Privacy Policy

1. Who we are

The App is developed and operated by Innotent LTD, a company registered in Israel ("Innotent", "we", "us" or "our").

• Address: Yachin 4, Ramat Gan, Israel
• Email: innotent.ltd@gmail.com

For the purposes of data protection laws such as the EU General Data Protection Regulation (GDPR), Innotent LTD is the controller of the personal data described in this Privacy Policy.

2. Summary

• No account. The App has no sign-in or registration. We do not ask for your name, email address or phone number.
• Your scripts and recordings stay on your device. They are not uploaded to our servers and are not synced to any cloud service, except when you choose to use the Eye Contact feature on a video.
• Auto captions are created on your device.
• Analytics and purchases. We use Google Firebase and RevenueCat for analytics, A/B testing, purchases, subscriptions and ad campaign attribution.
• AI script generation sends the description you type to our server and then to a third-party AI provider (OpenAI or Anthropic). We do not store your description.
• The Eye Contact feature uploads the video you choose to our cloud storage and sends it to NVIDIA for processing. It is only for users aged 18 or older. Please read section 5 before using it.
• We do not sell your personal information, and we do not track you across other companies' apps and websites.

3. Information we collect

3.1 Content that stays on your device

The App asks for certain permissions in order to work. You can allow or deny them at any time in your iPhone Settings. Some features will not work without them.

• Camera and microphone: to record video and audio while you read from the teleprompter.
• Speech recognition: to create auto captions. Captions are generated on your device.
• Photo library: to save your recordings and to let you choose videos to edit.

The scripts you write, the videos you record, and your captions and edits are stored locally on your device. We do not have access to them, unless you choose to process a video with the Eye Contact feature (see section 5). If you delete the App, content stored inside the App is deleted as well. Videos you have saved to your photo library remain there.

3.2 App usage and device information (analytics)

We use Google Firebase Analytics and Firebase A/B Testing (with Firebase Remote Config) to understand how the App is used and to test changes to the App. This may include:

• app events, such as screens viewed, features used, buttons tapped and session length;
• device and app information, such as device model, iOS version, App version, language and region settings;
• an app instance identifier that Firebase creates for your installation of the App;
• approximate location, such as country or city, derived from your IP address.

Because the App has no accounts, this information is not linked to your name or contact details.

3.3 Purchases, subscriptions and attribution

Purchases are processed by Apple through the App Store. We do not receive your payment card details.

We use RevenueCat to manage subscriptions and in-app purchases, to run A/B tests on paywalls and prices, and to measure the performance of our Apple Ads (formerly Apple Search Ads) campaigns. RevenueCat may process:

• an anonymous user ID generated for your installation of the App;
• purchase and subscription information, such as product, price, currency, purchase date, trial status and renewal status;
• device information and IP address;
• attribution information provided by Apple's AdServices framework, such as the Apple Ads campaign, ad group and keyword that led to your download. This does not require access to your device's advertising identifier.

3.4 Information you choose to send us

• The description you enter when you use AI script generation (see section 4).
• Videos you choose to process with the Eye Contact feature (see section 5).
• Any information you include when you contact us by email.

3.5 Technical information processed by our servers

When the App communicates with our servers, for example when you use AI script generation or the Eye Contact feature, our servers and hosting providers process technical information such as your IP address, the time of the request, and device and App information. This is needed to operate and secure the service, and it may be recorded in server logs.

4. AI script generation

The App lets you describe the script you want and generates it using artificial intelligence. Using this feature is optional.

• What is sent: only the description you type into the script generation feature. We do not send your existing scripts or your recordings.
• How it works: your description is sent to our backend server, which forwards it to a third-party AI provider, currently OpenAI and/or Anthropic. The generated script is returned to the App and saved on your device.
• Storage: we do not store the description you enter on our servers.
• AI providers: OpenAI and Anthropic process your description in order to generate the script, under their own terms and privacy policies (see section 7). They may retain it for a limited period, for example for safety and abuse monitoring, according to their policies. We do not use your description to train AI models, but we cannot guarantee how these providers use it, including for training or improving their own models.
• Please do not include personal, confidential or sensitive information about yourself or others in your description.
• Accuracy: AI-generated content may be inaccurate or incomplete. Please review it before you use it.

5. Eye Contact feature: important information

Please read this section carefully before using the Eye Contact feature. Using this feature is optional.

5.1 Who can use it

The Eye Contact feature is only for users aged 18 or older. We do not ask for or verify your age in the App. By using the Eye Contact feature, you confirm that you are at least 18 years old.

