Условия эксплуатации

Privacy Policy 

reelfever.ai

Effective Date: August 13, 2026

Your privacy is important to us. This Privacy Policy explains how reelfever.ai ("we," "us," "our," or the "Service") collects, uses, discloses, and protects your personal information when you access or use our web-based platform at https://www.reelfever.ai. By using the Service, you consent to the practices described in this Privacy Policy.

Table of Contents

  1. Data Controller and Contact
  2. Information We Collect
  3. How We Use Your Information
  4. Legal Basis for Processing (GDPR)
  5. Cookies and Tracking Technologies
  6. Information Sharing and Disclosure
  7. International Data Transfers
  8. Data Retention
  9. Your Privacy Rights
  10. Children's Privacy
  11. Data Security
  12. Changes to This Privacy Policy
  13. Contact Us

1. Data Controller and Contact

The entity responsible for your personal data (the "Data Controller") under applicable data protection laws is:

For data protection inquiries, you may contact us at legal@reelfever.ai. If you are in the European Union, the United Kingdom, or another jurisdiction that requires a representative, our representative's details are available upon request.

For users in the European Union, we have designated a Data Protection Officer (DPO) who can be contacted at legal@reelfever.ai regarding data protection matters.

2. Information We Collect

We collect various types of personal information when you use the Service, as described below.

2.1 Information You Provide

When you register an account, make purchases, or otherwise interact with the Service, you may provide:

Category

Examples

When Collected

Account Information

Email address, password (encrypted), account preferences

When you register for an account

Purchase Information

Subscription plan, Virtual Coins purchased, transaction history, billing country

When you purchase subscriptions or Virtual Coins

Payment Data

Payment method type, last four digits of card (full payment details are handled by our third-party payment processors)

When you make a purchase

Marketing Preferences

Email opt-in/opt-out status, promotional communication preferences

When you set or change your marketing preferences

Communications

Records of your correspondence with us (e.g., support emails)

When you contact customer support

 

2.2 Information Collected Automatically

When you access or use the Service, we and our third-party partners automatically collect certain information about your device and usage through cookies, log files, and similar technologies:

Category

Examples

Device Information

Device identifier, device type, operating system, browser type and version, screen resolution

Network Information

IP address, approximate location (derived from IP), connection type

Usage Data

Pages visited, content viewed, time spent on pages, click data, search queries, scroll depth, feature usage frequency

Browsing Patterns

Content preferences, viewing history, interaction patterns, engagement metrics

Guest User Identifier

Device-bound identifier used to associate Guest User purchases with the specific device

 

2.3 Information Collected by Third Parties

Third-party SDKs and APIs integrated into the Service may collect information on our behalf or for their own purposes. This includes:

  • Advertising networks— collect device identifiers, browsing data, and interaction data to serve and measure advertisements;
  • Analytics providers— collect usage data to help us understand how the Service is used;
  • Payment processors— collect and process payment information to complete transactions; and
  • Other service providers— collect data necessary to provide their respective services (e.g., authentication, security, performance monitoring).

The specific third-party SDKs and APIs used, and the data they collect, are listed in Section 6 below. Please refer to the respective third parties' privacy policies for more information about their data practices.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

3.1 Providing and Operating the Service

  • Creating and managing your account (for Registered Users);
  • Authenticating your access to the Service;
  • Processing subscription payments and Virtual Coin purchases;
  • Maintaining Guest User purchase records tied to your device;
  • Delivering access to licensed content based on your subscription or Virtual Coin balance;
  • Providing customer support; and
  • Managing the technical operation of the Service.

3.2 Improving and Developing the Service

  • Analyzing usage patterns and trends to improve user experience;
  • Developing new features and content offerings;
  • Monitoring and maintaining Service performance, stability, and security;
  • Conducting analytics and generating aggregate, anonymized reports; and
  • Troubleshooting technical issues.

3.3 Advertising and Marketing

  • Displaying advertisements on the Service (including personalized ads based on your interests, where permitted);
  • Sending you promotional emails and communications (only if you have opted in);
  • Measuring the effectiveness of advertising campaigns; and
  • Providing you with relevant content recommendations.

3.4 Legal Compliance and Protection

  • Complying with applicable legal obligations;
  • Detecting, preventing, and addressing fraud, abuse, and security issues;
  • Enforcing our Terms of Use; and
  • Protecting the rights, property, and safety of our users and the Company.

4. Legal Basis for Processing (GDPR)

If you are located in the European Union, the United Kingdom, or another jurisdiction subject to the General Data Protection Regulation (GDPR), we process your personal information under the following legal bases:

Legal Basis

Processing Activities

Consent (Art. 6(1)(a))

• Placing non-essential cookies and similar technologies on your device;
• Sending marketing communications;
• Collecting data for personalized advertising;
• Processing analytics data that is not strictly necessary for the Service.

Performance of a Contract (Art. 6(1)(b))

• Creating and managing your account;
• Processing subscription payments and Virtual Coin purchases;
• Delivering access to content;
• Maintaining Guest User purchase records.

Legitimate Interests (Art. 6(1)(f))

• Improving and securing the Service;
• Detecting fraud and abuse;
• Analyzing usage trends (in anonymized or pseudonymized form where possible);
• Displaying non-personalized advertising.

Legal Obligation (Art. 6(1)(c))

• Retaining transaction records for tax and accounting purposes;
• Complying with law enforcement requests;
• Meeting other regulatory requirements.

 

For special categories of personal data (Art. 9 GDPR), we only process such data where you have given explicit consent or where processing is necessary for a reason of substantial public interest. We do not knowingly collect special categories of personal data through the Service.

You have the right to withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

5. Cookies and Tracking Technologies

We and our third-party partners use cookies, web beacons, pixels, and similar tracking technologies ("Cookies") on the Service for the following purposes:

5.1 Types of Cookies We Use

Cookie Type

Purpose

Consent Required?

Strictly Necessary

Essential for the Service to function (e.g., login sessions, security, load balancing)

No

Functional

Remember your preferences and settings (e.g., language, display options)

Yes

Analytics

Understand how visitors use the Service, measure performance, and improve features

Yes

Advertising

Deliver relevant ads, measure ad performance, and limit the number of times you see an ad

Yes

Social Media

Enable social media features and sharing (if applicable)

Yes

 

5.2 Cookie Consent

For users in the European Union, the United Kingdom, and other jurisdictions requiring consent for non-essential cookies, we will display a cookie consent banner when you first visit the Service. You may:

  • Accept all cookies— all cookie types will be placed on your device;
  • Reject non-essential cookies— only strictly necessary cookies will be used; or
  • Manage preferences— selectively enable or disable specific cookie categories.

You can change your cookie preferences at any time by clicking the "Cookie Settings" link in the footer of the Service.

5.3 Third-Party Cookies

Third-party advertising networks and analytics providers may set their own cookies on your device when you use the Service. These cookies are governed by the respective third parties' privacy policies. We do not control these cookies.

5.4 Browser Controls

You can also control cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Please note that if you disable strictly necessary cookies, some parts of the Service may not function properly.

5.5 Do Not Track Signals

Some browsers offer a "Do Not Track" (DNT) feature. Because there is currently no industry consensus on how to interpret DNT signals, we do not currently respond to DNT signals. We will update this Privacy Policy if our approach changes.

5.6 Additional Jurisdiction-Specific Cookie Requirements

In addition to the EU and UK ePrivacy requirements described above, the following jurisdictions have specific cookie consent requirements:

  • Quebec, Canada (Law 25):Requires opt-in consent before placing cookies or tracking technologies on a user's device. This is the only jurisdiction in North America with an opt-in cookie requirement. Quebec residents will receive a cookie consent prompt regardless of EU/UK status.
  • South Korea (PIPA):Requires separate consent for cookies that collect personally identifiable information. We provide a granular consent mechanism for Korean users.
  • Brazil (LGPD):Requires consent for cookies that process personal data, with options to accept or reject non-essential cookies.

6. Information Sharing and Disclosure

We do not sell your personal information to third parties. However, we may share your personal information with the following categories of recipients:

6.1 Service Providers and Processors

We share personal information with third-party service providers who perform services on our behalf, including:

Category

What They Do

Data Shared

Cloud Hosting Providers

Host the Service and store data

Account, usage, and system data

Payment Processors

Process subscription and Virtual Coin payments

Payment method data, transaction details

Analytics Providers

Provide usage analytics and reporting

Device information, usage data, IP address

Advertising Networks

Serve and measure advertisements

Device identifiers, browsing data, interaction data

Authentication Services

Verify user identity and prevent fraud

Email address, device information

Performance Monitoring

Monitor Service uptime and performance

System logs, error reports

Customer Support Tools

Manage and respond to user inquiries

Account information, communication records

 

Our service providers are bound by contractual obligations to protect your personal information and are prohibited from using it for any purpose other than providing services to us.

