Privacy Policy

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The short version What this policy covers

What we collect

Data we collect Other people, sensitive data

Why we use it

Our purposes and legal bases Improving clip selection Automated processing Cookies and tracking

Who else sees it

Sharing and disclosure International transfers

How long, how safe

Retention and deletion Security and breaches

Your rights

Your privacy rights When we act for a business Nigeria, Europe and the UK

Reference

Other provisions Schedules

Effective Date: 18 August 2026
Last Updated: 18 August 2026

This Privacy Policy (the "Policy") explains how ReelUse Technologies Limited, a private company limited by shares incorporated in the Federal Republic of Nigeria with company registration number RC 9782918 ("ReelUse," "we," "us," or "our"), collects, receives, records, stores, organises, uses, analyses, combines, discloses, transfers, secures, retains, deletes, and otherwise processes Personal Data in connection with ReelUse.

Registered Office: 1, Olaniyan Close, Off Mobolaji Bank Anthony Way, Ikeja, Lagos State, Nigeria, 100271
Website: https://reeluse.com
Application: https://app.reeluse.com
Privacy Contact: support@reeluse.com
Legal Contact: legal@reeluse.com

This Policy applies to our websites, web applications, desktop applications, software, subscription services, support channels, automated media-processing features, and related products and services that link to or expressly incorporate this Policy (collectively, the "Service").

This Policy should be read together with the ReelUse Terms of Use and, where applicable, the ReelUse Data Processing Addendum, Cookie Notice, Acceptable Use Policy, Refund and Cancellation Policy, Subprocessor List, order form, enterprise agreement, or other supplemental terms that expressly apply to your use of the Service.

IMPORTANT PRIVACY NOTICE

REELUSE PROCESSES AUDIOVISUAL CONTENT. CUSTOMER CONTENT MAY CONTAIN THE VOICES, IMAGES, NAMES, OPINIONS, RELIGIOUS OR PHILOSOPHICAL STATEMENTS, HEALTH INFORMATION, POLITICAL OPINIONS, PERSONAL STORIES, AND OTHER PERSONAL DATA OF SPEAKERS, GUESTS, EMPLOYEES, STUDENTS, CONGREGANTS, CUSTOMERS, CHILDREN, OR OTHER THIRD PARTIES.

IF YOU UPLOAD OR OTHERWISE SUBMIT PERSONAL DATA ABOUT ANOTHER PERSON, YOU ARE RESPONSIBLE FOR ENSURING THAT YOU HAVE AN APPROPRIATE LEGAL BASIS, AUTHORITY, NOTICE, CONSENT, RELEASE, OR OTHER PERMISSION REQUIRED BY APPLICABLE LAW. WHERE REELUSE ACTS ONLY AS A PROCESSOR FOR A BUSINESS CUSTOMER, THAT CUSTOMER REMAINS RESPONSIBLE FOR ITS DUTIES AS CONTROLLER.

REELUSE ALSO USES CERTAIN TRANSCRIPTS, CLIP-PREFERENCE SIGNALS, AND RELATED SERVICE-INTERACTION DATA TO DEVELOP, TEST, EVALUATE, TUNE, AND IMPROVE ITS OWN CLIP-SELECTION AND RANKING SYSTEMS, AS EXPLAINED IN THIS POLICY. AS OF THE EFFECTIVE DATE, REELUSE DOES NOT USE PRIVATE CUSTOMER CONTENT TO TRAIN UNRELATED GENERAL-PURPOSE GENERATIVE-AI FOUNDATION MODELS.

REELUSE DOES NOT SELL PERSONAL DATA, AND DOES NOT SHARE PERSONAL DATA FOR CROSS-CONTEXT BEHAVIOURAL ADVERTISING.

Nothing in this Policy limits any privacy or data-protection right that cannot lawfully be limited under applicable law.

PART I - GENERAL FRAMEWORK

1. PURPOSE OF THIS POLICY

1.1 This Policy is intended to provide clear information about:

• who is responsible for Personal Data processed through ReelUse;
• the categories and sources of Personal Data we process;
• the purposes for which we process Personal Data;
• the lawful bases on which we rely where a lawful basis is required;
• how ReelUse processes Customer Content and transcripts;
• how ReelUse uses service-improvement and clip-preference data;
• when ReelUse acts as a controller and when it acts as a processor;
• the categories of persons with whom data may be shared;
• international transfers of Personal Data;
• retention, deletion, and backup practices;
• security and incident response;
• automated processing and profiling;
• the rights available to Data Subjects; and
• how to contact ReelUse or make a complaint.

1.2 This Policy is drafted principally with reference to the Nigeria Data Protection Act 2023 (the "NDP Act"), applicable regulations, directives, guidance and subsidiary instruments issued by the Nigeria Data Protection Commission ("NDPC"), including the Nigeria Data Protection Act General Application and Implementation Directive 2025 ("GAID 2025") where applicable.

1.3 Where the processing of Personal Data falls within the territorial scope of the EU General Data Protection Regulation (Regulation (EU) 2016/679) ("EU GDPR"), ReelUse will comply with the requirements applicable to it under the EU GDPR and applicable EEA Member State law.

1.4 Where processing falls within the territorial scope of the UK GDPR, the Data Protection Act 2018, and applicable amendments including those introduced under the Data (Use and Access) Act 2025, ReelUse will comply with the requirements applicable to it under United Kingdom data-protection law.

1.5 Other privacy laws may apply depending on the location of a Data Subject, a customer, or a particular processing activity. Where mandatory law gives a person greater rights than this Policy states, the mandatory law prevails.

2. DEFINITIONS

For purposes of this Policy:

"Account" means a registered ReelUse account.

"Applicable Data Protection Law" means the NDP Act and applicable NDPC instruments, and any other privacy, data-protection, electronic-communications, confidentiality, cybersecurity, or data-security law that applies to the relevant processing activity, including the EU GDPR or UK GDPR where applicable.

"Business Customer" means a person or entity using ReelUse for business, professional, ministry, educational, institutional, agency, organisational, commercial, or similar non-household purposes.

"Controller" means the person or entity that determines the purposes and means of processing Personal Data, or the equivalent concept under Applicable Data Protection Law.

"Customer Content" means audio, video, images, text, transcripts, subtitles, captions, documents, metadata, links, URLs, brand assets, logos, files, recordings, or other material submitted to or processed through the Service.

"Data Subject" means an identified or identifiable natural person to whom Personal Data relates.

"Derived Data" means technical, statistical, analytical, operational, or performance data derived from use of ReelUse, including clip-selection signals, likes, saves, rejections, skips, re-runs, downloads, ranking outcomes, processing metrics, feature usage, quality metrics, and similar service-interaction information.

"Job" or "Run" means a request submitted through the Service to process Customer Content and create or evaluate Outputs.

"Output" means a clip, transcript, caption, subtitle, crop, title, excerpt, ranking, score, recommendation, metadata, derivative file, or other result generated or assembled by the Service from Customer Content.

"Personal Data" means information relating to an identified or identifiable natural person and includes equivalent concepts such as personal information where applicable law uses a different term.

"Processing" includes any operation performed on Personal Data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, analysis, use, disclosure, transmission, combination, restriction, erasure, or destruction.

"Processor" means a person or entity that processes Personal Data on behalf of a Controller, or the equivalent concept under Applicable Data Protection Law.

"Sensitive Personal Data" means data treated as sensitive, special-category, or similarly protected data under Applicable Data Protection Law. Depending on the applicable law, this may include data concerning racial or ethnic origin, political opinions or affiliations, religious or philosophical beliefs, trade-union membership, genetic data, biometric data used for unique identification, health, sex life, sexual orientation, and other categories designated by law or a regulator.

"Service-Improvement Data" means the transcripts, clip-preference signals, Derived Data, quality indicators, and related information used in the limited manner described in Part V of this Policy to improve ReelUse's own selection and ranking systems.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA

3.1 ReelUse Technologies Limited is a Controller for Personal Data where ReelUse determines why and how that Personal Data is processed. Examples ordinarily include:

• Account registration and administration;
• subscription administration and billing records received by ReelUse;
• support, service communications, and feedback;
• security, authentication, fraud prevention, and abuse detection;
• website and Service analytics where ReelUse determines the analytics purpose;
• legal compliance, claims, and regulatory matters;
• ReelUse's own service-improvement processing described in this Policy; and
• corporate administration and business operations.

3.2 For Customer Content submitted by a Business Customer where that Business Customer determines the purposes for which the Personal Data in the Customer Content is collected and processed, ReelUse generally acts as a Processor on behalf of that Business Customer while providing the requested media-processing service.

