Dualeyo Privacy Policy

Dualeyo is the name of the website at dualeyo.com. The website and associated Service are owned and operated by Dual Element, Co. LLC, a Nevada limited liability company based in Las Vegas, Nevada ("Dual Element," "we," "us," or "our"). References to "Dualeyo" identify the website and its associated Service, not a separate legal entity or an assumed business name. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with dualeyo.com, the Dualeyo application, and related support and communications (the "Service"). It also explains how to exercise privacy rights and report unauthorized use of a voice or likeness.

This policy describes our information practices. Our separate Terms of Service govern use of the Service, subscriptions, content rights, and contractual dispute procedures. This policy does not replace a separate consent or authorization required by law. Merely visiting the Service does not constitute consent to biometric processing or another activity requiring specific consent. Nothing in this policy waives a privacy right or remedy that applicable law makes nonwaivable.

Independent websites, payment pages, and social platforms have their own privacy practices. This policy continues to describe disclosures we make to those companies; their policies govern their independent processing. Where we process information solely on a business customer's documented instructions under a data processing agreement, that agreement governs our processor obligations, subject to applicable law. Individuals may contact us for help identifying the appropriate party to handle a request.

2.1 Account and contact information. We collect information you provide when creating or managing an account or contacting us, including your name, email address, account identifiers, preferences, and authentication information. Our authentication provider manages password credentials. Do not send passwords, full payment card numbers, or platform access credentials through ordinary support messages.

2.2 Content and instructions. We collect topics, prompts, scripts, captions, brand names and settings, pronunciation instructions, schedules, and other information you submit. We also process uploaded photographs, video, music, and audio, and the images, audio, captions, and videos generated for you. Content can contain information about you or other people. Optional voice and face features are subject to Section 5.

2.3 Payment and commercial information. Stripe processes payments. We receive subscription and transaction information needed for billing and account administration, such as plan, payment status, customer and transaction identifiers, purchase history, and billing contact information made available to us. We do not receive your full payment card number through the Service's ordinary Stripe payment flow.

2.4 Connected accounts. When you authorize an integration, we receive information within the permissions you grant, such as account or channel name and ID, authorization tokens, connected account details, publication identifiers, and available engagement statistics. We receive this information from the connected platform. Section 7 explains the integrations.

2.5 Technical and usage information. We and providers supporting the Service process IP addresses, browser and device information, request times, authentication and security events, feature use, generation status, plan usage, and diagnostic records. An IP address may reveal an approximate location. We do not request precise device location, contact lists, or private social-platform messages as part of the features described here.

2.6 Communications and consent records. We process support communications, information submitted with privacy or abuse reports, and records of permissions and consent, including the notice or agreement version, identity or account associated with the record, date, scope, and withdrawal where applicable. Information about a depicted person may come from an authorized uploader or representative rather than directly from that person.

Do not submit sensitive information unrelated to the requested feature, including health records, government identification numbers, financial account credentials, or confidential third-party material. This instruction does not limit our legal duties if such information is received.

We use the information described in Section 2 to provide and administer accounts; authenticate users; process subscriptions; apply plan limits; generate and store requested content; carry out authorized scheduling and publishing; display available performance information; and respond to support requests.

We also use relevant information to troubleshoot and maintain the Service, understand feature use, prevent fraud and abuse, investigate complaints, protect information and accounts, enforce lawful contractual rights, maintain required business records, and comply with applicable legal obligations. We limit information used for these purposes to what is reasonably necessary. Special restrictions for voice and face information appear in Section 5.

We send operational messages concerning accounts, security, billing, and service changes. Where permitted, we also send product news and marketing emails. You may unsubscribe from marketing using the message's unsubscribe option or by contacting us. Unsubscribing does not stop necessary operational messages.

We do not use the Service to make solely automated decisions about individuals that produce legal or similarly significant effects. We do not use personal information for targeted advertising or cross-context behavioral advertising, or sell it for monetary or other valuable consideration as those activities are defined by applicable privacy law.

Generating content requires sending relevant inputs to third-party AI providers. For example, a writing provider receives the prompt and context needed for a script; a voice provider receives the script or authorized audio needed for speech processing; and an image or avatar provider receives the instructions and authorized images needed for that feature. Support messages submitted to an AI support feature are processed by the provider powering that feature.

We do not use customer content to train our own general-purpose AI models. We require providers processing customer content on our behalf to operate under applicable contractual restrictions. We do not authorize them to use customer voice or face inputs or derived biometric data to train general-purpose models or develop unrelated products. Any proposed optional training use of other customer content will require advance disclosure and consent where required. Required biometric consent is separate from any optional model-training consent.

