RealVideoCreator Global Privacy Policy

Effective Date: August 14, 2026 Version: 2.1

This Privacy Policy explains how Real Labs Development ("Real Labs," "RealLabs," "we," "us," or "our") collects, uses, stores, shares, transfers, protects, and otherwise processes personal information in connection with RealVideoCreator, VoiceLab, related websites, accounts, subscriptions, billing, support, AI-generation services, project tools, protected downloads, and related services.

Real Labs Development is based in the United States.

RealVideoCreator is not a local-only service. Account records, project information, uploaded media, generated output, billing records, and VoiceLab information may be stored or processed on Real Labs systems or by authorized service providers so that authenticated workspaces, generation systems, processing workers, billing systems, security systems, and support services can operate.

This Privacy Policy should be read together with the RealVideoCreator Terms of Service.

VoiceLab is additionally governed by the VoiceLab 18+ Consent, Biometric & Voice Data Notice, and Permitted Use.

If applicable privacy law provides you with rights or protections that cannot lawfully be limited by this Privacy Policy, those rights and protections continue to apply.

1. Controller and Business Information

For purposes of applicable privacy and data-protection laws, the controller, business, or equivalent organization responsible for the personal information described in this Privacy Policy is:

Real Labs Development 1043 Pinegrove Dr Holland, MI 49423 United States

Privacy and Data Protection Contact: legal@realvideocreator.com

Where Real Labs processes information solely on behalf of another organization under a separate agreement, Real Labs may act as a processor or service provider rather than a controller for that specific processing.

2. Scope

This Privacy Policy applies to personal information processed through:

• RealVideoCreator websites;
• RealVideoCreator user accounts;
• Browser-based project tools;
• AI-assisted video generation;
• AI-assisted image generation;
• AI-assisted audio and narration generation;
• VoiceLab;
• Media uploads;
• Generated media and exports;
• Protected downloads;
• Subscription and billing systems;
• Paid-generation billing and entitlement systems;
• Personal API-key integrations;
• Authentication systems;
• Customer support;
• Contact and custom-service forms;
• Security, fraud-prevention, and audit systems; and
• Related RealVideoCreator services.

This Privacy Policy does not control the independent privacy practices of third-party services that you choose to use or connect to RealVideoCreator.

3. Personal Information We Collect

The personal information we process depends on the features you use.

3.1 Account and Identity Information

We may process:

• Username;
• Email address;
• Profile information;
• Account identifier;
• Authentication information;
• Account status;
• Security settings;
• Login records;
• Consent records;
• Terms-acceptance records; and
• Information used to recover or secure an account.

3.2 Billing and Transaction Information

We may receive and store:

• Transaction identifiers;
• Subscription identifiers;
• PayPal payer references;
• Plan information;
• Paid-generation purchase and transaction information;
• Transaction amounts;
• Currency;
• Payment status;
• Subscription activation dates;
• Renewal dates;
• Cancellation status;
• Refund information;
• Reversal information;
• Chargeback or dispute information; and
• Transaction timestamps.

Payment credentials are processed by the applicable payment provider.

Real Labs does not store full payment-card numbers or card security codes when payment credentials are processed directly by PayPal or another payment provider.

3.3 Project and Creator Content

We may process information you submit or create through RealVideoCreator, including:

• Projects;
• Project state;
• Prompts;
• Scripts;
• Uploaded images;
• Uploaded video;
• Uploaded audio;
• Logos;
• Media files;
• Reference material;
• Generation parameters;
• Editing information;
• Generated images;
• Generated video;
• Generated audio;
• Generated narration;
• Exports; and
• Technical metadata associated with project files.

Content may contain personal information if you include personal information in your prompts, scripts, media, or other materials.

You are responsible for complying with applicable law when submitting personal information concerning another person.

VoiceLab does not permit third-party voice enrollment regardless of permission.