3.3 A Business Customer using ReelUse may therefore be a Controller of Personal Data contained in sermons, lectures, podcasts, interviews, meetings, lessons, presentations, recordings, or other material that it submits. ReelUse's processing on behalf of such Business Customer is subject to the customer's lawful instructions, our Terms, and, where applicable, a Data Processing Addendum.

3.4 ReelUse may nevertheless act as an independent Controller for a separate processing purpose involving the same underlying information, such as security, fraud prevention, legal compliance, or the limited Service-Improvement Data processing described in this Policy. Controller and Processor roles therefore depend on the particular processing purpose, not merely on the type of file involved.

3.5 Where an individual Consumer submits his or her own content directly to ReelUse and no separate organisational Controller exists for that processing, ReelUse may act as Controller for processing necessary to provide the Service to that Consumer.

3.6 If you are unsure whether ReelUse or one of our customers is the Controller for a particular request, contact support@reeluse.com. We may need information such as the relevant Job, Run, Account, uploader, organisation, or recording before we can determine the applicable role.

4. TERRITORIAL SCOPE AND INTERNATIONAL USERS

4.1 ReelUse is established in Nigeria and provides an online service capable of being used internationally.

4.2 The NDP Act applies to ReelUse's relevant processing in Nigeria and may also apply in circumstances specified by Nigerian law.

4.3 EU GDPR obligations may apply where ReelUse's processing relates to offering goods or services to individuals in the EEA or monitoring their behaviour in circumstances falling within Article 3 of the EU GDPR.

4.4 UK GDPR obligations may apply where ReelUse's processing relates to offering goods or services to individuals in the United Kingdom or monitoring their behaviour in circumstances within the territorial scope of UK law.

4.5 Privacy enquiries and Data Subject rights requests from any jurisdiction may be sent directly to support@reeluse.com. ReelUse may request information reasonably necessary to verify identity, authority, and the processing to which a request relates.

5. DATA-PROTECTION PRINCIPLES

5.1 ReelUse seeks to process Personal Data in accordance with applicable data-protection principles, including:

• lawfulness, fairness, and transparency;
• purpose limitation;
• data minimisation;
• accuracy;
• storage limitation;
• confidentiality, integrity, and availability;
• accountability; and
• an appropriate duty of care toward Data Subjects.

5.2 We seek to design processing activities so that Personal Data is reasonably proportionate to a legitimate purpose, access is limited according to role and need, and retention is not longer than reasonably necessary for applicable purposes or legal obligations.

PART II - PERSONAL DATA WE COLLECT AND RECEIVE

6. SOURCES OF PERSONAL DATA

ReelUse may receive Personal Data from the following sources:

6.1 Directly from you, for example when you create an Account, update a profile, contact support, provide feedback, subscribe, complete a form, or communicate with us.

6.2 Through Customer Content, when you upload, import, link, or submit audio, video, text, or other media. Customer Content may contain Personal Data about you and other people.

6.3 Automatically from your use of the Service, including technical, device, log, network, security, session, performance, and feature-interaction data.

6.4 From our payment providers, Polar and Paystack, such as transaction status, plan, amount, currency, payment reference, billing country, refund status, subscription status, fraud signals, or other information needed to administer a purchase. The exact information received may vary by payment method and provider.

6.5 From linked or integrated services, where you direct ReelUse to retrieve or interact with content from a third-party service, such as through a URL or supported integration.

6.6 From Business Customers or Account administrators, where an organisation creates, invites, manages, or provides information about users authorised to use an organisational account.

6.7 From service providers and security partners, where necessary to prevent fraud, investigate abuse, protect accounts, or operate the Service.

6.8 From public or legal sources, where reasonably necessary for legal compliance, enforcement, sanctions screening where applicable, intellectual-property complaints, litigation, or protection of rights.

7. ACCOUNT AND PROFILE DATA

7.1 We may process Account and profile information such as:

• name;
• email address;
• Account identifier;
• organisation or business name, where provided;
• role or Account permissions;
• authentication and security information;
• subscription plan and entitlements;
• user preferences;
• communications preferences; and
• Account status.

7.2 We may create internal identifiers associated with an Account or user to operate, secure, and support the Service.

7.3 You are responsible for keeping Account information reasonably accurate and up to date.

8. CUSTOMER CONTENT AND AUDIOVISUAL DATA

8.1 Customer Content may include:

• video files;
• audio recordings;
• images and frames extracted from video;
• spoken words and voices;
• visual likenesses;
• names and usernames;
• presentation slides;
• logos and branding;
• music and other audio;
• metadata associated with media files;
• URLs and information associated with linked content;
• transcripts generated from recordings;
• captions and subtitles;
• timestamps and speaker segments;
• text supplied in connection with a Job or Run; and
• other information contained in or inferable from submitted media.

8.2 Customer Content may contain Personal Data of people who do not have a ReelUse Account and who may have no direct relationship with ReelUse.

8.3 Customer Content can be highly contextual. ReelUse does not assume that an uploader owns every right in a recording merely because the uploader possesses the file.

8.4 If you submit Customer Content on behalf of another person or organisation, you are responsible for satisfying the transparency, lawful-basis, consent, confidentiality, and other obligations applicable to your collection and disclosure of that content to ReelUse.

9. TRANSCRIPTS, CAPTIONS, AND CONTENT-DERIVED INFORMATION

9.1 ReelUse may generate transcripts, captions, subtitles, speaker segments, timing data, candidate clip boundaries, titles, summaries, rankings, scores, and other information from Customer Content.

9.2 A transcript may itself constitute Personal Data even when the original recording has been deleted from a local user device, because the transcript may identify or describe a speaker or another person.

9.3 A transcript may also reveal Sensitive Personal Data depending on what is said. For example, a sermon may reveal religious beliefs; a political interview may reveal political opinions; a testimony may reveal health information; or a counselling discussion may reveal intimate personal information.

9.4 ReelUse therefore treats transcripts as potentially sensitive content and applies the distinctions in Part IV and Part V of this Policy.

10. JOB, RUN, OUTPUT, AND WORKFLOW DATA

10.1 We may process information concerning the operation of Jobs or Runs, including:

• Job or Run identifiers;
• source file or URL information;
• submission and completion times;
• processing status;
• duration and media properties;
• candidate clips;
• output length and position;
• clip rankings and scores;
• caption or style selections;
• brand settings applied to outputs;
• exports and downloads;
• re-runs or regeneration actions;
• user likes, saves, approvals, rejections, skips, or preference signals;
• errors or failed processing events; and
• other workflow information reasonably necessary to provide and improve the Service.

11. DEVICE, LOG, NETWORK, AND TECHNICAL DATA

11.1 When you access the Service, we may automatically process technical information such as:

• Internet Protocol address;
• browser type and version;
• operating system;
• device type;
• language and locale;
• approximate geographic region derived from network information;
• referring and exit pages;
• date and time of access;
• session and authentication events;
• network and request logs;
• error and crash information;
• performance metrics;
• feature-interaction events;
• security events; and
• identifiers used to maintain sessions or protect against abuse.

11.2 We do not represent that every category above is collected in every interaction. The exact data depends on the Service feature, device, configuration, and providers used at the relevant time.

12. PAYMENT AND TRANSACTION DATA

12.1 ReelUse accepts payments in United States dollars through Polar, which acts as merchant of record for those transactions. ReelUse accepts payments in Nigerian naira through Paystack. On the naira rail ReelUse is the seller and merchant of record, so a refund, a chargeback or a tax question about a naira payment is ours to answer and not Paystack's.

12.2 Depending on the transaction, payment provider, and jurisdiction, a payment provider may process information such as your name, billing address, payment card details, bank or account information, tax information, payment authentication information, device information, and fraud-prevention information under its own privacy terms.

12.3 ReelUse does not need to receive or store every piece of payment-card information processed by a payment provider. We may instead receive transaction references, status, plan, amount, currency, subscription dates, country, invoice details, refund information, and information reasonably necessary for customer support, accounting, fraud prevention, and subscription administration.

12.4 A payment provider may act as a merchant of record for qualifying transactions. Polar currently acts as merchant of record for payments made in United States dollars. Where a provider acts as merchant of record, the purchaser may contract with that provider for the transaction and the provider may act as an independent Controller for payment, tax, fraud-prevention, and related legal purposes under its own privacy notices.

12.5 Polar and Paystack may each process payment and transaction information as a service provider or Controller for purposes established by their own legal obligations and services.

12.6 ReelUse is not responsible for the independent privacy practices of payment providers, although we seek to use providers appropriate to our business and Applicable Law.

