Privacy Policy

Last updated: 22 July 2026

This Privacy Notice for Maxwell Charles Wheatley (doing business as Reelium) (“we”, “us”, or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at https://reelium.ai or any website of ours that links to this Privacy Notice
• Use Reelium. Reelium turns a Twitch or Kick VOD — or an uploaded MP4 — into short-form vertical clips with captions, hooks and word-level subtitles, then schedules them to TikTok, YouTube Shorts and Instagram Reels.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@reelium.ai.

UK data protection registration. Reelium is registered with the UK Information Commissioner's Office (ICO). Our registration reference is ZC137522. If you believe we are unlawfully processing your personal information, you may complain directly to the ICO at ico.org.uk/make-a-complaint.

Summary of key points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://reelium.ai/dashboard/settings, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. Do we offer artificial intelligence-based products?
7. How do we handle your social logins?
8. Is your information transferred internationally?
9. How long do we keep your information?
10. How do we keep your information safe?
11. Do we collect information from minors?
12. What are your privacy rights?
13. Controls for do-not-track features
14. Do United States residents have specific privacy rights?
15. Do we make updates to this notice?
16. How can you contact us about this notice?
17. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Email addresses
• Usernames
• Passwords
• Contact preferences
• Contact or authentication data
• Billing addresses
• Source URLs (Twitch, Kick) and user-uploaded content

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice here: https://stripe.com/gb/privacy.

Social media login data. We may provide you with the option to register with us using your existing Google account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called “How do we handle your social logins?” below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://reelium.ai/cookies.

The information we collect includes:

• Log and usage data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Google user data we access

When you sign in with Google or connect your YouTube channel to Reelium, we request only the OAuth scopes listed below and use the resulting access strictly as described.

• Sign-in (basic Google profile): your name and email address — used solely to create and identify your Reelium account. No additional Google profile data is read.
• YouTube channel display fields (youtube.readonly scope): your YouTube channel ID, channel title, and channel avatar URL — used to display the connected channel on your Reelium dashboard so you can confirm which YouTube account is linked.
• Optional niche inference (youtube.readonly scope): only when you explicitly click the “Suggest niche from my YouTube” button on the onboarding page, Reelium reads the titles of up to your 25 most recent uploaded videos (via the playlistItems endpoint on your uploads playlist) and passes those titles to our AI to suggest a content niche label that tailors caption generation. Titles are not stored after inference; only the resulting niche label is saved against your account. You can skip this entirely and pick a niche manually instead.
• Publishing clips (youtube.upload scope): used only when you explicitly click “Publish to YouTube” or schedule a clip for future publication. Reelium calls Google's videos.insert API with the specific clip you have created and approved inside Reelium. We never upload anything without an explicit user action initiating that specific upload.
• What Reelium does NOT read: video bodies, analytics, comments, subscribers, watch history, search history, recommendations, monetisation data, channel memberships, or any other Google data outside the items listed above.

Token storage and security

OAuth access and refresh tokens issued by Google are stored in our database (Neon Postgres, encrypted at rest) under your user account. Tokens are never written to logs, never shared with third parties, and are transmitted only directly to Google's API endpoints over HTTPS. Refresh tokens are exchanged for short-lived access tokens on demand using the same secure channel.

Token deletion and revoking access

You can disconnect your YouTube channel at any time from the Reelium dashboard's Connected platforms page; this immediately deletes the stored OAuth tokens from our database. Deleting your Reelium account also deletes all stored OAuth tokens. To revoke Reelium's access to your Google account from Google's side, visit myaccount.google.com/permissions.

Live co-pilot and real-time stream chat

Reelium offers an optional live “co-pilot” that helps you and your moderators catch clip-worthy moments while you stream. When you enable it and connect your Twitch account, we monitor your channel's public live chat in real time (via Twitch EventSub) to detect reaction spikes — bursts of laughter, hype, or emote activity — and alert you when a moment is worth clipping.