5.2 What happens to your video

1. The video you select, including any people, faces and sound in it, is uploaded from your device to our cloud storage on Google Cloud Storage. The storage location is the European Union (EU multi-region).
2. Our servers send the video to NVIDIA's hosted Eye Contact service, which adjusts the eyes in the video so that the speaker appears to look at the camera. NVIDIA may process the video on servers located outside the European Union, including in the United States.
3. The processed video is returned to the App. The original video and the processed video may be kept temporarily in our cloud storage (see section 5.4).

The feature processes images of faces only in order to modify the eye area in the video. We do not use it to identify anyone.

5.3 Service providers may change

We are still testing and improving this feature. We may use additional or different service providers for storing and processing videos in the future. If we do, your video may be shared with those providers for the same purpose. We will keep the list of providers in section 7 up to date.

5.4 How long videos are kept

We aim to delete uploaded and processed videos from our cloud storage within 1 to 7 days after processing. However, because of technical issues, some videos may remain stored for longer. We cannot guarantee that a video will be deleted within a specific period, but we work to identify and remove such videos.

Videos processed by NVIDIA or by any other service provider are handled under that provider's own terms and retention policies, which we do not control. We do not use your videos to train AI models, but we cannot guarantee how these providers use them, including for training or improving their own models or services.

5.5 Your responsibility

• Only upload videos that you have the right to use. If a video shows or records other people, you are responsible for having their permission.
• Do not upload videos that contain sensitive or confidential information that you do not want shared with third-party service providers.
• If you do not want your video uploaded, stored and processed as described in this section, do not use the Eye Contact feature.

By using the Eye Contact feature, you acknowledge that you have read this section and understand that your video will be uploaded, stored and processed by us and by third-party service providers as described above. To the extent permitted by applicable law, you use this feature at your own risk.

5.6 Asking us to delete a video

You can ask us to delete a video by emailing innotent.ltd@gmail.com. Because the App has no accounts, please include the approximate date and time you used the feature, so we can try to locate it. We may not be able to identify a specific video in every case.

6. How we use information

We use the information described above to:

• provide and operate the App and its features, including AI script generation and the Eye Contact feature;
• process purchases, manage subscriptions and restore purchases;
• understand how the App is used, fix problems and improve the App;
• run A/B tests on features, design, paywalls and prices;
• measure the effectiveness of our Apple Ads campaigns;
• keep the App and our servers secure and prevent abuse and fraud;
• respond to your requests and messages;
• comply with legal obligations.

We do not use your videos or your script descriptions to train AI models. However, our third-party service providers, such as OpenAI, Anthropic and NVIDIA, process them under their own terms and privacy policies, and we cannot guarantee how they use them, including whether they use them to train or improve their own models or services. Please review their privacy policies (see section 7).

7. Service providers and other sharing

We share information with the following service providers, only as needed for the purposes described in this Privacy Policy.

We may also disclose information:

• if required by law, regulation, legal process or a government request;
• to protect the rights, property or safety of Innotent, our users or others, and to enforce our Terms of Use;
• in connection with a merger, acquisition, financing or sale of all or part of our business, in which case the information will remain subject to this Privacy Policy or a policy that is at least as protective.

We do not sell your personal information.

8. Tracking and advertising

• We do not ask for permission to track you through Apple's App Tracking Transparency, and we do not access your device's advertising identifier (IDFA).
• We do not combine information collected in the App with information from other companies' apps or websites for targeted advertising, and we do not share it with data brokers.
• To measure our Apple Ads campaigns, we use Apple's AdServices attribution through RevenueCat. It tells us which Apple Ads campaign led to an install, without tracking you across other apps.

9. How long we keep information

• Content on your device: until you delete it or delete the App.
• Analytics data: kept by Firebase according to our retention settings and Google's policies, then deleted or aggregated.
• Purchase and subscription data: kept by RevenueCat and Apple for as long as needed to manage your subscription and for accounting, tax and legal purposes.
• AI script descriptions: not stored by us. AI providers may retain them for a limited period according to their policies.
• Eye Contact videos: see section 5.4.
• Server logs: kept for a limited period for security and troubleshooting.
• Emails you send us: for as long as needed to handle your request and keep appropriate records.

10. Security

We use reasonable technical and organizational measures to protect information, including encrypted connections (HTTPS) between the App and our servers and restricted access to our cloud storage. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

11. International data transfers

Innotent is based in Israel. The European Commission has recognized Israel as providing an adequate level of protection for personal data.

Our service providers, including Google, RevenueCat, Apple, OpenAI, Anthropic and NVIDIA, may process information in the United States and other countries. Eye Contact videos are stored in the European Union, but they may be processed by NVIDIA outside the European Union.

Where required by law, these transfers rely on appropriate safeguards, such as the EU–U.S. Data Privacy Framework (where the provider is certified) or Standard Contractual Clauses included in the provider's data processing terms.