13. COMMUNICATIONS, SUPPORT, AND FEEDBACK DATA

13.1 If you contact ReelUse, we may process:

• your name and email address;
• the contents of your message;
• support ticket information;
• screenshots or files you voluntarily send us;
• Account and Job information needed to investigate an issue;
• correspondence history;
• feedback, feature requests, bug reports, and survey responses; and
• internal notes reasonably necessary to resolve the request.

13.2 Do not send passwords, complete payment-card details, or unnecessary Sensitive Personal Data through support channels.

14. FRAUD, SECURITY, COMPLIANCE, AND ENFORCEMENT DATA

14.1 We may generate or receive information concerning suspected fraud, abuse, copyright complaints, prohibited content, repeated account creation, compromised credentials, suspicious network activity, payment disputes, chargebacks, sanctions or legal restrictions where applicable, and violations of our Terms or policies.

14.2 This information may include technical logs, Account identifiers, transaction references, complaint correspondence, evidence submitted by users or rights holders, and records of enforcement actions.

PART III - THIRD-PARTY AND SENSITIVE PERSONAL DATA

15. PERSONAL DATA ABOUT PEOPLE WHO ARE NOT REELUSE USERS

15.1 Many recordings contain Personal Data about people who did not upload the recording themselves. Examples include speakers, guests, interviewees, congregants, students, employees, customers, conference attendees, or members of an audience.

15.2 If a Business Customer determines why a recording is made and why it is submitted to ReelUse, that Business Customer will generally be the Controller responsible for providing required privacy information and establishing a lawful basis for processing.

15.3 ReelUse may not have a direct method of contacting every person appearing in Customer Content. Applicable law recognises that direct notice may not always be required where a person already has the information or where providing individual notice would be impossible or involve disproportionate effort, subject to the conditions and safeguards in the applicable law.

15.4 This does not relieve customers from their own legal duties. Customers should not use ReelUse as a means to bypass recording consent, privacy notice, confidentiality, employment, education, safeguarding, or other requirements.

15.5 A person who appears or speaks in Customer Content may contact support@reeluse.com. Where ReelUse is only the Processor, we may refer the request to the relevant customer Controller and assist that customer as required by law and any applicable Data Processing Addendum.

16. SENSITIVE PERSONAL DATA AND SPECIAL-CATEGORY DATA

16.1 ReelUse is not designed as a medical-record system, counselling-record repository, human-resources investigation platform, biometric identification system, or other specialised repository for high-risk regulated data.

16.2 Nevertheless, the nature of sermons, lectures, interviews, podcasts, testimonies, lessons, and other recordings means Customer Content may incidentally include Sensitive Personal Data.

16.3 Where ReelUse acts solely as Processor for Customer Content, the customer Controller is responsible for identifying a valid lawful basis and, where required, an additional condition for processing Sensitive Personal Data. ReelUse will process such data only under lawful instructions, subject to our Terms, DPA, and security controls.

16.4 Where ReelUse acts as an independent Controller, ReelUse will not intentionally process Sensitive Personal Data unless an applicable legal condition permits that processing. Depending on the jurisdiction and purpose, such a condition may include explicit consent, establishment or defence of legal claims, vital interests, substantial public interest where provided by law, data manifestly made public by the Data Subject where legally sufficient, or another condition recognised by Applicable Data Protection Law.

16.5 Service-improvement limitation. ReelUse does not rely solely on ordinary legitimate interests as a blanket justification to use Sensitive Personal Data from Customer Content for secondary service-improvement purposes. Where a transcript or other content used for improvement contains Sensitive Personal Data, ReelUse will take reasonable steps appropriate to the processing to minimise, filter, mask, pseudonymise, aggregate, exclude, or otherwise reduce the use of the sensitive information, or obtain/use an additional lawful condition where required.

16.6 ReelUse does not intentionally use Sensitive Personal Data from Customer Content to create advertising profiles about speakers, guests, or other individuals.

16.7 You should not submit highly confidential or regulated information unless you have determined that ReelUse is appropriate for that data and you have all required authority, safeguards, and contractual protections.

17. CHILDREN AND PERSONS LACKING LEGAL CAPACITY

17.1 ReelUse Accounts are intended only for people who are at least 18 years old and have reached the legal age of majority in their jurisdiction. If the age of majority in your jurisdiction is higher than 18, you must have reached that higher age.

17.2 ReelUse does not knowingly permit children to create or operate Accounts.

17.3 Customer Content may nevertheless contain images or voices of children. The uploader or customer is responsible for obtaining parental or guardian consent, safeguarding approval, or another lawful basis where required.

17.4 Under Nigerian law, where reliance on consent is necessary for processing Personal Data of a child or person lacking legal capacity, parental or legal-guardian consent and appropriate age/consent verification may be required, subject to statutory exceptions.

17.5 If ReelUse becomes aware that a child has created an Account contrary to our Terms, we may suspend the Account and take reasonable steps to delete or restrict the relevant data, subject to legal, security, and preservation requirements.

17.6 If a parent or guardian believes a child has created an Account or that ReelUse is independently processing a child's Personal Data unlawfully, the parent or guardian may contact support@reeluse.com.

PART IV - WHY WE PROCESS PERSONAL DATA AND OUR LAWFUL BASES

18. GENERAL LAWFUL-BASE FRAMEWORK

18.1 Where ReelUse acts as Controller and Applicable Data Protection Law requires a lawful basis, we may rely on one or more of the following, depending on the particular purpose:

• Contractual necessity: processing necessary to provide the Service you requested, administer your Account, or take steps at your request before entering a contract;
• Legitimate interests: processing necessary for legitimate interests pursued by ReelUse or a third party, where those interests are not overridden by the rights and freedoms of the Data Subject;
• Consent: where you have given valid consent for a specific purpose and may withdraw it as provided by law;
• Legal obligation: processing necessary to comply with law, regulation, court orders, lawful regulatory requests, tax, accounting, or other binding obligations;
• Vital interests: limited processing necessary to protect someone's life or comparable vital interests where recognised by law; and
• Public interest or official authority: only where a valid legal basis exists and the processing is applicable to ReelUse.

18.2 ReelUse does not treat acceptance of our Terms as universal consent for every processing activity. Different processing purposes may rely on different lawful bases.

18.3 Where ReelUse relies on legitimate interests, we seek to assess:

• the legitimate purpose being pursued;
• whether the processing is reasonably necessary for that purpose;
• what a Data Subject would reasonably expect;
• the nature and sensitivity of the Personal Data;
• the likely impact on the Data Subject;
• available safeguards; and
• the Data Subject's rights, including the right to object where applicable.

18.4 Where ReelUse acts solely as Processor for a Business Customer, the Business Customer determines the lawful basis for the underlying processing. ReelUse's legal basis for acting is its processor relationship and lawful instructions; it does not replace the customer's duty to establish a valid basis for the Personal Data it controls.

19. PROVIDING AND OPERATING THE SERVICE

19.1 We process Personal Data to:

• create and administer Accounts;
• authenticate users;
• receive and process Jobs or Runs;
• upload, download, transmit, and store media;
• transcribe recordings;
• identify and rank candidate moments;
• generate captions, subtitles, crops, titles, and Outputs;
• apply user-selected branding or formatting;
• display, save, and deliver Outputs;
• maintain user preferences and subscription entitlements;
• provide support and troubleshoot technical issues; and
• perform other functions expressly requested through the Service.

19.2 For individual Account data, this processing is generally necessary to perform our contract with you or take steps at your request.

19.3 For Personal Data contained in Business Customer Content, ReelUse generally performs this processing as Processor under the customer's instructions.

20. ACCOUNT, SUBSCRIPTION, AND BILLING ADMINISTRATION

20.1 We process Account and transaction information to:

• create subscriptions;
• administer monthly and annual plans;
• process renewals;
• determine entitlements and usage limits;
• issue or reconcile invoices and receipts;
• administer cancellations and refunds;
• investigate failed payments and chargebacks;
• maintain accounting records; and
• comply with tax and financial obligations.

20.2 Lawful bases may include contractual necessity, legitimate interests in administering the business and preventing fraud, and legal obligations relating to tax, accounting, or financial records.

21. SECURITY, FRAUD PREVENTION, AND SERVICE INTEGRITY

21.1 We may process Personal Data to:

• authenticate users and sessions;
• detect compromised credentials;
• prevent unauthorised access;
• detect fraud, abuse, spam, scraping, malicious automation, or circumvention;
• investigate suspicious activity;
• secure networks, systems, and infrastructure;
• enforce technical limits and policies;
• maintain logs necessary for security and incident response; and
• protect ReelUse, users, third parties, and the public from harm.