Our providers and the work they perform are:

4.1 Supabase provides database, authentication, and file storage and processes the account information and content needed for those functions.

4.2 Hetzner hosts the application server in Germany and processes application traffic and information needed to operate that server.

4.3 Stripe provides payment processing, subscription administration, and payment-fraud prevention and receives relevant billing and transaction information.

4.4 Anthropic provides AI writing and support responses and processes relevant prompts, scripts, support messages, and images submitted for supported photo-description features.

4.5 ElevenLabs provides speech generation, authorized voice cloning, and transcription and processes relevant scripts, authorized voice samples, and audio.

4.6 HeyGen provides avatar and talking-photo video generation and processes relevant scripts and authorized portraits.

4.7 fal.ai provides image generation and receives relevant scene descriptions. Pexels provides stock-media search and receives relevant search terms.

4.8 Resend delivers email and processes recipient information and message content. ImprovMX forwards email sent to our domain and processes those messages.

4.9 hCaptcha, operated by Intuition Machines, supports bot and abuse prevention and processes relevant device, browser, network, and interaction information.

Providers may use authorized subprocessors subject to applicable agreements and legal restrictions. A provider may independently process certain information, such as its own billing, account, or security records, where legally permitted. That does not authorize independent use of restricted biometric information. Features, providers, and processing may change; we will update required disclosures and obtain additional consent when required before a new use or disclosure begins.

5.1 Optional features and covered information. Voice Clone uses an authorized adult's voice sample to create synthetic speech resembling that voice. Talking Photo uses an authorized portrait to generate an animated depiction. Processing may create or use voice models, voiceprints, facial measurements, templates, embeddings, or other derived information, depending on the feature and provider. Photographs and audio recordings are not automatically biometric identifiers under every law. When information qualifies as biometric identifiers or biometric information under applicable law, we apply that law's requirements. This section is our public biometric retention and destruction policy.

5.2 Advance notice and separate consent. Before collecting or processing a real person's voice or face for these features, we require the applicable feature-specific notice and informed written or electronic authorization from that adult or a legally authorized representative. The notice identifies the information involved, the purpose, relevant recipients, and retention period. Acceptance of general website terms or an uploader's unsupported statement that permission exists does not replace a legally required release from the individual.

If you upload another adult's voice or likeness, you must have all necessary rights and authorizations, including authorization for the proposed scripts, synthetic depiction, and publication. We may require direct confirmation or supporting authorization and may refuse or suspend processing when authorization cannot be established. Uploads of minors' voices or likenesses for these features are prohibited. An entirely fictional image must not misappropriate an identifiable real person's likeness.

5.3 Limited purposes and disclosures. We use this information only to provide the specifically authorized voice, animation, and related processing features. We do not use it for advertising, unrelated identity recognition, or general-purpose AI model training. Authorized processing may involve ElevenLabs for voice functions, HeyGen for animation, and the hosting and infrastructure providers necessary to transmit or process the information, as identified in the feature notice. We do not sell, lease, trade, or otherwise profit from covered biometric identifiers or information.

We disclose covered biometric information only with the authorization required by applicable law or under an applicable statutory exception. The general safety and business-transfer provisions in Section 6 do not independently authorize a biometric disclosure that the law prohibits. A new purpose or recipient requiring additional consent will not be introduced without that consent.

5.4 Voice retention. Original voice samples are transmitted for authorized voice processing. Temporary application working copies are removed when the transfer or processing request finishes. Provider-held source samples and reusable voice models are retained only while necessary for the authorized voice feature, subject to the destruction triggers below. Removing a voice, withdrawing applicable consent, or deleting the account triggers cessation of further voice generation and deletion instructions to relevant providers.

5.5 Portrait retention. Portrait inputs and temporary facial-processing data are retained only as necessary to complete the requested animation. We initiate deletion when processing finishes, and active processing copies are deleted no later than 30 days after upload. This period does not authorize retaining derived biometric templates after the authorized purpose ends. Provider backup copies are subject to Section 5.7 and the applicable destruction deadline.

5.6 Mandatory destruction deadline. We permanently destroy covered biometric identifiers and biometric information when the initial purpose for collecting or obtaining them has been satisfied or within three years of the individual's last interaction with us, whichever occurs first, or sooner when another applicable law requires. Three years is an outside limit, not permission to retain information after its purpose has ended. Retention beyond a mandatory deadline occurs only where controlling law or a valid warrant or subpoena expressly permits or requires it; a general desire to keep business records is not an independent exception.

