GenerateUGC.AI is operated by GenerateUGC.AI, LLC, with its registered address at 7901 4TH ST N, SAINT PETERSBURG, FL 33702 STE 300 ("GenerateUGC.AI", "we", "our", or "us").

Your privacy is very important to us. Accordingly, We have developed this Privacy Policy in order for You to understand how We collect, use, communicate, disclose, and make use of Your Data and Confidential Information. GenerateUGC.AI adheres to the principle of data minimization and collects only the personal data that is necessary to provide, secure, and improve the Services.

Modification of This Privacy Policy
If We make material changes to this Privacy Policy, We will notify You by posting a notice on the Services and/or via email at least thirty (30) days before the changes take effect. For non-material changes, such changes become effective immediately upon posting. Your continued use of the Services after the effective date constitutes acceptance of the updated Privacy Policy. If You do not agree with the modified Privacy Policy, You must stop using the Services before the effective date.

Before or at the time of collecting Your Data, We will identify the purposes for which Your Data is being collected.

We will collect and use Your Data solely with the objective of fulfilling those purposes specified by Us and for other compatible purposes unless We obtain the consent of the individual concerned or as required by law.

We may disclose Your Data to the extent compelled by law to do so, provided We give You prior notice of the compelled disclosure (to the extent legally permitted) and reasonable assistance, at Your cost, if You wish to contest the disclosure. If We are compelled by law to disclose Your Data as part of a civil proceeding to which You are a party, and You do not contest the disclosure, You will reimburse Us for the reasonable cost of compiling and providing secure access to Your Data.

We will only retain Your Data as long as necessary for the fulfillment of those purposes.

We will collect Your Data by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.

Your Data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

We will protect Your Data by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

We will make readily available to You information about Our policies and practices relating to the management of Your Data.

In addition to the data described above, GenerateUGC.AI may collect the following categories of information in connection with Your use of the Services:

• (a) Identifiers. Name, email address, IP address, device identifiers, account username, and similar identifiers.

• (b) Contact Information. Email address, phone number, and mailing address where provided.

• (c) Financial Information. Payment card details, billing address, and transaction history, processed through our third-party payment processors.

• (d) Location Data. General geolocation data derived from Your IP address, and precise location data where You have granted permission through Your device settings.

• (e) User Content. Prompts, inputs, generated outputs, Purchased Materials, and any other content You submit to or create through the Services.

• (f) Search and Browsing History. Searches You perform within the Services, pages You view, features You interact with, and referring URLs.

• (g) Usage Data. Generation frequency, feature usage, session duration, clicks, and other behavioral data collected during Your use of the Services, including data collected by third-party advertising pixels and tracking technologies such as button click interactions, structured data, meta tag content, and website performance signals.

• (h) Diagnostics and Device Data. Device type, operating system, browser type, crash reports, performance logs, and technical diagnostics. Where You access the Services via an Apple device or platform, diagnostic data collection is subject to and limited by applicable Apple platform policies and Your device privacy settings.

• (i) Purchase History. Records of subscriptions purchased, plan changes, and transaction history associated with Your account.

• (j) Generation Request Logs. For each generation request: account identifier, timestamp (UTC), IP address and geolocation, user agent string, generation type, prompt submitted, API quota consumed, and whether any rate limit or threshold was triggered. This data is retained for 12 months, or up to 24 months where required for active security investigations, legal holds, or regulatory compliance, in a separate, access-controlled log database.

• (k) Third-Party AI Provider Data Practices. GenerateUGC.AI's third-party AI service providers may independently access, monitor, and process data submitted through the Services for purposes including service delivery, quality assurance, compliance, and — depending on GenerateUGC.AI's contractual arrangements — product improvement. As of March 27, 2026, GenerateUGC.AI maintains paid commercial agreements with its primary AI service providers, under which user-submitted prompts, inputs, and outputs are not used by those providers for model training or product improvement. If this status changes, GenerateUGC.AI will update this Privacy Policy and notify affected users in accordance with the Modification of This Privacy Policy section above. GenerateUGC.AI does not control the independent data practices of these providers. Details of applicable provider terms and current data usage practices are available upon request at [email protected] or by phone at +1 305-209-9537.