21.2 This processing may rely on legitimate interests and legal obligations. In emergencies, vital interests or other lawful grounds may apply.

22. SUPPORT, SERVICE COMMUNICATIONS, AND CUSTOMER RELATIONSHIP

22.1 We process Personal Data to respond to support requests, send transaction and service messages, investigate bugs, communicate security notices, notify users of material changes, and maintain the customer relationship.

22.2 Service communications that are necessary to operate an Account are not marketing merely because they are sent by email.

22.3 This processing generally relies on contractual necessity, legitimate interests, or legal obligations, depending on the communication.

23. PRODUCT ANALYTICS AND PERFORMANCE

23.1 We may process usage, feature-interaction, reliability, device, and performance information to understand how the Service functions, diagnose errors, allocate infrastructure, measure performance, improve usability, and plan capacity.

23.2 Where analytics involve Personal Data and ReelUse acts as Controller, this processing may rely on legitimate interests, subject to the Data Subject's rights and applicable cookie/electronic-communications rules.

23.3 Where consent is legally required for a particular analytics cookie or similar storage/access technology, ReelUse will seek consent before using that technology for the relevant purpose.

24. LEGAL COMPLIANCE, DISPUTES, AND CLAIMS

24.1 We may process Personal Data to:

• comply with binding laws and regulations;
• respond to valid court, regulatory, law-enforcement, or governmental requests;
• establish, exercise, or defend legal claims;
• investigate intellectual-property complaints;
• maintain evidence concerning Terms violations or abuse;
• protect legal rights and property; and
• obtain professional legal, accounting, security, or compliance advice.

24.2 Applicable lawful bases may include legal obligation, legitimate interests, establishment or defence of legal claims, or another basis recognised by law.

25. MARKETING AND PROMOTIONAL COMMUNICATIONS

25.1 ReelUse may send promotional communications where permitted by law.

25.2 Depending on the jurisdiction and context, marketing may rely on consent or legitimate interests, subject to applicable electronic-marketing rules.

25.3 Where a marketing message is subject to an opt-out requirement, you may use the unsubscribe mechanism in the message or contact support@reeluse.com.

25.4 Opting out of promotional messages does not prevent us from sending non-promotional service, billing, security, or legal communications that are necessary for your Account or our legal obligations.

PART V - SERVICE-IMPROVEMENT DATA AND REELUSE SELECTION ALGORITHMS

26. HOW REELUSE IMPROVES CLIP SELECTION

26.1 ReelUse's core product depends on identifying useful moments within long-form recordings. To improve that capability, ReelUse may use Service-Improvement Data to develop, test, evaluate, tune, calibrate, and improve its own proprietary clip-selection, ranking, recommendation, scoring, and quality-control systems.

26.2 Service-Improvement Data may include:

• transcripts generated from Jobs or Runs;
• candidate clip boundaries;
• candidate clip ranking and score information;
• which candidate clips a user marks as liked, preferred, saved, approved, or useful;
• which clips a user rejects, skips, replaces, or regenerates;
• download and re-run behaviour;
• output length and source position;
• quality and performance indicators;
• feature-interaction data associated with content selection;
• pseudonymised or de-identified quality metrics; and
• other derived indicators reasonably related to improving ReelUse's ability to select and rank useful moments.

26.3 The purpose of this processing is to improve the ReelUse Service itself, including reducing poor selections, improving ranking quality, understanding what users consider useful, evaluating algorithm changes, and making the Service more effective.

27. LAWFUL BASIS FOR SERVICE-IMPROVEMENT PROCESSING

27.1 To the extent Service-Improvement Data constitutes ordinary Personal Data and ReelUse acts as Controller for this improvement purpose, ReelUse generally relies on its legitimate interests in developing, securing, evaluating, and improving its own product, subject to the balancing requirements of Applicable Data Protection Law.

27.2 Relevant safeguards may include purpose limitation, access restriction, data minimisation, pseudonymisation, de-identification where reasonably feasible, limited retention, deletion controls, and exclusion or additional safeguards for Sensitive Personal Data.

27.3 Where legitimate interests cannot lawfully support a particular improvement activity, ReelUse will use another lawful basis or will not perform that processing.

27.4 Where consent is required, ReelUse will seek consent in a manner intended to be specific, informed, affirmative, and capable of withdrawal as required by applicable law.

28. SENSITIVE DATA IN SERVICE-IMPROVEMENT PROCESSING

28.1 A transcript can incidentally reveal Sensitive Personal Data even where ReelUse's algorithm is interested only in linguistic structure, clip quality, or user preference.

28.2 ReelUse does not treat the presence of Customer Content in the Service as blanket consent to use every Sensitive Personal Data element for independent product-improvement purposes.

28.3 Where required by Applicable Data Protection Law, ReelUse will use appropriate measures to avoid or minimise Sensitive Personal Data in independent improvement processing, or rely on an additional valid condition such as explicit consent before using that Sensitive Personal Data for the relevant purpose.

28.4 ReelUse does not intentionally use religious belief, political opinion, health status, sex life, sexual orientation, racial or ethnic origin, or similar sensitive traits as advertising attributes or as criteria to make high-impact decisions about an individual.

29. NO CURRENT TRAINING OF UNRELATED GENERAL-PURPOSE GENERATIVE AI MODELS

29.1 As of the Effective Date, ReelUse does not use private Customer Content to train unrelated general-purpose generative-artificial-intelligence foundation models.

29.2 This statement does not prevent ReelUse from using the Service-Improvement Data described above to improve ReelUse's own specialised clip-selection, ranking, scoring, recommendation, or quality systems.

29.3 ReelUse may use third-party infrastructure or technology providers to perform specific processing functions. ReelUse does not intentionally authorise a Processor to use private Customer Content for that Processor's unrelated general-purpose model training where doing so would conflict with ReelUse's contractual commitments or Applicable Data Protection Law.

29.4 If ReelUse later proposes a materially broader use of private Customer Content for general-purpose or unrelated model training, ReelUse will update its legal notices and establish an appropriate lawful basis before beginning that materially broader processing where required by law.

30. AGGREGATED, DE-IDENTIFIED, AND ANONYMISED INFORMATION

30.1 ReelUse may create aggregated, statistical, pseudonymised, de-identified, or anonymised information from Service usage where permitted by law.

30.2 Information that has been irreversibly anonymised so that no person is reasonably identifiable is not Personal Data under data-protection laws that recognise true anonymisation.

30.3 ReelUse may retain and use genuinely anonymised information for analytics, benchmarking, research, capacity planning, quality measurement, product development, security, and business planning without treating that information as identifiable Personal Data.

30.4 Pseudonymised information remains Personal Data where ReelUse or another person can reasonably re-identify the Data Subject using additional information. ReelUse does not describe pseudonymised information as anonymous merely because direct identifiers have been removed.

31. DELETION AND PRIOR ALGORITHM LEARNING

31.1 When a user deletes a Job or Run, ReelUse removes the Customer Content and identifiers associated with that Job or Run from active Service systems. Before removal, ReelUse may retain a de-identified operational summary limited to facts such as processing stage, elapsed time, source category, count of generated Outputs, quality score bands, and cost. The retained summary does not contain the recording, transcript, clip, title, filename, account identifier, Job identifier, or a link that restores ordinary account access.

31.2 When an Account is deleted, ReelUse removes account identifiers, credentials, Customer Content, transcripts, clips, brand assets, and payment-provider identifiers from active Service systems. We detach retained operational, quality and accounting records from the Account and remove free-text feedback and content-bearing metadata before retaining them for aggregate reliability, capacity, product-quality and accounting analysis.

31.3 One record survives Account deletion. ReelUse retains a one-way cryptographic value derived from the Account email address, together with the number of free-allowance Runs already used and the date on which it was recorded. The value cannot be reversed to recover the email address, and is never used to identify, contact, profile, market to, or re-link a former user. It exists for one purpose only: to prevent the same address obtaining a further free allowance by repeatedly deleting and re-creating an Account. It is recorded only for Accounts on the free tier, never for an Account that has paid, and it ceases to have any effect one month after it is recorded.

31.4 Where an identifiable transcript or other identifiable copy of Customer Content remains in an active Service-Improvement Data store controlled by ReelUse, ReelUse will apply deletion and Data Subject rights as required by Applicable Data Protection Law.

31.5 Deletion of a source Job or identifiable transcript does not necessarily reverse statistical or algorithmic learning that was lawfully incorporated into model parameters or ranking logic before the deletion request, where the resulting parameters do not themselves contain a reasonably retrievable copy of the deleted content or otherwise constitute Personal Data attributable to the Data Subject. ReelUse will not rely on this paragraph to retain a recoverable copy of deleted Customer Content merely by relabelling it as a model or algorithm.

