on [LAWYER: appropriate transfer safeguard — e.g. adequacy regulations, the UK International Data Transfer Agreement, or Standard Contractual Clauses].
We keep your account and conversation data for as long as your account is active, and for [LAWYER: post-closure retention period] afterwards. We keep billing and accounting records for as long as the law requires (in the UK, generally six years). We keep creator and payout records for as long as needed to administer payouts and meet our legal obligations. When data is no longer needed, we delete or anonymise it.
If you are in the UK or the EEA, you have the right to: access your data; correct it; have it erased; restrict or object to how we use it; receive a copy in a portable format; and withdraw consent where we rely on it. To exercise any of these, contact us at [LAWYER: privacy contact email].
You also have the right to complain to the UK's Information Commissioner's Office (ICO) at ico.org.uk, or to your local data protection authority.
You can request deletion of your data at any time by emailing [LAWYER: privacy contact email] or through your account settings. We will delete your personal data except where we are required to keep certain records (for example, billing records) by law.
When you verify as a creator, we record the public property you use to prove control of your claimed name (for example, a website URL or social profile) and the result of that check. We also run an automated identity check that searches publicly available information about the creative to corroborate your claim, and we keep the resulting verdict for our records. This verification uses only information you provide and information that is already public — we do not access your private accounts. You can request removal of this data using the contact details above.
Creator verification involves automated processing that assesses whether a claimant is legitimately connected to the creative name they have registered. This automated assessment affects whether a creative can be paid. If you receive an unfavourable verification result, you can request a human review by contacting us at [LAWYER: privacy contact email]. [LAWYER: confirm Art. 22 GDPR / UK GDPR wording on automated individual decision-making, including the right to human intervention.]
We use cookies that are essential to the service, such as keeping you signed in. We do not use advertising cookies.
Umfug is not directed at, and is not intended for, anyone under the age of [LAWYER: confirm minimum age — currently 16].
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