5.7 Providers and backups. We require providers handling covered biometric information on our behalf to support the applicable destruction schedule, including retained source samples and derived models. Backup handling must not extend a mandatory biometric destruction deadline. We use secure deletion or other permanent destruction methods appropriate to the storage medium. Operational deletion and final backup expiration may occur at different times only where applicable law permits and within the required destruction period.

5.8 Outputs and copies outside our control. Finished videos and audio may themselves contain personal information and, depending on their contents and processing, information subject to special legal protections. Calling an output "customer content" does not exempt it from applicable privacy or destruction requirements. Otherwise, outputs follow Section 9. Deletion from Dualeyo does not automatically remove copies already downloaded or published elsewhere. We will take actions within our control and provide assistance required by law; independent recipients and platforms handle their own copies and lawful removal requests.

5.9 Withdrawal and complaints. You may remove an available voice through account settings or email privacy@dualeyo.com to withdraw consent, request deletion, or report unauthorized use. You do not need a Dualeyo account to report use of your voice or likeness. Include enough information to locate the content without sending additional sensitive material unnecessarily. We may verify identity or authority, restrict further processing while investigating, and request supporting information. Withdrawal does not retroactively make previously lawful processing unlawful, but we will stop future consent-based processing and handle deletion as required.

6.1 Authorized providers and personnel. We disclose information to providers performing the functions described above and personnel who need access for authorized business responsibilities, subject to appropriate confidentiality and access restrictions.

6.2 Selected platforms and audiences. When you direct publication, we transmit the content and related metadata to the selected platform. Public content may be copied, indexed, redistributed, or processed by others. You should review the script, authorized likeness, audience, and publication settings before scheduling or publishing.

6.3 Legal obligations and protection. Subject to special restrictions such as Section 5, we may disclose relevant information where required by law or valid legal process, or where legally permitted and reasonably necessary to investigate fraud or abuse, protect safety and security, or establish, exercise, or defend legal rights. Requests are evaluated for legal authority and appropriate scope.

6.4 Business transactions. Subject to applicable law, confidentiality safeguards, and necessary notices or consent, relevant information may be disclosed in due diligence or transferred in a merger, financing, acquisition, reorganization, or sale of assets. A recipient must remain subject to applicable privacy obligations. This provision does not authorize selling or transferring covered biometric information contrary to Section 5 or applicable law.

6.5 Other authorized disclosures. We may disclose information at your direction or with valid consent for the specified purpose. Deidentified or aggregate information is used and disclosed only where it meets applicable legal requirements; we do not attempt to reidentify information we maintain as deidentified, except as legally permitted to test deidentification safeguards.

7.1 Permissions and purpose. Integrations are optional. We request permissions needed for the features you choose and use connected-platform information only for the disclosed, authorized purposes. We do not use it for targeted advertising or to train general-purpose AI or machine-learning models.

YouTube features upload authorized videos with selected titles, descriptions, tags, and privacy settings; identify the connected channel; and display available engagement information for posts managed through Dualeyo. TikTok features identify the connected account and send selected videos as drafts for completion in TikTok. Instagram features identify an eligible connected business account through authorized Meta account or Page information, publish selected content, and retrieve available performance information. Actual access is limited by the permissions granted and the supported integration.

7.2 Google policies. Dualeyo uses YouTube API Services. Use of those features is subject to the YouTube Terms of Service at https://www.youtube.com/t/terms. Google's privacy practices are described at https://policies.google.com/privacy. Our use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy at https://developers.google.com/terms/api-services-user-data-policy, including its Limited Use requirements. We do not transfer Google user data to AI providers for model training.

7.3 Storage and access. We store necessary authorization tokens, account and channel identifiers, publication identifiers, and supported statistics. Access is limited to authorized operations, necessary infrastructure providers, and other disclosures permitted by the relevant platform rules and applicable law. We refresh, verify authorization for, or delete stored API data as required by the relevant platform, including applicable 30-day YouTube requirements. We do not treat all categories of API data as having identical retention rules.

7.4 Disconnecting and deletion. You may disconnect an account in Settings under Connected Channels. For Google, you may also revoke access at https://security.google.com/settings/security/permissions. Disconnecting within Dualeyo triggers revocation of the affected authorization and removal of stored tokens. We delete associated YouTube API data as soon as possible and within seven calendar days after an in-Service revocation, a deletion request, or deletion of your Dualeyo account. For external revocations, we check authorization validity and delete affected data within the applicable platform deadline. Other platform data is deleted within applicable requirements and the periods described in this policy.

