Privacy Policy

Last Updated: 20260320

Xleum Software Limited (“Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store, and protect your information when you use the Viveo mobile application and any related services we provide (collectively, the “Service”). It also explains your privacy rights and the choices available to you.

By using the Service, you acknowledge that you have read and understood this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with initial capital letters have meanings defined under the following conditions. These definitions apply whether they appear in singular or plural form.

Definitions

For the purposes of this Privacy Policy:

Application means the Viveo mobile application provided by the Company.

Company means Xleum Software Limited.

Device means any device that can access the Service, including a mobile phone, tablet, or other smart device.

Face Data means information related to a person’s face, including facial images, facial landmarks, face geometry, or other face-related visual data processed by the Service for a requested feature.

Personal Data means any information that identifies you or can reasonably be linked to you.

Service means the Application and related services.

Service Provider means any third party or individual who processes data on our behalf to help us operate, provide, analyze, secure, or improve the Service.

Usage Data means data collected automatically when you use the Service.

User Content means content you provide through the Service, including photos, videos, text prompts, and generated output.

You means the individual using the Service.

Scope of This Privacy Policy

This Privacy Policy applies to information collected through the Service, including when you:

• use the Application,

• contact us for support,

• submit photos, videos, or prompts to generate content,

• interact with features that require camera or photo library access.

This Privacy Policy does not apply to third-party websites, services, or applications that may be linked from or integrated with the Service but are governed by their own privacy policies.

Types of Data We Collect

We collect only the data reasonably necessary to provide and improve the Service.

Personal Data You Provide

Depending on how you use the Service, we may collect:

• your email address when you contact us for support or other inquiries;

• User Content, including:

  • photos,

  • videos,

  • text prompts,

  • generated videos or other output,

  • feedback or communications sent to us.

Face Data

Some features of the Service may require processing information related to your face in order to generate user-requested video content.

This may include:

• facial images contained in uploaded or captured photos or videos,

• facial landmarks,

• face geometry,

• other face-related visual data necessary to create the requested output.

We collect or process Face Data only when you choose to use a feature that requires it.

Camera and Photo Library Data

With your permission, the Application may access your Device’s camera and photo library so that you can:

• capture photos or videos,

• select existing photos or videos,

• submit media for video generation or related requested features.

Such media may contain your face or other visual information necessary to provide the feature you choose to use.

Usage Data

We may automatically collect certain information when you use the Service, such as:

• IP address,

• device model,

• operating system and version,

• application version,

• language and region settings,

• app interactions,

• timestamps,

• crash data,

• diagnostic and performance information,

• network and log data.

How We Use Your Data

We use your information only for legitimate and limited purposes related to the Service.

We may use your data to:

• provide, operate, and maintain the Service,

• process your photos, videos, prompts, and Face Data to generate the content you request,

• deliver generated videos and related outputs,

• respond to support requests and communications,

• monitor performance, debug errors, and improve reliability,

• detect, prevent, and address fraud, abuse, security incidents, or illegal activity,

• comply with legal obligations,

• enforce our terms, policies, and rights.

We do not use Face Data for:

• advertising,

• marketing,

• profiling,

• facial recognition,

• identity verification,

• authentication,

• data brokerage,

• cross-app or cross-website tracking,

• unrelated analytics.

Face Data

Purpose of Face Data Processing

Some features of the Service process Face Data solely to generate video content or related output that you specifically request.

We process Face Data only when necessary to provide the chosen feature, such as when you upload or capture a photo or video for video-generation purposes.

Consent

We will clearly request your permission before accessing your camera or photo library where required by your device or operating system.

Where Face Data is collected or processed, your use of the relevant feature constitutes your direction to process that media for the requested functionality. Where required by law or platform rules, we will obtain explicit consent before collecting or using Face Data.

No Advertising or Profiling Use

We do not use Face Data for advertising, behavioral marketing, profiling, user identification, facial recognition, authentication, or tracking across apps, websites, devices, or services.

Sharing Restrictions

We do not sell, rent, trade, or disclose Face Data to advertising platforms, data brokers, or information resellers.

If Face Data must be processed by a Service Provider to generate the requested output, that provider may process Face Data only:

• on our behalf,

• for the limited purpose of providing the requested feature,

• under contractual obligations requiring privacy and security protections no less protective than those described in this Privacy Policy.

Off-Device Processing

Face Data will not be transferred off your Device unless such transfer is necessary to provide the feature you requested, such as cloud-based video generation or rendering.

Where off-device processing occurs, we take reasonable measures to protect the data in transit and at rest.

Retention of Face Data

We retain Face Data only for as long as reasonably necessary to:

• provide the requested feature,

• deliver the generated output,

• maintain service integrity,

• comply with legal obligations,

• resolve disputes,

• enforce agreements.

After that, Face Data is deleted or irreversibly anonymized, unless longer retention is required by law.

Legal Bases for Processing (GDPR/Similar Laws)

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction that requires a legal basis for processing, we may process your Personal Data on one or more of the following bases:

• consent, where you have given permission;

• performance of a contract, where processing is necessary to provide the Service you requested;

• legitimate interests, such as service security, fraud prevention, analytics, and operational improvement, where those interests are not overridden by your rights;

• legal obligation, where processing is necessary to comply with applicable law;

• protection of vital interests, where necessary in exceptional circumstances.

How We Share Your Data

We may share your information only in the following limited circumstances:

Service Providers

We may share Personal Data with trusted Service Providers that help us operate the Service, such as providers of:

• cloud hosting,

• storage,

• rendering or processing infrastructure,

• analytics,

• crash reporting,

• customer support tools.