6.2 Third-Party SDKs

The Service integrates third-party Software Development Kits (SDKs) that may collect and process your personal information. The primary SDKs we use include:

SDK Category

Data Collected

Purpose

Google Analytics

IP address, device info, usage data

Web analytics

Google AdSense / AdMob

Device ID, cookies, browsing data

Advertising

Stripe / PayPal

Payment method, transaction data

Payment processing

[Other SDKs]

[As described by the SDK provider]

[Purpose]

 

Note: The above list is illustrative and may not be exhaustive. We will update this list as we add or remove SDKs. Please refer to each provider's privacy policy for detailed information about their data practices.

6.3 Legal Compliance

We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., law enforcement, court orders, or government regulations).

6.4 Business Transfers

If we are involved in a merger, acquisition, reorganization, dissolution, or other sale or transfer of some or all of our assets, your personal information may be transferred as part of that transaction. We will notify you via email or a prominent notice on the Service of any change in ownership or control of your personal information.

6.5 With Your Consent

We may share your personal information with third parties for purposes not described in this Privacy Policy with your consent.

7. International Data Transfers

The Service is operated from [Country/Jurisdiction], and your personal information may be processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction.

7.1 Transfer Mechanisms

When we transfer your personal information from the European Economic Area (EEA), the United Kingdom, or other jurisdictions with data transfer requirements, we use appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs)— the standard contractual clauses approved by the European Commission for the transfer of personal data to third countries. We rely on SCCs as our primary transfer mechanism;
  • UK International Data Transfer Addendum— for transfers from the United Kingdom; and
  • EU-U.S. Data Privacy Framework (DPF)— if the receiving organization in the United States is certified under the DPF, transfers may also be made under the DPF principles. However, given potential regulatory and legal developments affecting the DPF, we maintain SCCs as a fallback mechanism to ensure continuous protection of your data.

For transfers to other countries, we will implement appropriate safeguards in accordance with applicable data protection laws, which may include:

  • South Korea (PIPA):As South Korea does not currently recognize SCCs as a standalone transfer mechanism, we rely on your separate consent for cross-border transfers and/or contractual safeguards, in accordance with PIPA requirements;
  • Japan (APPI):We comply with the cross-border transfer requirements under APPI, including providing information about the destination country's data protection system and obtaining your consent where required; and
  • Brazil (LGPD):We use ANPD-approved standard contractual clauses or other mechanisms recognized under LGPD for transfers to countries that do not provide an adequate level of protection.

7.2 Your Rights Regarding Transfers

Under GDPR, you have the right to be informed about the safeguards we use for international transfers. You may request a copy of the relevant safeguards by contacting us at legal@reelfever.ai.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. Specifically:

Data Type

Retention Period

Account Information (Registered Users)

For the duration of your account, plus [30/90] days after account deletion request

Guest User Data

For the duration of your use of the Service on the same device, plus [30/90] days of inactivity

Purchase and Transaction Records

For the duration required by applicable tax and accounting laws (typically 5-7 years)

Usage and Analytics Data

Up to [24] months, after which it is anonymized or deleted

Marketing Communications Records

Until you opt out, plus [12] months

Support Communications

Up to [24] months after resolution

Security Logs

Up to [12] months

 

When personal information is no longer needed, we will either delete it or anonymize it so that it can no longer be used to identify you.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

9.1 GDPR Rights (EEA and UK Users)

Right of Access

You have the right to request a copy of the personal information we hold about you.

Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal information.

Right to Erasure ("Right to Be Forgotten")

You have the right to request that we delete your personal information, subject to certain exceptions (e.g., legal retention obligations).

Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal information under certain conditions.

Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another controller.

Right to Object

You have the right to object to the processing of your personal information based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent

Where we process your personal information based on consent, you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection authority. In the EU, you can find your local authority at edpb.europa.eu. In the UK, the authority is the Information Commissioner's Office (ICO) at ico.org.uk.

9.2 CCPA/CPRA Rights (California, USA Users)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

Right to Know

You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purpose for collecting, and the third parties to whom we disclose the information.

Right to Delete

You have the right to request that we delete your personal information, subject to certain exceptions.

Right to Correct

You have the right to request that we correct inaccurate personal information about you.

Right to Opt-Out of Sale or Sharing

We do not sell your personal information. However, we may "share" personal information (as defined under CPRA) with advertising partners for targeted advertising purposes. You have the right to opt-out of this sharing by contacting us at legal@reelfever.ai.

Right to Limit Use of Sensitive Personal Information

Under CPRA, you have the right to limit the use of your sensitive personal information for purposes other than those permitted by the law.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights.