• (l) Biometric Data. When You use the content generation features and upload photographs containing faces or other biometric identifiers, GenerateUGC.AI and its third-party AI service providers may process such biometric data to generate the requested content and for legal compliance, security, abuse prevention, and service optimization purposes. This processing is subject to Your explicit consent provided prior to Your first upload. GenerateUGC.AI retains uploaded images containing biometric data for the duration of Your active account and deletes them within 12 months of account termination, or 3 years from upload, whichever is shorter. GenerateUGC.AI does not build or maintain biometric databases or facial recognition databases from user-submitted images. Biometric data is not used for AI model training. Illinois residents should note that this processing is subject to the Illinois Biometric Information Privacy Act (BIPA). Texas and Washington residents have similar state-level protections that apply to this processing.

We collect this data to provide and improve the Services, prevent abuse, comply with legal obligations, and enhance our AI models as described in the Terms of Service. You may contact us at [email protected] or by phone at +1 305-209-9537 with any questions about our data collection practices.

GenerateUGC.AI may share Your data with the following categories of recipients:

• (a) Third-Party AI Service Providers. As described in section (k) of Categories of Data We Collect, for the purpose of providing the Services.

• (b) Payment Processors. Financial information necessary to process transactions.

• (c) Affiliates. GenerateUGC.AI may share Your data with its Affiliates (as defined in the Terms of Service) for purposes including service delivery, analytics, AI model training and service optimization (subject to Your opt-out rights), and internal business operations. Affiliates receiving Your data are bound by data protection obligations no less protective than those in this Privacy Policy.

• (d) GenerateUGC.AI Affiliate Partners. Limited data — including referral identifiers, transaction confirmations, and commission-relevant purchase data — may be shared with GenerateUGC.AI Affiliate Partners for the purpose of tracking referrals and calculating commissions. Affiliate Partners do not receive Your name, email, payment information, or User Content.

• (e) Law Enforcement and Legal Process. As described in the Data Collection & Use section above.

• (f) Successors in Interest. In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all of GenerateUGC.AI's assets, Your personal data may be transferred to the acquiring entity. We will notify You via email and/or a prominent notice on the Services before Your data becomes subject to a materially different privacy policy. You will have the opportunity to delete Your account and request deletion of Your data before any such transfer takes effect.

• (g) Advertising and Analytics Partners. GenerateUGC.AI shares data with third-party advertising and analytics service providers — including Meta (Facebook Pixel and Meta Conversions API), Google (Google Ads and Google Analytics), and TikTok (TikTok Pixel with first-party cookies and enhanced data postback) — for purposes of advertising measurement, conversion tracking, audience building, and campaign optimization. Data shared with these providers may include cookie identifiers, browsing behavior, button click interactions, meta tag data, structured data, website performance metrics, and device information. This sharing may constitute a "sale" or "sharing" of personal information under the CCPA/CPRA; You may opt out as described in the "Your California Privacy Rights" section below. For EU/EEA/UK users, this sharing is based on Your prior consent obtained through Our Consent Management Platform, in compliance with the ePrivacy Directive and GDPR.

• (h) Promotional Use. GenerateUGC.AI may use Purchased Materials and other content generated through the Services — including AI influencers and AI generated content — in its marketing, advertising, promotional materials, social media accounts, and website for the purpose of promoting the Services, as authorized under the User Content Showcase License in the Terms of Service. You may revoke this authorization at any time by contacting [email protected].