These providers may access information only as necessary to perform services for us and are required to protect it appropriately.

Legal Compliance and Protection

We may disclose information if we believe in good faith that disclosure is necessary to:

• comply with legal obligations,

• respond to lawful requests by public authorities,

• protect our rights, property, or safety,

• investigate fraud, abuse, or security issues,

• enforce our legal terms and policies.

Business Transfers

If we are involved in a merger, acquisition, financing, asset sale, or similar transaction, your information may be transferred as part of that transaction, subject to appropriate confidentiality and legal safeguards.

We do not sell your Personal Data in the ordinary commercial sense.

Data Retention

We retain Personal Data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods may vary depending on the type of data:

• User Content and Face Data: retained only for as long as needed to provide the requested features and outputs, unless legal or operational needs require longer retention;

• support communications: retained as needed to respond and maintain support records;

• Usage Data and diagnostics: retained for troubleshooting, analytics, security, and service improvement for a limited period as appropriate;

• transaction-related records: retained as required by financial, tax, accounting, or legal obligations.

When data is no longer needed, we delete it or anonymize it where reasonably practicable.

Data Deletion Requests

Because the Application does not require account registration, there may not be a self-service account deletion function.

If you have submitted Personal Data, User Content, Face Data, or other information to us directly, you may request deletion by contacting us at feedback@xleumsoftware.com.

Generated results and related data may be stored locally on your Device, depending on how you use the Service. Locally stored data can generally be removed by deleting the content from your Device, clearing local app data, or uninstalling the Application, depending on your Device settings.

To process your request, we may ask for information reasonably necessary to verify your request and identify any data we may hold. We may retain limited information where necessary to comply with law, detect or prevent fraud or abuse, protect security and integrity, or enforce legal claims or obligations.

International Data Transfers

Your information may be processed in countries other than the country in which you live. These countries may have data protection laws that differ from those in your jurisdiction.

Where required by applicable law, we take reasonable steps to ensure appropriate safeguards are in place for international transfers of Personal Data.

By using the Service and submitting your information, you understand that your information may be transferred to and processed in other jurisdictions, subject to applicable legal protections.

Data Security

We use commercially reasonable administrative, technical, and organizational measures to protect your Personal Data against unauthorized access, loss, misuse, disclosure, alteration, or destruction.

However, no method of transmission over the internet or electronic storage is completely secure. Therefore, while we strive to protect your information, we cannot guarantee absolute security.

Analytics and Diagnostics

We may use third-party analytics, crash reporting, and diagnostic tools to understand how the Service is used, improve stability, and fix bugs.

These tools may collect information such as:

• device identifiers,

• app usage events,

• performance data,

• crash logs,

• diagnostic information.

We use such tools only to the extent necessary to operate, analyze, and improve the Service.

If you use versions of the Service that include third-party analytics SDKs, those providers may process data according to their own policies and our contractual arrangements with them.

Advertising and Tracking

We do not use Face Data for advertising or tracking purposes.

If the Service uses advertising or analytics technologies that qualify as tracking under applicable platform rules, including Apple’s App Tracking Transparency framework, we will request any required permission before engaging in such tracking.

If you decline permission, we will not use your data for tracking purposes where such permission is required.

You may also be able to manage certain privacy choices through your Device settings.

Children’s Privacy

The Service is not directed to children under the age of 13, or such higher minimum age as required by applicable law in the jurisdiction where the child resides.

We do not knowingly collect Personal Data from children below the applicable minimum age without the legally required consent of a parent or guardian. If you believe that a child has provided us with Personal Data in violation of applicable law, please contact us at feedback@xleumsoftware.com. If we become aware of such collection, we will take reasonable steps to delete the information.

If applicable law requires parental or guardian consent before collection or processing, we may require such consent before providing certain features of the Service.

Your Privacy Rights

Depending on where you live, you may have rights regarding your Personal Data, including the right to:

• request access to your Personal Data,

• request correction of inaccurate information,

• request deletion of your Personal Data,

• object to or restrict certain processing,

• withdraw consent where processing is based on consent,

• request portability of certain data,

• lodge a complaint with a data protection authority where applicable.

To exercise these rights, contact us at feedback@xleumsoftware.com.

We may need to verify your identity or request details reasonably necessary to process your request.

California Privacy Notice

If you are a California resident, you may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, subject to applicable exceptions.

Depending on the circumstances, these rights may include:

• the right to know what personal information we collect, use, disclose, and retain,

• the right to request deletion,

• the right to request correction,

• the right to limit certain uses of sensitive personal information where applicable,

• the right to opt out of certain sharing or sales as defined by California law,

• the right not to be discriminated against for exercising your privacy rights.

We do not use Face Data for advertising, profiling, or cross-context behavioral advertising.

To submit a California privacy request, contact us at feedback@xleumsoftware.com and include “California Privacy Request” in the subject line.

We may need to verify your request before responding.

Third-Party Services

The Service may rely on third-party services or contain links to third-party websites or platforms. Those third parties operate under their own privacy policies and terms.

We encourage you to review the privacy policies of any third-party services you interact with.

We are not responsible for the privacy practices of third parties except as required by applicable law.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Service, technology, legal requirements, or our privacy practices.

When we make changes, we will update the “Last Updated” date at the top of this Privacy Policy. Where required by law, we may also provide additional notice.

Your continued use of the Service after the updated Privacy Policy becomes effective constitutes your acknowledgment of the updated policy.

Contact Us

If you have any questions, requests, or concerns about this Privacy Policy or our privacy practices, you may contact us at:

Email: feedback@xleumsoftware.com

Website: www.xleumsoftware.com