This involves processing chat messages sent by your viewers, who may not themselves be Reelium users. We handle that data carefully:

• Individual chat messages are processed transiently. Message text and the sending viewer's Twitch ID are held in memory only long enough to compute a rolling reaction score, and are not stored per message.
• Only aggregate statistics are retained — for example, per-window message rates, the count of distinct chatters, the dominant reaction category, and per-channel baseline reaction levels. These aggregates contain no individual message content and are used to calibrate the alert threshold for your channel.
• Alerts. When a reaction spike is detected, we can send a “clip this” alert to a Discord channel you have connected (see the sub-processor list below). The alert contains a timestamp and a short reaction summary — not viewer chat content.

The lawful basis for this processing is our legitimate interest (and yours, as the channel owner) in identifying highlight moments from your own stream; live stream chat is public. If you are a viewer and do not want your chat activity contributing to a streamer's reaction metrics, you can avoid channels running Reelium's live co-pilot.

Connected platform accounts

When you connect a streaming or publishing account, we request only the OAuth scopes needed for the corresponding feature, and use the resulting access strictly as described:

• Twitch: your email and basic profile (user:read:email) to identify the connected account and read your VODs/clips for analysis. If you enable the live co-pilot, our bot account additionally reads your channel's public chat (channel:bot, user:read:chat) as described above.
• Kick: basic profile (user:read) to identify the connected account and fetch your VODs/clips for analysis.
• TikTok: basic profile and publishing scopes (user.info.basic, user.info.profile, video.upload, video.publish) — used only to display your connected account and to publish a clip when you explicitly choose to.
• Instagram / Meta: business-account and content-publish scopes (instagram_basic, instagram_content_publish, pages_show_list, pages_read_engagement) via the Facebook Graph API — used only to identify your linked Instagram business account and to publish a clip when you explicitly choose to.

Access and refresh tokens for these platforms are stored encrypted at rest (Neon Postgres) and can be revoked at any time from the Connected platforms page or from the platform's own settings.

Clip-detection signals

To rank clip-worthy moments, Reelium processes signals derived from the source you provide: the audio (transcribed to text — see “Do we offer artificial intelligence-based products?” below), your chat replay, and, for Twitch sources, the titles and view counts of fan-made clips of that stream (via Twitch's public Helix API). For channels using the live co-pilot we also fetch public emote lists from 7TV and BetterTTV to recognise channel-specific emotes. These signals are used solely to select and score clips.

Information collected from other sources

In short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

If you interact with us on a social media platform using your social media account (e.g. X), we receive personal information about you from such platforms such as your name, email address, and gender. You may have the right to withdraw your consent to processing your personal information. Learn more about withdrawing your consent. Any personal information that we collect from your social media account depends on your social media account's privacy settings. Please note that their own use of your information is not governed by this Privacy Notice.

2. How do we process your information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “What are your privacy rights?” below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• Improve AI caption and transcription quality. We review samples of AI-generated captions and transcripts to measure accuracy and tune our prompts.

3. What legal bases do we rely on to process your information?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services
  • Analyse how our Services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
  • Maintain and improve the quality of the Service
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and with whom do we share your personal information?

In short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows:

• AI service providers: Anthropic (clip selection and caption generation), AssemblyAI (audio transcription for word-level karaoke captions)
• User authentication: Google Sign-In
• Payment processing: Stripe
• Cloud hosting and computing: Vercel (web hosting), Amazon Web Services (Remotion Lambda video render and durable clip-source storage in S3), Cloudflare (DNS and CDN)
• Analytics and performance monitoring: Vercel Web Analytics and Vercel Speed Insights — aggregate page-view and page-performance data (page/route, referrer, approximate geolocation, device type, browser, operating system, and Core Web Vitals such as load time). Both are cookieless: they set no cookie and store no persistent identifier on your device, visitors are recognised only by a short-lived hash generated from the request, sessions are discarded after 24 hours, and no data point is tied to an individual, an account, or an IP address. We receive counts and aggregates rather than individual browsing profiles. Because no cookie is set, this processing sits outside the scope of our Cookie Notice, which covers cookie-based tracking.
• Database: Neon (managed Postgres)
• Email services: Google Workspace (inbound mail to reelium.ai addresses), Resend (transactional outbound email — account verification, publish notifications, system alerts)
• Audio extraction (fallback): RapidAPI (youtube-mp36 service, used when YouTube native transcripts are unavailable)
• Live co-pilot and messaging: Discord (delivers “clip this” alerts to a channel you connect), 7TV and BetterTTV (public channel emote lists used to recognise channel-specific emotes)
• Allow users to connect to their third-party accounts for publishing: YouTube, TikTok and Instagram (via the Meta / Facebook Graph API)

We also may need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we use cookies and other tracking technologies?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/“sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “Do United States residents have specific privacy rights?”