Where the EU General Data Protection Regulation or UK GDPR applies, GenerateUGC.AI processes Your personal data on the following legal bases:

• (a) Contractual Necessity — processing necessary to perform the Services You have requested;

• (b) Legitimate Interest — processing necessary for our legitimate business interests, such as fraud prevention, security, analytics, and service improvement, where those interests are not overridden by Your rights;

• (c) Consent — where You have given explicit consent to specific processing activities, such as receiving marketing communications or opting into optional features;

• (d) Legal Obligation — processing necessary to comply with applicable laws, regulations, or legal process;

• (e) AI Model Training and Service Optimization — GenerateUGC.AI's use of Your data for service optimization and, where applicable, training, developing, and improving its AI models is based on legitimate interest under Article 6(1)(f) of the GDPR. GenerateUGC.AI has conducted a Legitimate Interest Assessment balancing its interest in optimizing and improving its AI models and Services against the rights of data subjects. A copy of GenerateUGC.AI's Legitimate Interest Assessment for AI training and service optimization is available upon request at [email protected]. You may exercise Your right to object to AI training and service optimization use at any time as described in the "AI Training and Service Optimization Opt-Out" section of the Terms of Service. Upon receiving an objection to AI training and service optimization use under Article 21, GenerateUGC.AI will cease such processing unless it demonstrates compelling legitimate grounds in accordance with Article 21(1). If GenerateUGC.AI determines that compelling grounds exist, it will notify You in writing of its reasoning within thirty (30) days, and You may escalate the matter to Your supervisory authority. Where You have opted out or objected, GenerateUGC.AI will cease prospective AI training and service optimization use of Your data and will rely solely on the legal bases in subsections (a) through (d) above for any continued processing.

You may withdraw consent for consent-based processing activities at any time by contacting Us at [email protected] without affecting the lawfulness of processing based on consent before its withdrawal. For AI training and service optimization use specifically, see the opt-out mechanism described in the Terms of Service.

GenerateUGC.AI and its third-party service providers use cookies, web beacons, pixels, and similar tracking technologies to collect information about Your use of the Services. Certain tracking technologies — including TikTok Pixel with enhanced data postback — may collect additional data beyond standard cookies, including information from meta tags, structured data, button click interactions, and website performance metrics. These technologies are used for authentication, analytics, personalization, and advertising purposes. You may manage Your cookie preferences through Your browser settings. For EU/EEA/UK users, non-essential cookies will only be placed with Your prior consent in compliance with the ePrivacy Directive. For California users, information collected through cookies may constitute a "sale" or "sharing" of personal information under the CCPA/CPRA; You may opt out as described below.

GenerateUGC.AI honors Global Privacy Control (GPC) opt-out preference signals. If We detect a GPC signal from Your browser, We will treat it as a valid request to opt out of the sale or sharing of personal information associated with that browser, in compliance with the California Consumer Privacy Act as amended by the CPRA.

If You are a California resident, You have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

• (a) Right to Know — the right to request disclosure of the categories and specific pieces of personal information We have collected, the sources, the business purposes, and the categories of third parties with whom We share it;

• (b) Right to Delete — the right to request deletion of Your personal information, subject to certain exceptions;

• (c) Right to Correct — the right to request correction of inaccurate personal information;

• (d) Right to Opt Out of Sale/Sharing — the right to opt out of the sale or sharing of Your personal information for cross-context behavioral advertising;

• (e) Right to Limit Use of Sensitive Personal Information — the right to limit Our use of sensitive personal information to purposes necessary to perform the Services.

Certain data sharing activities — including the use of cookies and tracking technologies for cross-context behavioral advertising and the transmission of user inputs and content to third-party AI service providers — may constitute a "sale" or "sharing" of personal information under the CCPA/CPRA. You have the right to opt out of such sale or sharing by contacting Us at [email protected], calling +1 305-209-9537, or using the "Do Not Sell or Share My Personal Information" link on Our website. GenerateUGC.AI does not sell personal information in exchange for monetary consideration.

To exercise any of these rights, contact Us at [email protected] or call +1 305-209-9537. We will not discriminate against You for exercising these rights.

GenerateUGC.AI complies with applicable state comprehensive privacy laws, including the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), the Texas Data Privacy and Security Act (TDPSA), and other applicable state privacy statutes. Residents of those states may exercise rights comparable to those described in the California Privacy Rights section — including the right to access, correct, delete, and opt out of targeted advertising and the sale of personal data — by contacting [email protected] or calling +1 305-209-9537.

If You are located in the European Union, European Economic Area, or United Kingdom, You have the following rights in addition to those described elsewhere in this Privacy Policy:

• (a) Right of Access — the right to request confirmation of whether We process Your personal data and to obtain a copy of that data;

• (b) Right to Rectification — the right to request correction of inaccurate or incomplete personal data;

• (c) Right to Erasure — the right to request deletion of Your personal data, subject to the exceptions described in the "Your Right to Request Deletion" section;

• (d) Right to Restriction of Processing — the right to request that We temporarily restrict the processing of Your personal data where You contest its accuracy, where processing is unlawful but You prefer restriction over deletion, where We no longer need the data but You require it for legal claims, or where You have objected to processing pending verification of Our legitimate grounds;

• (e) Right to Object — the right to object to processing of Your personal data based on legitimate interest at any time. Upon receiving an objection, GenerateUGC.AI will cease processing unless We demonstrate compelling legitimate grounds that override Your interests, rights, and freedoms, or where processing is necessary for the establishment, exercise, or defense of legal claims. For objections specific to AI model training and service optimization, see the AI Training and Service Optimization Opt-Out section in the Terms of Service;

• (f) Right to Data Portability — as described in the "Right to Data Portability" section of this Privacy Policy;

• (g) Right to Withdraw Consent — as described in the "Legal Basis for Processing" section of this Privacy Policy;

• (h) Right to Lodge a Complaint — as described in the "Right to Lodge a Complaint with a Supervisory Authority" section of this Privacy Policy;

• (i) Right to Object to Direct Marketing — You have the right to object at any time to processing of Your personal data for direct marketing purposes, including profiling related to direct marketing. Upon receiving such an objection, GenerateUGC.AI will cease processing Your data for direct marketing without exception.

Automated Decision-Making and Profiling. GenerateUGC.AI uses automated systems in the operation of the Services, including for usage monitoring, rate limit enforcement, content filtering, and compliance with third-party provider policies. Certain automated processes may result in actions that affect Your access to the Services, including throttling, queuing, content rejection, or account suspension. These automated decisions are based on technical signals such as generation volume, request frequency, content policy analysis performed by third-party AI models, and compliance flags. For automated decisions made by GenerateUGC.AI's own systems — including throttling, queuing, and account suspension — You may request human review by contacting [email protected]. For automated content filtering or rejection performed by third-party AI models integrated into the Services, GenerateUGC.AI will use commercially reasonable efforts to facilitate review or provide an explanation, though GenerateUGC.AI's ability to override third-party model decisions may be limited by the terms of those providers. If You are unsatisfied with the outcome, You may escalate to Your supervisory authority. We will review such requests and provide a substantive response within thirty (30) days.

To exercise any of these rights, contact Us at [email protected], [email protected], or +1 305-209-9537. We will respond to verified requests within 30 days. If a request is complex or We receive a high volume of requests, We may extend this period by an additional 60 days with notice to You.

GenerateUGC.AI retains each category of data for the following periods, after which the data will be securely deleted or anonymized unless a longer retention period is required by applicable law, legal hold, or active dispute:

• (a) Identifiers and Contact Information — active account duration plus 12 months post-termination;

• (b) Financial Information — 7 years post-transaction for tax/accounting compliance; payment card details retained by third-party processors per PCI-DSS;

• (c) Location Data — general geolocation 12 months, precise location 6 months from collection;

• (d) User Content — active account duration plus 30 days post-termination for data export;

• (e) Search and Browsing History — 12 months;

• (f) Usage Data — 24 months;

• (g) Diagnostics and Device Data — 12 months;

• (h) Purchase History — 7 years post-transaction;

• (i) Generation Request Logs — 12 months, or up to 24 months where required for active security investigations, legal holds, or regulatory compliance;

• (j) Biometric Data — uploaded images containing biometric data are retained for the duration of the active account and deleted within 12 months of account termination, or 3 years from upload, whichever is shorter. Processed biometric scans generated by third-party AI providers during the generation session are not retained by GenerateUGC.AI beyond that session.

