Privacy Policy

Fanvibes Media Limited is the controller of personal data processed under this Privacy Policy unless we state otherwise.

Contact: privacy@fanvibes.media / legal@fanvibes.media Address: 101 New Cavendish Street, 1st Floor, London, W1W 6XH

In some cases, where we provide services to a brand, partner or other counterparty under a separate arrangement, we may process certain personal data on that party's behalf. Where that is the case, the relevant arrangement or privacy notice will explain it.

Bites is available on the Apple App Store. If you access the Service through the Apple App Store, Apple may collect certain technical and device data in connection with App Store operations in accordance with Apple's own Privacy Policy. We are not responsible for Apple's data practices.

The Service is strictly intended only for users aged 18 or over. We do not knowingly collect personal data from children under the age of 18. If we become aware that a user under the age of 18 has provided us with personal data or accessed the Service, we will take steps to remove that data and close the relevant account. If you believe a child under 18 has used the Service, please contact us at privacy@fanvibes.media. Users should not upload personal data relating to children or minors unless strictly necessary, lawful and specifically authorised.

We do not intentionally require users to provide special category personal data as part of normal use of the Service.

However, because the Service enables users to upload audio, video, images, free-form text and related materials, uploaded content may incidentally contain sensitive or special category personal data, including information relating to health, biometric characteristics, racial or ethnic origin or other sensitive information.

Users should avoid uploading unnecessary sensitive personal data relating to themselves or others unless strictly necessary, appropriate and authorised.

If we intentionally process special category personal data, we will identify both a lawful basis and an additional condition required by applicable law.

We do not use uploaded content for biometric identification or facial recognition purposes.

Fanvibes collects and receives the following information through the Services and your interactions with the Services:

Account and profile data such as name, email, phone number, username, social handles, profile details, team or agency details and country.

Relationship and participation data such as whether you are a creator, athlete, ambassador, representative, partner, prospect or campaign participant.

Technical and device data such as IP address, device identifiers, browser type, app version, logs and diagnostics.

Service usage data such as interactions with Pocket Studio, prompts, boards, storyboards, uploads, clicks, navigation, support history and use of AI-assisted features.

Content data such as videos, audio, stills, images, captions, transcripts, prompt responses, metadata, edits, versions, comments and related materials created or submitted through the Service.

Workflow and review data such as self-serve edits, iterations, approvals, rejections, optional production support actions, version history and related records.

Persona and context data such as onboarding persona/context inputs, user-supplied descriptive information, style or resource preferences, and related settings used to tailor outputs.

Trend, performance and feedback data such as engagement, reach, response patterns, performance signals and feedback associated with content or workflows.

Communications data such as emails, messages, meetings and support requests.

Commercial and finance data where relevant, such as payment, invoicing and campaign administration information.

Public-source data such as public social content, public post history, public engagement patterns and publicly available profile information.

We collect personal data:

• directly from you;
• from your representatives, managers, agents or other authorised contacts;
• from your use of the website, app and Service;
• from public sources and public social platforms;
• from third-party technology, data, analytics or API providers used in the Service workflow;
• from hosting, communications, editing and infrastructure providers;
• from business partners and distribution partners where relevant; and
• from the Apple App Store, where applicable, including device identifiers and download information provided by Apple.

Personal data will be processed by Fanvibes in accordance with your instructions, and any applicable terms in the Terms of Use, and as required by applicable law. We also process personal data for the following purposes.

A. To provide and operate the Service: This includes creating accounts, authenticating access, managing prompts, storyboards, content capture, self-serve editing flows, optional production support, approvals, publishing support and customer support. Lawful basis: contract, or steps at your request before entering into a contract.

B. To operate, analyse and improve Bites: This includes using usage data, prompts, responses, approvals, edit history, persona/context inputs, metadata, trend signals, workflow patterns and performance data to improve prompts, workflows, safety, ranking, quality and product performance. Lawful basis: legitimate interests and, where the processing is integral to the feature being used, contract.

C. To use AI-assisted systems and agentic workflows: This includes trend analysis, relevance weighting, prompt generation, format selection, content-direction assistance, output evaluation, quality control and related service improvement. Lawful basis: legitimate interests and, where appropriate, contract.

D. To manage content and commercial exploitation: This includes receiving, processing, editing, distributing, publicising, licensing, monetising, sponsoring, branding, promoting and administering content created through the Service, where permitted under the relevant terms, agreement, approval or campaign arrangement. Lawful basis: contract where this forms part of the relevant service arrangement, otherwise legitimate interests.

E. To support creative product functions: This includes enabling users to interact with, react to, compare against, or otherwise use public or shared content in creator-facing features and workflows. Lawful basis: legitimate interests and, where relevant, contract.

F. To communicate with you: This includes service notices, account messages, support communications, operational updates and administrative communications. Lawful basis: contract and legitimate interests.

G. For security, fraud prevention and compliance: This includes monitoring misuse, enforcing terms, investigating incidents, protecting systems and complying with legal or regulatory obligations. Lawful basis: legitimate interests and legal obligation.

H. For business development and relationship management: This includes responding to enquiries, managing relationships with partners and representatives, and sending business communications. Where consent is required by law, we will ask for it. Lawful basis: legitimate interests and, where required, consent.

Where we rely on legitimate interests, those interests generally include:

• operating, improving and scaling the Services;
• improving content direction, prompts, workflows and performance;
• protecting our systems, business, users and rights;
• commercialising content created through the Service where permitted;
• maintaining rights records and audit trails; and
• developing business relationships and opportunities.

We use AI-assisted systems, analytics tools and automated workflows to support content creation, editing, recommendations, trend analysis, workflow assistance and platform improvement.

Where reasonably practicable, we use aggregated or de-identified data for analytics and improvement purposes.

We do not use the Service to make automated decisions producing legal or similarly significant effects about users.

We are not using uploaded content to train a general-purpose foundation model. We use model-assisted and agentic workflows to operate and improve the Service.

The Service may use public social posts, hashtags, conversations, public post history and public engagement patterns to identify trends, understand relevance and support content direction.

Where we process public social data, we do so for the purposes of operating and improving the Service, identifying and matching trends, supporting creator-facing features, and improving recommendations and workflow quality.

Lawful basis: legitimate interests.

User profile and other information that you choose to provide, including your username, contact name, Content you upload, and information about yourself, may be displayed to other users to facilitate user interaction within our Services. This information will be displayed to other users depending on your privacy settings.

Some of your activity on and through our Services is publicly displayed by default. This includes User Content you have posted publicly on Bites or otherwise through our Services.

For registered users, all User Content you post publicly (or privately) will be associated with your account. Unregistered users will not have this association, but personal data concerning their use of the Services (such as what pages they have visited) may be tracked through the use of cookies and stored by us.

Please remember that if you choose to provide personal data using certain public features of our Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in your User account that you create or information that you submit through our Services.

We may share personal data with:

• hosting, cloud storage, infrastructure and security providers;
• third-party social, analytics, data or API providers;
• communications, CRM and support providers;
• optional editing, production, moderation and workflow vendors used for particular users or workflows;
• AI and technology providers acting on our behalf;
• payment, accounting and professional advisers;
• social platforms and distribution partners where content is published, distributed or monetised;
• business partners, brand partners and campaign counterparties where relevant to opportunities, activations or commercial arrangements; and
• regulators, courts, law enforcement, counterparties or others where required by law or reasonably necessary to protect rights or safety.

We may process your information in several countries, including countries within the European Economic Area, the UK, the USA and others. When we transfer your information outside the UK or the EEA, we may transfer it to countries that have been recognised as offering adequate protection by the EEA or the UK. When this adequacy status has not been offered, we will use appropriate safeguards, such as standard contracts that can be used in the EEA or the UK to safeguard your information.

We keep personal data for as long as reasonably necessary for the purposes described in this Policy and as required by applicable law.

As a general guide we retain personal data for the following periods:

• account and relationship data: while the account or relationship remains active and for a reasonable period afterwards;
• workflow, rights and exploitation records: for as long as needed to administer rights, content exploitation, audit trails and dispute resolution;
• technical logs and diagnostics: for a shorter operational period unless needed longer for security or investigations;
• finance and payment data: for as long as required by legal, regulatory, accounting or tax obligations; and
• other data: for as long as reasonably necessary having regard to the purpose, sensitivity, risk and any legal or operational need.

We use appropriate technical and organisational measures to protect personal data. No system can be guaranteed to be completely secure.

We process all personal data in accordance with the principles of GDPR and especially having in mind your data protection rights, in particular your right in certain circumstances to:

• request access to any personal data about you held by Fanvibes and information relating to how and why it’s processed;
• request to have any inaccurate data corrected;
• request to have personal data erased where it is no longer required for the original purpose or where you have withdrawn your consent, and no other lawful processing grounds apply;
• request the restriction of processing of your personal data;
• object to processing of your personal data;
• receive a copy of certain personal data you have provided to us in a structured, commonly used and machine-readable format; and
• withdraw consent where we rely on consent.

These rights are subject to legal limits and exceptions.

If you upload or submit content that includes another person's personal data, you should ensure you have an appropriate legal basis, consent or other lawful justification to do so. You should avoid uploading unnecessary personal data about family members, minors, bystanders or other third parties.

Our website and app may use cookies or similar technologies for essential functionality, analytics and performance. Where required by law, we will ask for consent before using non-essential cookies or similar technologies. A separate Cookie Notice may be provided if required.

If you have concerns about how we handle personal data, please contact us first at privacy@fanvibes.media. You also have the right to complain to the Information Commissioner's Office in the UK.

This Policy should be read alongside the Bites Terms of Use, Community Guidelines and any separate written creator, talent or campaign agreement that applies.

We may update this Privacy Policy from time to time. We will post the updated version on our website or app and, where appropriate, notify you of material changes.