PART VI - AUTOMATED PROCESSING AND PROFILING

32. AUTOMATED CONTENT ANALYSIS

32.1 ReelUse uses automated systems to process Customer Content. Depending on the feature, this may include transcription, segment detection, scoring, ranking, caption generation, crop selection, formatting, or recommendation.

32.2 These systems may analyse language, timing, structure, context, audio or video characteristics, user-preference signals, and other information relevant to identifying and ranking potential clips.

32.3 Automated systems can be inaccurate. A high ranking or recommendation does not mean that a clip is factually accurate, legally safe, non-defamatory, non-infringing, or appropriate to publish.

33. PROFILING AND SIGNIFICANT AUTOMATED DECISIONS

33.1 Some Service functionality may involve automated analysis of content or user interactions that could be considered profiling under certain data-protection laws.

33.2 ReelUse's ordinary clip-selection and ranking systems are designed to decide which portions of content may be useful to a user. They are not designed to make decisions about an individual's credit, employment, insurance, housing, medical treatment, legal entitlement, criminal responsibility, or similar matters producing legal or comparably significant effects.

33.3 ReelUse does not currently use automated decision-making based solely on Personal Data to make decisions about a user that produce legal effects or similarly significant effects in the sense contemplated by Article 22 EU GDPR or equivalent law.

33.4 If ReelUse introduces such high-impact automated decision-making in the future, we will provide the notices, safeguards, rights, human-review options, or other measures required by Applicable Data Protection Law before applying the processing where required.

PART VII - COOKIES, SIMILAR TECHNOLOGIES, AND ONLINE TRACKING

34. COOKIES AND LOCAL STORAGE

34.1 The Website and Application may use cookies, local storage, pixels, SDKs, or similar technologies to maintain sessions, authenticate users, remember preferences, secure the Service, measure performance, and, where implemented, perform analytics.

34.2 Some technologies may be strictly necessary for the Service to function. Other technologies may be optional under Applicable Law.

34.3 Where consent is legally required for a non-essential cookie or similar technology, ReelUse will seek the required consent before activating that technology for the relevant user or jurisdiction.

34.4 The cookie banner saves your choice in your browser and does not reopen after you choose. To choose again, clear this site's saved data in your browser, then return. You may also control certain technologies through browser or device settings.

34.5 Blocking strictly necessary technologies may prevent parts of the Service from operating correctly.

34.6 The specific non-essential technologies ReelUse currently uses, all subject to the consent described in 34.3, are set out below. Each provider acts as an independent Controller for its own processing and applies its own privacy notice:

• Google Analytics (Google LLC), which measures website traffic and how the public pages are used. See policies.google.com/privacy.
• Microsoft Clarity (Microsoft Corporation), which provides session analytics and heatmaps that help us understand and improve the public pages. See privacy.microsoft.com.
• Meta Pixel (Meta Platforms, Inc.), which measures the effectiveness of our advertising and helps us reach relevant audiences. See facebook.com/privacy/policy.
• TikTok Pixel (TikTok), which measures the effectiveness of our advertising and helps us reach relevant audiences. See the TikTok privacy policy.

34.7 These technologies load on the public pages of the site: the marketing pages, the Help centre, the legal pages (Terms, Privacy, Refunds and DMCA), the status page, the sign-up and sign-in pages, and the unsubscribe page. They never load inside the signed-in Application, so they do not observe your workspace, recordings, transcripts, or Outputs.

34.8 To measure whether an advertisement led to a sign-up or a subscription, ReelUse may send a limited record of that event to Meta and TikTok directly from our servers. Any email address included is pseudonymised before it is sent, by a one-way conversion that makes the address unreadable in the record itself. That reduces identifiability rather than removing it: the recipient can still match the converted value against addresses it already holds, which is the purpose of sending it. No Customer Content (no recordings, transcripts, or Outputs) is included.

34.9 You may decline all of the above on the cookie banner. Declining does not affect your ability to use the Service. The banner does not provide a reopen control: to make a new choice, clear this site's saved data in your browser, then return.

35. DO-NOT-TRACK AND GLOBAL PRIVACY SIGNALS

35.1 Browser "Do Not Track" signals are not governed by a single universal technical or legal standard. ReelUse will respond to legally binding browser-based opt-out signals where Applicable Law requires us to do so and the signal is applicable to our processing.

35.2 This Policy does not promise support for every voluntary signal or specification that is not legally required or technically implemented by ReelUse.

PART VIII - HOW WE DISCLOSE OR SHARE PERSONAL DATA

36. SERVICE PROVIDERS AND SUBPROCESSORS

36.1 ReelUse may engage service providers to perform functions necessary to operate the Service. Categories may include:

• cloud infrastructure and hosting;
• storage, content-delivery, and backup services;
• transcription, media-processing, and AI-related technical services;
• database and infrastructure services;
• email and communications delivery;
• customer support systems;
• monitoring, logging, diagnostics, and error reporting;
• analytics providers;
• cybersecurity, anti-abuse, and fraud-prevention providers;
• payment providers;
• accounting, tax, legal, and professional advisers; and
• other technology vendors reasonably necessary to operate the Service.

36.2 Where a provider processes Personal Data on ReelUse's behalf as Processor or subprocessor, ReelUse will seek to impose contractual data-protection obligations appropriate to the processing and Applicable Data Protection Law.

36.3 Where a provider acts as an independent Controller, its own privacy notice and legal obligations may also apply.

36.4 Business Customers requiring a list of material subprocessors for controller-to-processor compliance may request the then-current information from support@reeluse.com or rely on a public Subprocessor List if ReelUse publishes one.

36.5 ReelUse does not sell Personal Data, and does not disclose Personal Data to third parties for their own advertising, marketing, or cross-context behavioural advertising purposes. Disclosures are limited to the purposes described in this Policy.

37. PAYMENT PROVIDERS

37.1 ReelUse may disclose transaction-related information to Polar, Paystack, banks, card networks, payment methods, tax or financial service providers, and other parties reasonably necessary to process payments, refunds, disputes, fraud checks, or legally required financial administration.

37.2 Payment providers may receive information directly from you, including information ReelUse never receives.

37.3 Where a payment provider acts as merchant of record, that provider may independently determine processing necessary for order fulfilment, payment processing, tax, fraud prevention, legal compliance, and related purchaser matters. Polar currently acts as merchant of record for payments made in United States dollars.

38. ORGANISATIONAL ACCOUNTS AND AUTHORISED USERS

38.1 If your Account is associated with a Business Customer, organisation, employer, agency, church, school, or other entity, authorised administrators may be able to manage the Account, assign permissions, view billing or usage information, and access content or Outputs consistent with the Service's permissions model.

38.2 Your organisation's own privacy policies may apply to its use of your Personal Data. ReelUse is not responsible for an organisation's independent decisions about employment, discipline, publishing, education, ministry, or other matters merely because the organisation uses ReelUse.

39. THIRD-PARTY INTEGRATIONS AND USER-DIRECTED DISCLOSURES

39.1 If you connect, link, import from, export to, or otherwise direct ReelUse to interact with a third-party service, Personal Data may be disclosed to or received from that service as necessary to carry out your instruction.

39.2 Third-party platforms may independently collect information about your activity and apply their own privacy policies, terms, API rules, and account controls.

39.3 ReelUse is not responsible for the privacy practices of a third-party service that is not controlled by ReelUse.

40. LEGAL, REGULATORY, AND SAFETY DISCLOSURES

40.1 ReelUse may preserve, access, or disclose Personal Data where we reasonably believe disclosure is required or permitted by Applicable Law, including in response to a valid court order, subpoena, regulatory demand, law-enforcement request, or other binding legal process.

40.2 Where legally permitted and appropriate, we may notify the affected customer before disclosure. We are not required to challenge every request.

40.3 ReelUse may also disclose information where permitted by law and reasonably necessary to protect the rights, property, security, or safety of ReelUse, our users, third parties, or the public; investigate fraud or cyberattack; or address an emergency involving imminent serious harm.

41. PROFESSIONAL ADVISERS

41.1 We may disclose Personal Data to lawyers, accountants, auditors, insurers, security professionals, consultants, or other professional advisers where reasonably necessary for advice, compliance, claims, corporate administration, or protection of legal rights.

41.2 Such disclosures are subject to applicable confidentiality, professional, contractual, or legal obligations.

42. BUSINESS TRANSFERS AND CORPORATE EVENTS

42.1 Personal Data may be disclosed or transferred in connection with an actual or proposed merger, acquisition, financing, investment, reorganisation, sale of assets, insolvency, restructuring, or similar corporate transaction.