Keeping a different account connected does not authorize retention of data belonging solely to a disconnected account. You may also request deletion at privacy@dualeyo.com. Removing a connection or deleting our stored API data does not automatically delete content or information held by the platform itself; use that platform's controls for those requests.

We use browser storage and similar technologies to maintain sessions and operate the Service. Authentication and security providers may use necessary cookies or similar tools. hCaptcha supports abuse prevention, and Stripe uses technologies for checkout and fraud prevention. These providers may recognize a device or browser across services for their disclosed security functions; we do not represent that every provider is technically incapable of cross-site recognition.

We do not deploy advertising pixels or third-party advertising or audience-analytics trackers such as Google Analytics or Meta Pixel. Internal operational usage records are described in Section 2. If we introduce optional nonessential tracking, we will update the relevant notice and provide consent or opt-out controls where required before activating it.

You can manage browser storage and cookies through your browser, although disabling necessary storage may affect sign-in or functionality. We honor legally recognized opt-out preference signals, including Global Privacy Control, as required. We currently do not sell or share information for cross-context behavioral advertising, so there is no such activity for the signal to stop. We do not change other processing solely in response to the older Do Not Track signal.

We retain personal information only as reasonably necessary for the disclosed purposes, considering the requested feature, account status, legal requirements, security needs, and applicable time limits. More specific requirements in Sections 5 and 7 control over this section.

9.1 Accounts and ordinary content. Account records and ordinary content remain available while the account is open and the content is needed to provide the requested storage or features. A verified deletion request triggers deletion from active systems within 30 days, unless a shorter deadline applies or a lawful, applicable exception requires or permits limited retention. Deactivation alone pauses an account and does not request deletion. You may request deletion by email.

9.2 Support and diagnostics. Support records are kept as needed to resolve the matter and maintain necessary business records. AI support requests also pass through the provider processing the response. We do not maintain a separate application transcript archive for AI support chat. Routine server error logs are retained for 30 days, unless specific records must lawfully be preserved for an identified incident or legal requirement. Provider-held records are subject to the applicable provider arrangement and legal limits.

9.3 Billing and consent evidence. Billing records are retained for applicable tax, accounting, and legal obligations. We retain limited evidence of notices, consent, withdrawals, and request handling for applicable compliance and claims periods. Keeping a consent record does not itself authorize keeping the underlying biometric sample or model.

9.4 Backups. Deleted ordinary information may remain in restricted disaster-recovery backups until their scheduled expiration, for no longer than 30 days. Such copies are not used for routine business operations, and deletion instructions are reapplied if a backup is restored. This paragraph does not extend a biometric, platform, or other mandatory deletion deadline.

9.5 Limited exceptions. Where applicable law permits or requires retention, we keep only information necessary for that reason, restrict its use, and delete or deidentify it when the reason ends. We will explain an applicable exception when legally required. We cannot erase independently retained copies outside our control, but that does not excuse duties the law imposes on us concerning recipients or processors.

Depending on your location and applicable law, you may have rights to confirm processing; know categories, sources, purposes, and recipients; access specific information; correct inaccuracies; obtain a portable copy; request deletion; withdraw consent; restrict or object to processing; limit certain uses of sensitive information; and opt out of sale, targeted advertising, or qualifying profiling. Some laws also provide information about specific third-party recipients. Rights and exceptions vary, and some laws apply only when statutory thresholds or other conditions are met.

Send requests to privacy@dualeyo.com. Account settings also allow available self-service actions, including updating profile information, downloading outputs, removing a voice, disconnecting accounts, and unsubscribing from marketing. If you cannot use an account control or need an accessible format, email us for assistance. Individuals depicted in uploaded content may contact us without an account.

We verify identity and authority using information reasonably related to the request's sensitivity and risk. Email access alone may not be sufficient for disclosure of sensitive data. Authorized agents may submit requests with evidence of authority; we may also verify the individual directly where permitted. We do not require unnecessary sensitive information or impose identity verification on an opt-out request where law prohibits it.

We respond within the period required by applicable law. We generally aim to respond within 30 days; applicable U.S. laws may allow 45 days and a permitted extension with notice. Where European or UK law applies, the ordinary period is one month, subject to lawful extensions. Shorter biometric and connected-platform deadlines remain controlling. Requests are generally free; any lawful refusal or fee for an excessive or unfounded request will be explained as required.