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://reelium.ai/cookies. Our website analytics (Vercel Web Analytics and Speed Insights, described above) are a deliberate exception: they set no cookie and store no persistent identifier, so they are not covered by the Cookie Notice and are not affected by your cookie preferences.

6. Do we offer artificial intelligence-based products?

In short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI technologies

We provide the AI Products through third-party service providers (“AI Service Providers”), including Anthropic (used for clip selection and caption generation) and AssemblyAI (used for audio transcription that powers word-level karaoke captions). As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in “What legal bases do we rely on to process your personal information?” You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI products

Our AI Products are designed for the following functions:

• Natural language processing
• Speech recognition
• Content generation
• Content personalisation

How we process your data using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

How to opt out

We believe in giving you the power to decide how your data is used. To opt out, you can:

• Log in to your account settings and update your user account
• Contact us using the contact information provided

7. How do we handle your social logins?

In short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your Google account. Where you choose to do this, we will receive certain profile information about you from Google — your name, email address and profile picture. Google is currently the only third-party sign-in option we support; you can also register with an email address and password instead.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. Is your information transferred internationally?

In short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United Kingdom and United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see “When and with whom do we share your personal information?” above), including facilities in the United Kingdom, United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

9. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). In particular, we apply the following retention periods:

• Account and profile data: kept while your account is active; deleted or anonymised after account closure, subject to the legal retention below.
• Billing records: retained as required by tax and accounting law (typically up to 7 years).
• Clip-source video (Amazon S3): temporary working segments are deleted within roughly 1 day; a durable staged copy of a clip's source is kept for up to 90 days so your renders and previews survive the streaming platform's VOD purge.
• Transcripts and chat-signal caches: up to 60 days.
• Clip-scoring snapshots and live-alert records: up to 30 days.
• Per-channel reaction statistics (aggregate only — no individual chat-message content): kept on an ongoing basis to calibrate live detection for your channel, and deleted on request or on account closure.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. How do we keep your information safe?

In short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at privacy@reelium.ai.

12. What are your privacy rights?

In short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “How can you contact us about this notice?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://reelium.ai/cookies.

If you have questions or comments about your privacy rights, you may email us at privacy@reelium.ai.

13. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

14. Do United States residents have specific privacy rights?

In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section “What information do we collect?”

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A — As long as the user has an account with us
• Category B — As long as the user has an account with us
• Category D — As long as the user has an account with us
• Category F — As long as the user has an account with us

Sources of personal information

Learn more about the sources of personal information we collect in “What information do we collect?”

How we use and share personal information

Learn more about how we use your personal information in the section, “How do we process your information?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, “When and with whom do we share your personal information?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category D. Commercial information
• Category F. Internet or other electronic network activity information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “When and with whom do we share your personal information?”

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to exercise your rights

To exercise these rights, you can contact us by visiting https://reelium.ai/dashboard/settings, by emailing us at privacy@reelium.ai, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@reelium.ai. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine the Light” law

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “How can you contact us about this notice?”

15. Do we make updates to this notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

16. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at privacy@reelium.ai or contact us by post at:

Maxwell Charles Wheatley
5 Burgess Wood Road South
Beaconsfield, Buckinghamshire HP9 1EU
United Kingdom

You may also raise a concern with the UK Information Commissioner's Office at ico.org.uk if you believe we have not handled your personal information appropriately.

17. How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://reelium.ai/dashboard/settings.

Deleting data obtained from a connected platform

To delete the data Reelium obtained through a specific connected account — including Facebook and Instagram, YouTube, TikTok, Twitch and Kick — disconnect that account on your Connected platforms page. Disconnecting immediately deletes the stored access tokens and the account identifiers we hold for it (such as your Instagram business account ID and Facebook user ID).

If you remove Reelium from your Facebook account settings instead, Meta notifies us directly and we delete the corresponding connection automatically. You can also email privacy@reelium.ai at any time to request deletion, and deleting your Reelium account removes all connected-platform data.