3.4 VoiceLab Information

VoiceLab may process information including:

• Your voice recordings;
• Enrollment recordings;
• Audio samples;
• Technical characteristics of your voice;
• Acoustic characteristics;
• Embeddings;
• Feature vectors;
• Templates;
• Voice profiles;
• Voice-model information;
• Generated narration;
• Voice-generation settings;
• Enrollment information;
• VoiceLab consent records;
• Consent-version records;
• Withdrawal records;
• Deletion records;
• Device and security information;
• Processing records; and
• Audit information.

Depending on the technical characteristics, purpose, use, and applicable law, some VoiceLab information may constitute personal information, biometric information, a biometric identifier, biometric data, sensitive personal information, special-category data, or another protected category of information.

Real Labs does not design or use VoiceLab for biometric identification, identity authentication, access control, or determining whether an unknown voice belongs to a particular person.

Real Labs does not represent that every technical voice representation is incapable of contributing to identification.

VoiceLab is strictly 18+ and self-voice only.

3.5 Connected Services and Personal API Keys

If you connect a supported personal API key or other third-party service, we may process:

• Provider identity;
• API-key configuration;
• Encrypted API credentials;
• Connection status;
• Requested model or provider;
• Prompts;
• Scripts;
• Media;
• Generation settings; and
• Technical request and response information.

Personal API credentials are stored in encrypted form where supported by the service architecture.

When you initiate a request using a third-party provider, information necessary to fulfill the request may be transmitted to that provider.

The provider's independent terms and privacy practices may also apply.

3.6 Device, Usage, Security, and Technical Information

We may automatically process information including:

• IP address;
• Browser type;
• Device type;
• Operating system;
• User agent;
• Session information;
• Login events;
• CSRF/security information;
• Request records;
• Pages or features used;
• Download activity;
• Generation requests;
• Worker activity;
• Error logs;
• Security events;
• Abuse-prevention information;
• Audit logs;
• Approximate location derived from IP address where necessary; and
• Other technical information reasonably necessary to operate and secure the service.

We do not intentionally collect precise geolocation unless a specific feature requires it and appropriate notice is provided.

3.7 Support and Communications

When you contact us, we may process:

• Name;
• Email address;
• Account information;
• Support messages;
• Attachments;
• Technical details;
• Transaction information;
• Complaint information; and
• Other information you choose to provide.

3.8 Information Received From Other Sources

We may receive personal information from:

• PayPal or another payment provider;
• Authentication providers such as Google;
• Security or infrastructure providers;
• Connected AI providers;
• Service providers;
• Fraud-prevention systems;
• Support providers;
• Government authorities where legally permitted; or
• Other sources where collection is authorized by applicable law.

Where applicable law requires notice concerning indirectly obtained personal information, we will provide that notice within the legally required period unless an exception applies.

4. Sources of Personal Information

We generally obtain personal information:

1. Directly from you;
2. Automatically through your interaction with RealVideoCreator;
3. From payment, authentication, infrastructure, security, and connected-service providers;
4. From information generated while providing the service; and
5. From authorized third parties or public authorities where permitted by applicable law.

Real Labs does not obtain third-party voices for VoiceLab enrollment.

5. Why We Process Personal Information

We process personal information for the following purposes.

Providing RealVideoCreator

We use information to:

• Create and administer accounts;
• Authenticate users;
• Maintain projects;
• Process uploads;
• Run AI-generation jobs;
• Generate media;
• Deliver exports;
• Provide protected downloads;
• Maintain VoiceLab profiles;
• Generate VoiceLab narration;
• Maintain billing, transaction, and entitlement records; and
• Provide requested functionality.

Billing and Subscription Administration

We use information to:

• Process subscriptions;
• Verify transactions;
• Apply purchases;
• Process paid-generation billing and usage records;
• Process renewals;
• Manage cancellations;
• Process refunds;
• Handle reversals;
• Investigate chargebacks; and
• Maintain accounting records.

Security, Fraud Prevention, and Abuse Prevention

We use information to:

• Authenticate users;
• Protect accounts;
• Detect suspicious activity;
• Prevent fraud;
• Enforce VoiceLab restrictions;
• Detect unauthorized third-party voice use;
• Prevent security attacks;
• Investigate incidents;
• Enforce service limits;
• Protect infrastructure; and
• Protect users and third parties.