Upon expiration of the applicable retention period, GenerateUGC.AI will delete or anonymize the relevant data within 90 days.

You have the right to request deletion of Your personal data at any time, whether Your account is active or inactive. To submit a deletion request, contact us at [email protected] or +1 305-209-9537. Upon receiving a verified request, GenerateUGC.AI will delete or anonymize the requested data within 30 days, subject to exceptions for:

• (a) completing a transaction;

• (b) legal obligations including tax retention;

• (c) security incident investigation;

• (d) exercising or defending legal claims;

• (e) law enforcement requests with valid process; or

• (f) other purposes permitted under CCPA, GDPR, and applicable law.

GenerateUGC.AI will direct third-party providers to delete relevant data as required. Deletion may result in loss of access to certain Services and may be irreversible. Where Your data has been transmitted to third-party AI providers through the Services, GenerateUGC.AI will direct those providers to delete the relevant data in accordance with GenerateUGC.AI's data processing agreements with them. GenerateUGC.AI's ability to confirm third-party deletion is subject to those providers' contractual obligations, technical capabilities, and their own data retention policies.

Data already incorporated into trained AI models — whether GenerateUGC.AI's or a third-party provider's — cannot be individually extracted or deleted from those models. In such cases, GenerateUGC.AI will: (a) suppress Your data from all future training runs; (b) delete all identifiable copies of Your data from training datasets, staging environments, and data pipelines; and (c) confirm the steps taken in writing upon request. Upon a verified deletion request, GenerateUGC.AI will also delete all uploaded images containing biometric data associated with Your account, regardless of the standard retention schedule.

GenerateUGC.AI will provide You with confirmation of the deletion steps taken upon request.

If You are located in the EU, EEA, or the United Kingdom, You have the right to receive Your personal data that You have provided to Us in a structured, commonly used, machine-readable format and to transmit that data to another controller without hindrance. To exercise this right, contact Us at [email protected]. This right applies to data processed on the basis of consent or contractual necessity and exists independently of the 30-day post-termination export window.

If You are located in the EU or EEA, You have the right to lodge a complaint with Your local data protection supervisory authority if You believe GenerateUGC.AI's processing of Your personal data violates the GDPR. A list of authorities is available at https://edpb.europa.eu. If You are in the United Kingdom, You may lodge a complaint with the ICO at https://ico.org.uk. While We encourage You to contact us first at [email protected] or +1 305-209-9537, Your right to lodge a complaint is independent and not conditioned on contacting GenerateUGC.AI first.

GenerateUGC.AI processes and stores data in the United States. For users in the EU, EEA, Switzerland, or the United Kingdom, GenerateUGC.AI relies on the following legal mechanisms for international data transfers:

• (a) the EU-U.S. Data Privacy Framework, the UK Extension, and the Swiss-U.S. Data Privacy Framework, as applicable;

• (b) Standard Contractual Clauses (SCCs) approved by the European Commission; or

• (c) other lawful transfer mechanisms permitted under applicable law.

You may request a copy of the applicable SCCs by contacting [email protected].

