Privacy Policy

This Privacy Policy describes how AvatarReacts collects, uses, and discloses your information when you use our website and AI avatar reaction video service. It also explains your privacy rights and how the law protects you.

Last updated: June 12, 2026.

We use your personal data to provide and improve our AI avatar reaction video service. By using AvatarReacts, you agree to the collection and use of information in accordance with this Privacy Policy and our Terms of Service.

Privacy Policy Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Privacy Policy Definitions

For the purposes of this Privacy Policy:

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Daruma Ventures LLC, the operator of AvatarReacts.
• For the purpose of the GDPR, the Company is the Data Controller.
• Website refers to AvatarReacts, accessible from https://avatarreacts.com.
• Service refers to the Website and the web-based AI avatar reaction video platform provided by AvatarReacts.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Account means a unique account created for You to access our Service or parts of our Service.
• Country refers to: United States
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• For the purpose of the GDPR, Service Providers are considered Data Processors.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Personal Data is any information that relates to an identified or identifiable individual.
• For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
• Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration.

Collecting and Using Your Personal Data

Types of Data Collected:

Personal Data

While using Our Service, We may collect certain personally identifiable information that can be used to contact or identify You. This may include, but is not limited to:

• Email address
• Name (if provided)
• Account information and login credentials (through the sign-in methods we offer)
• User Content, including text prompts you submit and videos or other materials you upload
• Generated Content and related activity within the Service
• Usage Data

Note on Usage Data

Usage Data is collected automatically when using the Service. This may include information such as your IP address, browser type and version, pages visited, time and date of visits, time spent on pages, and other diagnostic and analytics data.

We may also collect information that your browser automatically sends when you visit the Service.

AI Processing and Third-Party AI Services

AvatarReacts uses artificial intelligence and third-party AI service providers to generate avatars from text prompts and to render reaction videos from videos you upload.

• User Inputs and Uploaded Content: Prompts, text inputs, brand information, creative preferences, and any media or materials you upload may be processed by our third-party AI and infrastructure providers for the purpose of generating and delivering the Service.
• Third-Party Processing: To operate the Service, we may send relevant data to third-party providers that support image generation, video generation, hosting, storage, analytics, authentication, communications, and payment processing.
• Data Minimization: We aim to share only the information reasonably necessary to provide the requested feature or output.
• No Provider Training Commitment: We do not intentionally provide your personal data to third-party AI providers for the purpose of training their general models where such provider offers a no-training or limited-training option for API/customer data, but their handling of data remains subject to their own terms and policies.
• AI Output Notice: AI-generated outputs may be inaccurate, incomplete, or similar to content generated for other users. You are responsible for reviewing all outputs before publishing, distributing, or relying on them.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to operate and improve the Service. These technologies are used to maintain sessions, authenticate users (including through the sign-in methods we offer), process payments, analyze usage, and improve performance.

Third-party service providers (such as authentication providers, analytics services, payment processors, and infrastructure providers) may also use cookies or similar technologies as part of their services.

You can control cookie preferences through your browser settings. Disabling cookies may impact authentication and other core functionality of the Service.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email or other electronic communications regarding your account, service updates, security notifications, and relevant product or feature information.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• Or to manage Your requests: To attend and manage Your requests to Us.

User Content and Generated Content

AvatarReacts allows you to submit prompts, text, brand information, and other materials, and to upload or provide content ("User Content") in order to generate AI-powered outputs, including avatars and reaction videos ("Generated Content").

• Your Responsibility: You are responsible for all User Content you submit and for how you use any Generated Content. You agree that you have the necessary rights, permissions, and licenses to submit User Content and to use Generated Content.
• Processing of Content: User Content and Generated Content may be processed by our systems and third-party service providers to provide, maintain, and improve the Service.
• No Guarantee of Uniqueness: Generated Content may not be unique and similar or identical outputs may be generated for other users.
• Review Requirement: You are responsible for reviewing all Generated Content before using it publicly, including for advertising, marketing, or commercial purposes.

Sharing Your Personal Data

We may share your personal information in the following situations:

• With Service Providers: We may share Your personal information and User Content with third-party service providers that help us operate the Service, including providers for hosting, infrastructure, storage, authentication, analytics, communications, payment processing, and AI-powered content generation and processing.
• For Business Transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
• For Legal Compliance and Protection: We may disclose Your information where required to do so by law or where we believe disclosure is necessary to comply with a legal obligation, protect our rights, prevent fraud or abuse, or protect the safety of our users or others.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as necessary to provide the Service, comply with legal obligations, resolve disputes, enforce our agreements, and operate the Service.

User Content and Generated Content, including generated videos and other media, may be retained for a limited period of time. We may delete such content after a period of inactivity or after your subscription ends. You are responsible for downloading or exporting any content you wish to keep before deletion.

We may also retain Usage Data for internal analysis, fraud prevention, security, and service improvement purposes, subject to applicable legal requirements.

Transfer of Your Personal Data

Your information, including Personal Data, may be processed and stored in the United States or in other jurisdictions where our service providers operate. These locations may have data protection laws that differ from those in your jurisdiction.

By using the Service, you consent to the transfer of your information to such jurisdictions.

We take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use privacy-focused third-party analytics providers to monitor and analyze use of our Service. These providers collect aggregated usage information and do not sell personal data. We will identify our current analytics providers in this section.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Stripe - Privacy Policy

When You use Our Service to pay for a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Rights under GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You.
• Request correction of the Personal Data that We hold about You.
• Object to processing of Your Personal Data.
• Request erasure of Your Personal Data.
• Request the transfer of Your Personal Data.
• Withdraw Your consent.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
• We do not sell personal information, but under CCPA, you have the right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by contacting us via the Contact link in the footer.
• The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the Personal Data
  • Categories of third parties with whom We share Personal Data
  • The specific pieces of Personal Data we collected about You
• The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Do Not Sell My Personal Information

We do not sell personal information as defined under the CCPA.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please use the Contact link in the footer or email us at .