42.2 Where appropriate, ReelUse will seek confidentiality protections during diligence and will require a successor to process transferred Personal Data consistently with applicable law and binding commitments.

42.3 Nothing in this Section authorises a buyer or investor to use Personal Data for an unrelated purpose contrary to Applicable Data Protection Law merely because the data was made available during a corporate event.

PART IX - INTERNATIONAL DATA TRANSFERS

43. PROCESSING OUTSIDE NIGERIA

43.1 ReelUse is a cloud-based service and may use providers or infrastructure located outside Nigeria. As a result, Personal Data may be processed in countries other than the country in which the Data Subject resides.

43.2 We do not state in this Policy that all Personal Data remains exclusively in Nigeria unless a specific product or written enterprise commitment expressly says so.

43.3 Where a transfer of Personal Data outside Nigeria is subject to Sections 41-42 of the NDP Act or applicable NDPC requirements, ReelUse will seek to rely on a transfer basis recognised by Nigerian law, which may include an applicable adequacy determination, approved or recognised transfer instrument, contractual or other safeguards, consent where legally valid, or another statutory ground appropriate to the transfer.

44. EEA INTERNATIONAL TRANSFERS

44.1 Where the EU GDPR applies to a transfer from the EEA to a country that is not covered by an applicable European Commission adequacy decision, ReelUse will use an appropriate transfer mechanism where required.

44.2 Depending on the circumstances, this may include the European Commission's Standard Contractual Clauses, together with supplementary measures or transfer assessments where legally required, or another mechanism permitted by Chapter V of the EU GDPR.

44.3 The fact that this Policy lists a possible transfer mechanism does not mean that every mechanism is used for every transfer. The mechanism depends on the relevant parties, locations, provider contracts, and law in force at the time.

45. UNITED KINGDOM INTERNATIONAL TRANSFERS

45.1 Where the UK GDPR applies to a restricted transfer of Personal Data, ReelUse will use a transfer mechanism recognised under UK law where required.

45.2 Depending on the circumstances, this may include an applicable UK adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved EU Standard Contractual Clauses, or another lawful mechanism, together with any legally required transfer-risk or data-protection assessment.

46. ACCESS TO TRANSFER INFORMATION

46.1 Where Applicable Data Protection Law gives you a right to information about safeguards used for an international transfer, you may contact support@reeluse.com.

46.2 We may redact confidential commercial terms, security information, or information concerning third parties where law permits, while providing the information required by Applicable Data Protection Law.

PART X - DATA RETENTION, DELETION, AND BACKUPS

47. GENERAL RETENTION PRINCIPLE

47.1 ReelUse seeks to retain Personal Data for no longer than is reasonably necessary for the purposes for which it was processed, taking into account:

• the nature and sensitivity of the data;
• the purpose of processing;
• whether the purpose can be achieved using less data;
• Account status;
• customer deletion choices;
• security and fraud risks;
• contractual requirements;
• legal limitation periods;
• tax and accounting obligations;
• regulatory requirements;
• dispute and claims preservation; and
• backup and disaster-recovery cycles.

47.2 Different categories of Personal Data may therefore have different retention periods.

48. CUSTOMER CONTENT AND JOB DELETION

48.1 Customer Content associated with a Job or Run is ordinarily retained while that Job or Run remains available in the user's Account, subject to product-specific storage limits or plan terms.

48.2 When you delete a Job or Run, ReelUse removes the Customer Content and associated Outputs from active Service systems. We retain only the de-identified operational and accounting facts described in Section 31; those facts cannot be opened in the product or associated with your Account.

48.3 Deletion of a Job or Run removes associated Outputs from active Service systems where those Outputs are stored as part of that Job, subject to technical implementation and lawful retention grounds.

48.4 You are responsible for downloading Outputs and maintaining your own backups of files you need before deleting a Job or Account.

49. ACCOUNT DELETION

49.1 When you delete your Account, ReelUse removes Customer Content and direct Account identifiers from active Service systems. Retained operational, quality, usage and accounting facts are de-identified and cannot be returned to the former Account.

49.2 Account deletion may not require immediate deletion of every record about the former Account. ReelUse may retain de-identified aggregates and limited transaction, security, fraud, complaint, legal and administrative records where reasonably necessary and lawful.

49.3 Subscription cancellation or expiry is not the same as Account deletion. A user who cancels a Paid Plan must separately delete the Account or Jobs if the user wishes to trigger those deletion functions.

50. BACKUPS AND DISASTER RECOVERY

50.1 Residual copies of deleted data may remain temporarily in encrypted backups, disaster-recovery systems, replicated infrastructure, or similar systems that are not ordinarily used for active user processing.

50.2 Such residual copies are deleted, overwritten, or rendered inaccessible in the ordinary backup rotation and disaster-recovery lifecycle, unless preservation is required by law or for a specific security or legal purpose.

50.3 ReelUse does not promise instantaneous deletion from every backup copy at the exact moment a user presses a delete button where doing so is technically disproportionate or inconsistent with reliable disaster-recovery practices.

51. LEGAL, FINANCIAL, SECURITY, AND DISPUTE RETENTION

51.1 ReelUse may retain information after deletion where reasonably necessary to:

• comply with tax, accounting, corporate, financial, or regulatory obligations;
• process or document refunds, payment disputes, and chargebacks;
• investigate or prevent fraud, abuse, infringement, or cyber incidents;
• preserve evidence;
• establish, exercise, or defend legal claims;
• comply with a lawful preservation request or court order;
• enforce contractual rights; or
• demonstrate compliance with legal obligations.

51.2 Where possible and appropriate, retained data will be limited to what is necessary for the relevant purpose and will not be returned to ordinary product use merely because a legal retention copy exists.

52. RETENTION OF SERVICE-IMPROVEMENT DATA

52.1 Identifiable Service-Improvement Data is retained only while reasonably necessary for the relevant improvement, evaluation, quality, legal, or security purpose, subject to rights and deletion obligations under Applicable Data Protection Law.

52.2 ReelUse may retain genuinely anonymised or irreversibly aggregated information for longer because it no longer identifies a Data Subject.

52.3 Pseudonymised Service-Improvement Data remains subject to applicable data-protection obligations where re-identification remains reasonably possible.

PART XI - DATA SECURITY AND PERSONAL DATA BREACHES

53. SECURITY MEASURES

53.1 ReelUse uses technical and organisational measures intended to provide security appropriate to the nature of the Service and the risks presented by the processing.

53.2 Depending on the system and processing, measures may include:

• access controls and least-privilege practices;
• authentication controls;
• network and infrastructure security;
• encryption in transit and/or at rest where appropriate;
• logging and monitoring;
• backup and recovery controls;
• vulnerability and patch management;
• secure development practices;
• incident-response procedures;
• staff confidentiality obligations;
• provider due diligence and contractual safeguards; and
• periodic review of security measures.

53.3 No Internet, cloud, transmission, or storage system is perfectly secure. ReelUse does not promise absolute security or that every security incident can be prevented.

53.4 Users also have responsibilities. You must protect your password and authentication methods, maintain appropriate device security, and notify us promptly of suspected Account compromise.

54. PERSONAL DATA BREACH RESPONSE

54.1 ReelUse maintains processes intended to identify, investigate, contain, document, remediate, and, where required, notify relevant parties about Personal Data breaches.

54.2 Under the NDP Act, where ReelUse acts as Controller and becomes aware of a Personal Data breach that is likely to result in a risk to the rights and freedoms of individuals, notification to the NDPC may be required within the statutory period, including the applicable 72-hour requirement. Where a breach is likely to result in high risk to a Data Subject, direct communication to the affected person may also be required by law.

54.3 Where the EU GDPR or UK GDPR applies, ReelUse will make regulatory and Data Subject notifications within applicable statutory timeframes where the relevant legal thresholds are met.

54.4 Where ReelUse acts as Processor for a Business Customer, ReelUse will notify and assist the customer Controller in accordance with Applicable Data Protection Law and the applicable Data Processing Addendum or contract.

PART XII - YOUR PRIVACY RIGHTS

55. GENERAL RIGHTS

55.1 Depending on Applicable Data Protection Law and the circumstances, you may have rights to:

• receive information about how your Personal Data is processed;
• request access to Personal Data concerning you;
• request correction or completion of inaccurate or incomplete Personal Data;
• request deletion or erasure;
• request restriction of processing;
• object to certain processing, including certain legitimate-interest processing;
• withdraw consent where processing is based on consent;
• receive certain Personal Data in a structured, commonly used, machine-readable format and request portability where applicable;
• object to or challenge certain automated decision-making or profiling;
• lodge a complaint with an applicable data-protection authority; and
• exercise other rights provided by Applicable Data Protection Law.