12. Children and age requirements

• The App is intended for a general audience and is not directed at children under 13 (or under 16 in the EEA and UK). We do not knowingly collect personal information from children under these ages.
• The Eye Contact feature is only for users aged 18 or older (see section 5).
• The App does not ask for your age. It is your responsibility, or your parent's or guardian's responsibility, to read this Privacy Policy and our Terms of Use before using the App.
• If you are a parent or guardian and believe your child has provided us with personal information, please contact us and we will take reasonable steps to delete it.

13. Your choices and requests

• Permissions: you can allow or deny camera, microphone, speech recognition and photo library access at any time in your iPhone Settings.
• Optional features: you can choose not to use AI script generation or the Eye Contact feature. If you do not use them, no descriptions or videos are sent to our servers.
• Resetting identifiers: deleting and reinstalling the App creates new app identifiers for analytics and purchases.
• Subscriptions: you can manage or cancel subscriptions in your Apple ID settings on your device.
• Requests: you can contact us at innotent.ltd@gmail.com to ask about, or request deletion of, information we hold about you.

Because the App has no accounts, we may not be able to link a request to specific information. To help us, please include relevant details, such as the approximate date and time you used a feature, your device model and the App version. We may ask for additional information to verify a request. We will respond within the time required by applicable law.

14. Additional information for users in the EEA, UK and Switzerland

14.1 Controller

Innotent LTD, Yachin 4, Ramat Gan, Israel, innotent.ltd@gmail.com.

14.2 Legal bases

• Performance of a contract: to provide the features you ask for, including AI script generation, Eye Contact processing, purchases and subscriptions.
• Legitimate interests: for analytics, A/B testing, measuring our ad campaigns, security, fraud prevention and improving the App. Our interest is to understand, improve and grow the App, using limited information that is not linked to your identity. You can object to this processing (see section 14.3).
• Legal obligation: to comply with tax, accounting and other legal requirements.
• Consent: where required by law. You can withdraw your consent at any time. This does not affect processing that took place before you withdrew it.

14.3 Your rights

Subject to the conditions in applicable law, you have the right to:

• access the personal data we hold about you;
• correct inaccurate personal data;
• ask us to delete your personal data;
• restrict how we process your personal data;
• receive your personal data in a portable format;
• object to processing based on our legitimate interests;
• withdraw consent, where processing is based on consent;
• lodge a complaint with the data protection authority in the country where you live or work, or in the UK with the Information Commissioner's Office.

To exercise these rights, contact us at innotent.ltd@gmail.com. Please see section 13 about identifying your information when the App has no accounts.

14.4 Automated decision-making

We do not make decisions that have legal or similarly significant effects on you based solely on automated processing.

14.5 International transfers

See section 11.

15. Additional information for users in the United States (including California)

15.1 Categories of personal information

In the past 12 months, we have collected the following categories of personal information, as described in this Privacy Policy:

• Identifiers: app instance ID, anonymous user ID and IP address.
• Commercial information: purchase and subscription history.
• Internet or other electronic network activity: App usage events and ad attribution information.
• Approximate geolocation: country or city derived from IP address. We do not collect precise location.
• Audio and visual information: videos you choose to process with the Eye Contact feature.
• Other information you provide: script descriptions for AI script generation and the content of emails you send us.

We collect this information from you, from your device, and from Apple and our service providers. We use it for the purposes in section 6 and disclose it for business purposes to the service providers in section 7. We keep it as described in section 9.

15.2 No sale or sharing

We do not sell personal information and do not "share" it for cross-context behavioral advertising, as those terms are defined in the California Consumer Privacy Act (CCPA). We do not knowingly sell or share the personal information of consumers under 16. We do not use or disclose sensitive personal information to infer characteristics about you.

15.3 Your rights

Depending on your state of residence, you may have the right to:

• know what personal information we collect, use and disclose, and access it;
• request deletion of your personal information;
• request correction of inaccurate personal information;
• opt out of the sale or sharing of personal information, or of targeted advertising (we do not do these);
• not be discriminated against for exercising your rights.

To exercise these rights, contact us at innotent.ltd@gmail.com. You may use an authorized agent to submit a request on your behalf. We may need to verify your request. If we deny your request, you may appeal by replying to our response.

15.4 Do Not Track

The App does not track you across third-party apps or websites, and we do not currently respond to "Do Not Track" browser signals.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example when we add features or change service providers. We will update the "Last updated" date at the top of this page. If we make material changes, we will notify you in the App or by other appropriate means where required by law. Continuing to use the App after an update means you acknowledge the updated Privacy Policy.

17. Governing law

This Privacy Policy is governed by the laws of the State of Israel. This does not take away any protection you have under mandatory provisions of the law of the country where you live, including your data protection rights under the GDPR where it applies.

18. Contact us

If you have any questions about this Privacy Policy or how we handle your information, contact us: