Summary — the short version
We collect the minimum we need to run the Service. We do not sell your data. We do not train our models on your renders or uploads unless you explicitly opt in. You can export or delete your data at any time.
This document explains the details. If anything's unclear, email us — we'll rewrite the section.
1. What we collect
Account data
Name, email, hashed password (or Google OAuth token). Used to identify you, send transactional emails, and prevent fraud.
Billing data
Payments are processed by Polar Software Inc. (“Polar”), who acts as the Merchant of Record for all transactions. We store: order amounts, pack IDs, and your country (for VAT). Card numbers never touch our servers. By completing a purchase you also agree to Polar's Privacy Policy.
Usage data
Tool used, render count, credit balance, IP-derived country, browser type, and timestamps. Used to monitor performance, prevent abuse, and improve features. Retained for 24 months, then aggregated.
Content data
Photos, YouTube URLs, and hook text you submit to the Service. Stored encrypted at rest. Auto-deleted 30 days after your last activity unless you've saved them to a project.
2. How we use your data
- To provide the Service. Authenticate you, run renders, store outputs.
- To bill you. Charge for credit packs, issue receipts, prevent fraud.
- To communicate. Account notifications, security alerts, occasional product emails (with one-click unsubscribe).
- To improve the product. Aggregate analytics on which tools are used, where errors happen, what features creators want.
- To enforce these terms. Investigate suspected abuse, account sharing, or violations of our acceptable use policy.
3. AI model training
We do not train AI models. CTRpilot builds a prompt from what you submit and sends it to fal.ai, which runs the hosted image model that produces your thumbnails. Hook text, uploaded photos, and reference images are transmitted to fal.ai for this purpose and are subject to fal.ai's privacy policy. Hook-title suggestions are generated the same way via OpenAI.
We do not use your renders or uploads to train any model of our own, because we have none.
6. Your rights
Regardless of where you live, you can:
- Access your data — download a full export from Settings → Data
- Correct any inaccurate info — edit directly in Settings
- Delete your account and all associated data — irreversible, takes effect within 7 days
- Object to processing for marketing — unsubscribe link in every email
EU residents have additional rights under GDPR; California residents under CCPA. Contact us to exercise any of them.
7. Data retention
Account data: kept while your account is active, then 90 days after closure for billing reconciliation.
Uploaded content: 30 days after last activity (or until you delete it).
Renders: indefinite, unless you delete them.
Billing records: 7 years (legal requirement).
Backups: rotated every 30 days.
8. Security
Data in transit is encrypted with TLS 1.3. Data at rest is encrypted with AES-256. Passwords are hashed with bcrypt. We do quarterly penetration tests with an external firm and run a public bug bounty.
If a breach occurs, we'll notify affected users within 72 hours per GDPR.
9. International transfers
Our servers are in Frankfurt, Germany. If you're outside the EU, your data is processed in the EU under Standard Contractual Clauses.
10. Children
The Service is not directed to children under 16. We don't knowingly collect data from anyone under 16. If you believe we have, email us and we'll delete it.
11. Changes to this policy
We'll email all account holders 14 days before any material change takes effect.