55.2 These rights are not absolute. Applicable law may permit or require ReelUse to refuse, restrict, delay, or charge for a request in certain circumstances, including where a request is manifestly unfounded or excessive, affects the rights of others, conflicts with legal retention requirements, or falls within a statutory exemption.

56. HOW TO EXERCISE YOUR RIGHTS

56.1 To make a privacy request, contact:

Email: support@reeluse.com
Subject line suggestion: Privacy Request / Data Subject Request

56.2 Please explain the right you wish to exercise and provide enough information for us to identify the relevant Account, Job, Run, transaction, or processing activity.

56.2A For a copy of your Personal Data (an access or portability request), email support@reeluse.com from the address on your Account and say that you want an export. We will assemble what we hold, including your profile, your Job and Run records, the transcript kept for each Run, and any Outputs still in storage, and send it to you. A self-service export is planned. Until it is available, a request by email is the route, and we will confirm the expected turnaround.

56.3 We may ask for reasonable information to verify your identity and authority before disclosing, deleting, exporting, or changing Personal Data. Verification measures will be proportionate to the nature and sensitivity of the requested data.

56.4 You may appoint an authorised representative where Applicable Law permits. We may require evidence of the representative's authority and verification of the relevant Data Subject.

56.5 We will respond within the period required by Applicable Data Protection Law. Under applicable Nigerian requirements, Data Subject access requests are generally expected to be addressed promptly and within the applicable statutory or regulatory period. EU and UK response periods apply where those regimes govern the request.

57. ACCESS

57.1 Subject to applicable exceptions, you may request confirmation of whether ReelUse processes Personal Data concerning you and request access to that data together with information required by Applicable Data Protection Law.

57.2 Access rights do not require ReelUse to disclose trade secrets, security-sensitive information, confidential information about another person, or information that would adversely affect the rights and freedoms of others beyond what the law requires.

57.3 Where a recording contains Personal Data about several people, we may need to redact, restrict, or otherwise protect third-party information before responding.

58. RECTIFICATION

58.1 You may request correction of inaccurate Personal Data or completion of incomplete Personal Data where appropriate.

58.2 Some Customer Content reflects what was actually said or recorded. A right to rectification does not necessarily require ReelUse to alter an authentic historical recording to make a speaker's original words factually different. Depending on the context, correction may instead involve Account information, metadata, annotations, or other records.

59. ERASURE AND DELETION

59.1 You may request deletion of Personal Data where a legal ground for erasure applies.

59.2 Erasure rights may be limited where continued processing is necessary for legal obligations, legal claims, freedom of expression or information where applicable, security, fraud prevention, public-interest purposes recognised by law, or other statutory exceptions.

59.3 A user may also use available product deletion controls to delete Jobs, Runs, or an Account as described in Part X.

60. RESTRICTION

60.1 Where applicable, you may request restriction of processing, for example while accuracy is contested or while an objection is being evaluated.

60.2 Restricted data may continue to be stored and may be processed for legal claims, protection of rights, or another purpose permitted by law.

61. RIGHT TO OBJECT

61.1 Where ReelUse relies on legitimate interests as Controller, you may have a right to object on grounds relating to your particular situation.

61.2 This includes the right to object to applicable Service-Improvement Data processing based on legitimate interests.

61.3 Where the law requires us to honour the objection, ReelUse will stop the relevant processing unless we demonstrate compelling legitimate grounds that override the Data Subject's interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defence of legal claims.

61.4 An objection cannot require ReelUse to reverse processing of information that has already been irreversibly anonymised so that the information is no longer Personal Data.

62. WITHDRAWAL OF CONSENT

62.1 Where processing is based on consent, you may withdraw that consent at any time through an available product control or by contacting support@reeluse.com.

62.2 Withdrawal does not affect the lawfulness of processing performed before withdrawal.

62.3 If the withdrawn consent is necessary for an optional feature, the relevant feature may become unavailable after withdrawal.

63. DATA PORTABILITY

63.1 Where required by law, you may have the right to receive Personal Data you provided to ReelUse in a structured, commonly used, machine-readable format where the processing is automated and based on consent or contract.

63.2 Portability does not require ReelUse to disclose proprietary algorithms, ranking logic, trade secrets, or information about other people beyond the requirements of law.

64. RIGHTS RELATING TO AUTOMATED DECISION-MAKING

64.1 Where Applicable Data Protection Law grants rights concerning decisions based solely on automated processing that produce legal or similarly significant effects, ReelUse will provide those rights where the legal threshold is met.

64.2 ReelUse's ordinary clip-selection recommendations are not intended to constitute such high-impact decisions. If you believe an automated ReelUse process has produced a legally or similarly significant effect about you, contact support@reeluse.com with details so that we can assess the request.

PART XIII - WHEN REELUSE IS A PROCESSOR FOR A CUSTOMER

65. BUSINESS CUSTOMER CONTENT

65.1 A Business Customer may upload Customer Content containing Personal Data for which that Business Customer is Controller.

65.2 In that situation, ReelUse ordinarily processes the Customer Content only to provide the Service, follow documented lawful instructions, secure and support the Service, and perform other processing authorised by the applicable Data Processing Addendum, Terms, or law.

65.3 The Business Customer is responsible for:

• providing required privacy notices;
• identifying the lawful basis for the collection and submission of Personal Data;
• satisfying additional conditions for Sensitive Personal Data where required;
• responding to Data Subjects in the first instance where it is Controller;
• ensuring that its instructions to ReelUse are lawful;
• ensuring that it has appropriate agreements with clients or principals where applicable; and
• determining whether ReelUse is appropriate for the customer's sector-specific compliance obligations.

66. REQUESTS FROM PEOPLE APPEARING IN CUSTOMER CONTENT

66.1 If you appear or speak in a recording submitted by a ReelUse Business Customer, the uploader or organisation may be the Controller responsible for your privacy rights concerning that recording.

66.2 If you submit a request directly to ReelUse, we may:

• ask for information to identify the relevant customer or Job;
• forward or refer the request to the customer Controller;
• assist the customer in responding;
• restrict access while the matter is investigated where appropriate; and
• separately handle any rights request concerning processing for which ReelUse is an independent Controller.

66.3 ReelUse may be unable to locate a recording from a person's name alone, particularly where the uploader did not provide that name as metadata.

67. DATA PROCESSING ADDENDUM

67.1 Business Customers that require controller-to-processor contractual terms under the NDP Act, EU GDPR, UK GDPR, or another applicable law should enter into or incorporate ReelUse's Data Processing Addendum where applicable.

67.2 The DPA may address documented instructions, confidentiality, security, subprocessors, Data Subject rights assistance, breach notification, deletion or return, international transfers, audit information, and other statutory processor obligations.

67.3 If a signed DPA or enterprise agreement imposes stricter privacy obligations than this general Policy for a particular Business Customer, the signed agreement controls for that customer to the extent of the conflict.

PART XIV - NIGERIA-SPECIFIC INFORMATION

68. RIGHTS UNDER THE NIGERIA DATA PROTECTION ACT

68.1 Where the NDP Act applies, Data Subjects may have rights provided under Part VI and other provisions of the Act, including rights relating to access, rectification, erasure where applicable, objection, withdrawal of consent, data portability, and automated decision-making, subject to statutory conditions and exemptions.

68.2 ReelUse will provide the information required by Section 27 of the NDP Act in this Policy and, where appropriate, through supplemental or just-in-time notices.

68.3 Where processing is likely to result in high risk to the rights and freedoms of Data Subjects, ReelUse will assess whether a Data Privacy Impact Assessment is required before the relevant processing begins.

69. NIGERIA DATA PROTECTION COMMISSION

69.1 If you believe ReelUse has infringed rights protected by the NDP Act, you may first contact us at support@reeluse.com so that we can investigate and attempt to resolve the matter.

69.2 You also have the right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

69.3 Information about the NDPC, complaints, and Data Subject procedures is available from the NDPC through its official channels.

70. NIGERIAN PRIVACY CONTACT

70.1 ReelUse's privacy contact for Data Subject requests, privacy enquiries, and data-protection correspondence is support@reeluse.com.

70.2 Formal written privacy correspondence may also be addressed to ReelUse Technologies Limited, 1, Olaniyan Close, Off Mobolaji Bank Anthony Way, Ikeja, Lagos State, Nigeria, 100271.

PART XV - EEA-SPECIFIC INFORMATION

71. EU GDPR RIGHTS

71.1 Where the EU GDPR applies, you may have the rights described in Articles 12-22 of the EU GDPR, subject to applicable conditions and exemptions, including rights of access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and rights relating to certain automated decision-making.