If we decline a request, we will explain the decision unless prohibited by law. Where an appeal is available, reply to our response with "Privacy Appeal" and the reason you disagree. We review and respond within the applicable appeal period and provide any required information about contacting the appropriate regulator. We do not unlawfully discriminate or retaliate against anyone for exercising privacy rights. Deletion or withdrawal may prevent a feature from functioning when the requested processing is necessary to provide it.

We do not sell covered information as defined in NRS Chapter 603A. Nevada residents may submit a verified no-sale request to privacy@dualeyo.com with the subject "Nevada No-Sale Request." We respond within 60 days, with a further period of up to 30 days only when reasonably necessary and with required notice.

The categories collected and their sources appear in Section 2; uses in Sections 3 through 5; recipient categories in Sections 4, 6, and 7; review and correction procedures in Section 10; third-party technologies and cross-site activity in Section 8; and policy changes in Section 15. The effective date appears at the beginning of this policy.

During the preceding 12 months, or since launch if shorter, the categories of personal information processed through the Service are identifiers and contact information; customer account records; commercial and transaction information; internet and electronic activity; approximate location derived from IP addresses; audio, visual, and electronic content; and preferences or inferences reflected in brand settings and generated content. Sensitive personal information may include account login credentials and information qualifying as biometric or other sensitive information under applicable law, depending on the feature and processing. These categories are obtained from the sources in Section 2, used for the purposes in Sections 3 through 5, disclosed to the relevant recipient categories in Sections 4, 6, and 7, and retained using the category-specific periods or criteria in Sections 5, 7, and 9. Not every category is collected from every user.

We have not sold personal information or shared it for cross-context behavioral advertising during that period, and do not knowingly do so for people under 16. We do not use sensitive personal information to infer personal characteristics or for unrelated purposes that require an additional right to limit under applicable law. Where a separate notice or consent is required for a particular collection or sensitive-data use, we provide it before that processing begins.

California residents may have the rights described in Section 10 under the CCPA where it applies. We do not disclose personal information to third parties for their own direct marketing as described in California's Shine the Light law. Residents of other states may exercise applicable rights through the same contact process. A state not being named here does not exclude any legally required right.

We maintain reasonable administrative, technical, and organizational safeguards appropriate to the information and processing risks. These include encrypted network connections, provider-managed password protection, protection of stored integration credentials, access restrictions, and controls intended to separate customer records. Specific controls may change as technology and risks change, without reducing protections required by law.

No system can guarantee complete security. This statement does not waive security duties or excuse a failure to meet applicable law. If an incident triggers a legal notification obligation, we will provide required notices to affected individuals, authorities, or others within the applicable deadlines. Report suspected unauthorized access or disclosure to privacy@dualeyo.com without including passwords or full payment credentials.

14.1 Adults only. The Service is intended for adults age 18 and older and is not directed to children. We do not knowingly permit minors to create accounts, and users must not upload minors' voices or likenesses for cloning or animation. If we learn that personal information has been collected from a child in violation of applicable law, we take required steps to stop the processing and delete the information, subject only to lawful requirements. Report concerns to privacy@dualeyo.com. An age statement does not replace safeguards required by law.

14.2 Processing locations. Dualeyo is operated from the United States and intended primarily for U.S. users. Information is processed in the United States, Germany, and other countries where authorized providers operate. Foreign laws may differ from those where an individual lives. This disclosure does not itself constitute consent to an international transfer or establish a lawful transfer mechanism.

14.3 European and UK rights where applicable. Where the GDPR or UK GDPR applies, Dual Element acts as controller for processing whose purposes and means it determines. Legal bases are performance of a contract for requested services; legitimate interests in necessary security, support, and service maintenance, subject to applicable balancing; compliance with legal obligations; and consent for processing that requires it. If Article 9 applies to particular biometric processing, an appropriate Article 9 condition, including explicit consent where relied upon, is also required. We do not assume that every photograph or voice recording falls within Article 9.

Information necessary to provide a requested feature must be supplied for that feature to operate; optional consent may be withheld or withdrawn. Individuals have applicable access, correction, erasure, portability, restriction, objection, and consent-withdrawal rights and may complain to their competent supervisory authority. Before a restricted international transfer, we establish the legally required safeguard or other permitted basis. To ask about the safeguards that apply to a transfer, email privacy@dualeyo.com.

We post updates with a revised effective date. For material changes, we provide advance notice through email or a prominent in-Service notice when required, explaining the change and its effective date. We obtain fresh consent before a new biometric purpose, disclosure, or other processing for which applicable law requires it. Continued use alone does not supply legally required affirmative consent. Changes will not retroactively authorize a use of previously collected information contrary to applicable law or a binding prior commitment.