In the event of a security breach involving unauthorized access to, acquisition of, or disclosure of Your personal data, GenerateUGC.AI will notify affected individuals and applicable regulatory authorities in accordance with the timelines and procedures required by applicable law, including without limitation the Florida Information Protection Act (Fla. Stat. §501.171), the GDPR (Articles 33 and 34), and all other applicable federal, state, and international breach notification statutes. Notification will include, to the extent known at the time of notification: the nature of the breach, the categories and approximate number of individuals and records affected, the likely consequences, the measures taken or proposed to address the breach, and a contact point for further information. Where a breach involves biometric data, GenerateUGC.AI will disclose this specifically in the notification. GenerateUGC.AI will also direct its third-party service providers to notify GenerateUGC.AI promptly of any breach affecting data processed on GenerateUGC.AI's behalf. Nothing in this section limits any rights or remedies available to You under applicable breach notification law.

Certain Services, including but not limited to features that create AI influencers and AI generated content, may process biometric identifiers such as facial geometry derived from images or video You upload. GenerateUGC.AI processes this biometric data to generate Your requested content and for legal compliance, security, abuse prevention, and service optimization purposes. Uploaded images containing biometric data are retained for the duration of Your active account and deleted within 12 months of account termination, or 3 years from upload, whichever is shorter. Processed biometric scans generated by third-party AI providers during the generation session are not retained by GenerateUGC.AI beyond that session. Biometric data is not used for AI model training.

Before Your first upload of an image containing biometric data, GenerateUGC.AI will present You with a standalone consent disclosure, separate from this Privacy Policy and the Terms of Service, informing You of the specific data being collected, the purpose, the retention period, and the scope of consent. Your affirmative consent via that disclosure is required before processing begins and covers all subsequent uploads of biometric data for the duration of Your account. You may revoke this consent at any time by contacting [email protected], which will disable Your ability to upload images containing biometric data until consent is renewed.

This disclosure and consent process is provided in compliance with the Illinois Biometric Information Privacy Act (BIPA), 740 ILCS 14, the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code § 503.001), the Washington Biometric Identifier statute (RCW 19.375), and all other applicable federal, state, and local laws governing the collection, use, storage, and destruction of biometric data, including but not limited to laws classifying biometric data as sensitive personal information requiring affirmative consent prior to processing.

GenerateUGC.AI will not sell, lease, trade, or otherwise profit from biometric data. If You upload content containing the biometric data of third parties, You represent and warrant that You have obtained each such individual's informed, written consent prior to upload. GenerateUGC.AI is not responsible for obtaining consent from third parties featured in Your content.

This Privacy Policy applies equally to data collected through Beta Services (as defined in the Terms of Service), notwithstanding any distinction between Beta Services and Services in the Terms of Service.

The Services are not directed to individuals under the age of 18, and GenerateUGC.AI does not knowingly collect personal information from anyone under 18. If We become aware that We have collected personal information from an individual under 18, We will promptly delete that individual's account, personal data, User Content, and all associated information without prior notice. If You believe that We have inadvertently collected information from a person under 18, please contact Us immediately at [email protected] or +1 305-209-9537. This policy is maintained in compliance with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506, and applicable state laws governing the collection of data from minors.

GenerateUGC.AI has designated a Data Protection Officer who can be reached at [email protected] or by mail at:
DPO Consulting
50, Avenue des Champs-Elysées
75008 Paris, France

As GenerateUGC.AI is established in the United States and offers Services to individuals in the EU/EEA, GenerateUGC.AI has designated DPO Consulting, located at 50, Avenue des Champs-Elysées, 75008, Paris, France, as its representative in the European Union pursuant to Article 27 of the General Data Protection Regulation. You may contact our EU Representative regarding any matters relating to the processing of your personal data at [email protected] or by mail at the address above.

For questions or concerns about our privacy practices, you may contact us at: [email protected], by phone at +1 305-209-9537, or at our address: 7901 4th St N, STE 300, Saint Petersburg, FL 33702.

For account management, billing, and subscription cancellations: [email protected]. For legal inquiries, privacy requests, data deletion, and third-party provider information: [email protected].

For Data Protection Officer inquiries: [email protected]. For EU Representative inquiries: [email protected]. Or by mail at: DPO Consulting, 50 Avenue des Champs-Elysées, 75008 Paris, France.