9.3 Other U.S. State Privacy Rights

If you are a resident of another U.S. state with data privacy laws (such as Virginia, Colorado, Connecticut, Utah, or others), you may have similar rights, including the right to access, delete, correct, and opt-out of targeted advertising and certain profiling. To exercise these rights, please contact us at legal@reelfever.ai.

9.4 Other Jurisdiction Rights

If you are located in a jurisdiction outside the EU, UK, or US, you may also have privacy rights under your local law, including:

  • Japan (APPI):You have the right to request disclosure, correction, and cessation of use of your personal information.
  • South Korea (PIPA):You have the right to access, correct, delete, and suspend processing of your personal information.
  • Australia (Privacy Act):You have the right to access and correct your personal information, and to complain to the Office of the Australian Information Commissioner (OAIC).
  • Brazil (LGPD):You have the right to confirmation of processing, access, correction, deletion, portability, and withdrawal of consent.
  • Canada (PIPEDA):You have the right to access and challenge the accuracy of your personal information.
  • Quebec, Canada (Law 25):If you are a Quebec resident, you have additional rights under Law 25, including the right to be informed of the use of your personal information, the right to withdraw consent, and the right to request that your personal information be deleted. Law 25 also requires opt-in consent for cookies and tracking technologies — this is the only jurisdiction in North America with such a requirement.

9.5 How to Exercise Your Rights

To exercise any of your privacy rights, please contact us at:

We will respond to your request within the timeframes required by applicable law (typically 30 days, which may be extended by an additional 60 days for complex requests). We may need to verify your identity before processing your request.

9.6 Marketing Communications

You can opt out of receiving marketing emails from us at any time by:

  • Clicking the "unsubscribe" link in any marketing email;
  • Changing your preferences in your account settings; or
  • Contacting us at legal@reelfever.ai.

Please note that we may still send you service-related emails (e.g., account confirmations, purchase receipts, security notices) even if you opt out of marketing communications.

10. Children's Privacy

The Service is not directed to children under the age of 13 (or the minimum age required for digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at legal@reelfever.ai, and we will take steps to delete such information.

10.1 Age of Digital Consent

In jurisdictions where the age of digital consent is higher than 13 (for example, 16 years of age under GDPR, unless the member state has lowered it to 13), we will not process the personal information of users below the applicable age without parental or guardian consent.

10.2 Parental Consent for Purchases

Users under the age of 18 (or the age of majority in their jurisdiction) must obtain parental or guardian consent before making any purchases on the Service. We are not liable for purchases made by minors without parental consent but will process refund requests in accordance with applicable law.

10.3 COPPA Compliance

For users in the United States, we comply with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13, and we do not direct the Service to children under 13.

10.4 UK Age Appropriate Design Code

For users in the United Kingdom, we are aware of the Age Appropriate Design Code (Children's Code) issued by the Information Commissioner's Office (ICO). This code applies to online services that are likely to be accessed by children (under 18) in the UK. We have considered the 15 standards of the Children's Code in our design and will continue to evaluate whether any aspects of the Service are "likely to be accessed" by children. If you believe any aspect of the Service requires adjustments to comply with the Children's Code, please contact us at legal@reelfever.ai.

10.5 South Korea Children's Privacy

For users in South Korea, under PIPA, we require verifiable parental consent before collecting personal information from children under 14. For minors aged 14 to 18, we require consent from the minor and their legal representative for processing that may have a significant impact on their rights and interests.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption— encrypting personal information in transit (TLS/SSL) and at rest;
  • Access Controls— limiting access to personal information to authorized personnel on a need-to-know basis;
  • Regular Security Assessments— conducting security audits, vulnerability scans, and penetration testing;
  • Incident Response— maintaining an incident response plan to address potential data breaches;
  • Vendor Management— requiring third-party service providers to maintain appropriate security standards; and
  • Employee Training— providing data protection and security training to our employees.

Despite these measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to protecting your personal information to the best of our ability.

11.1 Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and affected individuals in accordance with applicable law (e.g., within 72 hours under GDPR Art. 33-34).

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

  • Update the "Effective Date" at the top of this Privacy Policy;
  • Provide a prominent notice on the Service; and
  • For significant changes that affect your rights, provide additional notice (e.g., email or in-Service notification).

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

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

Cloud Whale Interactive Technology LLC

300 Delaware Avenue, Suite 210-2207

Wilmington, DE 19801

 

If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with your local data protection authority or supervisory authority.