71.2 If processing is based on legitimate interests, you may object under Article 21 in circumstances provided by law.

71.3 If processing is based on consent, you may withdraw consent at any time without affecting prior lawful processing.

72. EEA SUPERVISORY AUTHORITY

72.1 Where the EU GDPR applies, you may have a right to lodge a complaint with a competent supervisory authority, including in the EEA country of your habitual residence, place of work, or the place of the alleged infringement, subject to the EU GDPR.

72.2 We encourage you to contact support@reeluse.com first where appropriate so that we have an opportunity to investigate, but doing so does not remove a statutory right to complain to a supervisory authority.

73. EEA PRIVACY REQUESTS

73.1 Individuals in the EEA may exercise applicable privacy rights by contacting ReelUse directly at support@reeluse.com.

73.2 Nothing in this section limits any right to lodge a complaint with a competent EEA supervisory authority as described in Section 72.

PART XVI - UNITED KINGDOM-SPECIFIC INFORMATION

74. UK DATA-PROTECTION RIGHTS

74.1 Where the UK GDPR applies, you may have rights including access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and rights concerning certain automated decisions, subject to applicable law, exemptions, and amendments.

74.2 UK law continues to evolve, including through amendments introduced by the Data (Use and Access) Act 2025. ReelUse will interpret this Policy consistently with mandatory UK law in force for the relevant processing activity.

75. INFORMATION COMMISSIONER'S OFFICE

75.1 Where UK law applies, you may have a right to complain to the Information Commissioner's Office (ICO).

75.2 You may contact ReelUse at support@reeluse.com before complaining if you wish to give us an opportunity to resolve the issue, but you are not required to waive any statutory complaint right.

76. UK PRIVACY REQUESTS

76.1 Individuals in the United Kingdom may exercise applicable privacy rights by contacting ReelUse directly at support@reeluse.com.

76.2 Nothing in this section limits any right to complain to the Information Commissioner's Office as described in Section 75.

PART XVII - ADDITIONAL OPERATIONAL PROVISIONS

77. CONFIDENTIALITY OF CUSTOMER CONTENT

77.1 ReelUse does not treat a user's submission of private Customer Content as permission to publish that content publicly.

77.2 ReelUse may permit authorised personnel and service providers to access non-public Customer Content only where reasonably necessary for permitted operational, support, security, legal, or service-improvement purposes described in applicable agreements and this Policy.

77.3 Access to Customer Content may occur for support or troubleshooting when necessary to resolve a user request, investigate a failure, protect the Service, or comply with law.

78. USER RESPONSIBILITY FOR PRIVACY-SENSITIVE CONTENT

78.1 ReelUse provides technology, not legal clearance for recordings.

78.2 Users should exercise particular caution before uploading:

• confidential counselling or pastoral conversations;
• medical or health records;
• disciplinary or human-resources investigations;
• private educational records;
• children's sensitive information;
• legally privileged communications;
• government-classified information;
• recordings subject to contractual confidentiality;
• biometric identification datasets;
• criminal-offence records; or
• other data subject to specialised sector rules.

78.3 A customer's ability to technically upload information does not mean that upload is legally authorised or contractually appropriate.

79. LINKS TO OTHER WEBSITES AND SERVICES

79.1 The Service may contain links to third-party websites, social platforms, payment pages, or other services.

79.2 This Policy applies to ReelUse, not to third parties we do not control. You should review the privacy notice of a third party before providing Personal Data to it.

80. CHANGES TO PROCESSING PURPOSES

80.1 If ReelUse proposes to use Personal Data for a materially new purpose that is incompatible with the purpose for which it was originally collected, we will establish an appropriate lawful basis and provide additional notice or obtain consent where required by law before the incompatible processing begins.

80.2 This principle is particularly important for materially broader AI-training or commercial-data uses. The existence of Customer Content in ReelUse does not give ReelUse unlimited permission to repurpose that content for unrelated purposes.

81. CHANGES TO THIS PRIVACY POLICY

81.1 We may update this Policy to reflect changes in law, regulation, guidance, technology, Service features, providers, security practices, or processing activities.

81.2 The updated Policy will state a revised "Last Updated" date.

81.3 Where a change materially affects how we use Personal Data already collected and Applicable Data Protection Law requires additional notice or consent, ReelUse will provide the required notice or seek the required consent before the materially different processing takes effect.

81.4 Continued use of the Service after a privacy-policy update does not, by itself, create valid consent where Applicable Data Protection Law requires specific affirmative consent for a processing purpose.

82. LANGUAGE AND INTERPRETATION

82.1 This Policy is written in English. If ReelUse provides a translation, the English version controls to the extent permitted by law unless mandatory law requires otherwise.

82.2 Headings are for convenience and do not limit the meaning of a provision.

82.3 "Including" means "including without limitation" unless the context requires otherwise.

82.4 A reference to a law includes applicable amendments, replacements, regulations, and binding subsidiary instruments, to the extent relevant to the processing.

83. CONTACT REELUSE

For privacy questions, Data Subject requests, or concerns about this Policy:

ReelUse Technologies Limited
RC 9782918
1, Olaniyan Close, Off Mobolaji Bank Anthony Way
Ikeja, Lagos State, Nigeria, 100271

Privacy Contact: support@reeluse.com
Legal Contact: legal@reeluse.com
Website: https://reeluse.com
Application: https://app.reeluse.com

If your request concerns Customer Content uploaded by a Business Customer, please identify the relevant customer, Job, Run, recording, URL, or other information that may help us locate the data without requiring unnecessary disclosure of additional Personal Data.

SCHEDULE 1 - SUMMARY OF CONTROLLER-ROLE PROCESSING

The table below summarises common ReelUse Controller-role processing. It does not replace the detailed provisions above. Where ReelUse acts only as Processor for Customer Content, the customer's lawful basis governs the underlying processing.

SCHEDULE 2 - SERVICE-IMPROVEMENT DATA

ReelUse's own service-improvement activities may include analysing:

1. transcripts generated from Jobs or Runs;
2. candidate clip boundaries and source positions;
3. which candidate clips users mark as liked, preferred, saved, approved, or useful;
4. which clips users reject, skip, regenerate, replace, or do not select;
5. download and re-run patterns;
6. clip length and ranking outcomes;
7. caption and formatting choices where relevant to quality evaluation;
8. pseudonymised or de-identified quality metrics;
9. feature usage and technical performance data; and
10. derived indicators designed to improve clip selection, ranking, scoring, recommendations, or quality.

These activities are intended to improve ReelUse's own systems. ReelUse does not, as of the Effective Date, use private Customer Content to train unrelated general-purpose generative-AI foundation models.

Where Service-Improvement Data contains Sensitive Personal Data, ReelUse will not rely on ordinary legitimate interests alone where Applicable Data Protection Law requires an additional special-category or sensitive-data condition.

SCHEDULE 3 - DATA SUBJECT REQUEST GUIDE

To help ReelUse respond efficiently, a request may include:

1. your full name;
2. the email address associated with your Account, if any;
3. the privacy right you wish to exercise;
4. relevant Job or Run identifiers, where known;
5. the organisation or Business Customer that uploaded a recording, where relevant;
6. the approximate date of the relevant processing;
7. enough information to distinguish you from another person; and
8. proof of identity or authority only where reasonably necessary and proportionate.

ReelUse may decline to provide information where disclosure would unlawfully expose another person's Personal Data, compromise security, disclose protected trade secrets beyond legal requirements, or fall within another statutory exception. Where required by law, we will explain a refusal and the available complaint or appeal route.

SCHEDULE 4 - PAYMENT PROVIDERS

Polar

ReelUse uses Polar Software, Inc. (Polar) as merchant of record for payments made in United States dollars. Polar may collect payment, identity, device, transaction, fraud-prevention, and financial information directly from the purchaser, and may independently process that information for payment processing, order fulfilment, tax, fraud prevention, refunds, legal compliance, and related purposes under its own privacy terms.

Paystack

ReelUse uses Paystack to process payments made in Nigerian naira. Paystack collects payment, device, transaction, and fraud-prevention information directly from the purchaser on our behalf, and processes it to take the payment, settle it to us, handle a refund or a dispute, and meet its own legal obligations, under its own privacy terms. For naira purchases ReelUse is the seller and merchant of record, so a refund, a chargeback or a tax question is answered by us and not by Paystack.

ReelUse may change or add payment providers as the Service evolves. Material privacy consequences of such changes will be reflected in applicable notices where required.

END OF PRIVACY POLICY