Customer Support

We use information to:

• Respond to support inquiries;
• Troubleshoot problems;
• Verify transactions;
• Resolve account issues;
• Process privacy requests;
• Process VoiceLab deletion and withdrawal requests; and
• Investigate reported misuse.

Legal and Compliance Purposes

We may process information to:

• Maintain evidence of consent;
• Maintain contract-acceptance records;
• Meet tax and accounting requirements;
• Respond to valid legal process;
• Establish, exercise, or defend legal claims;
• Enforce agreements;
• Meet privacy and data-protection obligations;
• Comply with sanctions and trade laws; and
• Comply with other applicable law.

Service Improvement

We may use appropriate technical, usage, reliability, and error information to:

• Diagnose failures;
• Improve performance;
• Improve security;
• Improve user interfaces;
• Improve reliability; and
• Develop or improve RealVideoCreator functionality.

We do not intentionally use VoiceLab information to infer unrelated sensitive characteristics about users.

Any materially different use of VoiceLab biometric or sensitive information will be subject to additional notice and consent where required by applicable law.

6. Legal Bases for Processing in the EEA and UK

Where the EU GDPR, UK GDPR, or another law requiring a legal basis applies, Real Labs relies on one or more of the following bases.

Performance of a Contract

We process information where reasonably necessary to:

• Create and maintain your account;
• Provide RealVideoCreator;
• Maintain projects;
• Process generation requests;
• Provide subscriptions or purchases;
• Deliver output;
• Process billing;
• Provide support connected to the service; and
• Fulfill other contractual obligations.

Consent

We rely on consent where required or appropriate, including for:

• VoiceLab enrollment and covered voice processing;
• Biometric or sensitive processing where applicable law requires consent;
• Optional processing that legally requires consent; and
• Other circumstances where we specifically ask for your consent.

Where processing is based on consent, you may withdraw consent at any time, subject to applicable law.

Withdrawal does not affect the lawfulness of processing performed before withdrawal.

VoiceLab may cease functioning if consent necessary for VoiceLab processing is withdrawn.

Legitimate Interests

Where permitted, Real Labs may rely on legitimate interests including:

• Protecting accounts;
• Preventing fraud;
• Maintaining network and service security;
• Preventing abuse;
• Protecting Real Labs and other users;
• Diagnosing technical errors;
• Maintaining appropriate business records;
• Establishing or defending legal claims; and
• Improving service reliability.

Where required, we balance these interests against the rights and interests of affected individuals.

Legal Obligations

We process personal information where necessary to comply with applicable:

• Tax requirements;
• Accounting requirements;
• Court orders;
• Regulatory obligations;
• Privacy and data-protection requirements;
• Consumer-protection obligations;
• Sanctions or trade requirements; and
• Other legal duties.

Establishing, Exercising, or Defending Legal Claims

Where applicable law recognizes this basis, certain information may be retained or processed when necessary to establish, exercise, or defend legal rights.

7. Information You Are Required or Not Required to Provide

Some information is necessary to provide requested services.

For example:

• Account credentials are necessary to maintain an authenticated account;
• Payment information is necessary to purchase paid services;
• Project information is necessary to perform generation requests;
• Voice recordings and derived voice information are necessary to provide VoiceLab;
• VoiceLab consent is necessary to activate VoiceLab; and
• A personal API key is necessary only if you choose to use a feature requiring your own API credentials.

VoiceLab is optional.

You are not required to provide VoiceLab information to use unrelated RealVideoCreator functionality.

If you do not provide information required for a particular feature or transaction, we may be unable to provide that feature or complete that transaction.

8. VoiceLab, Voice Data, and Biometric Information

VoiceLab is subject to additional protections because voice recordings and derived technical information may receive heightened legal protection.

Self-Voice Only

VoiceLab may be used only with your own voice.

You may never submit, record, upload, enroll, clone, synthesize, process, or generate another person's voice through VoiceLab.

Another person's consent does not create an exception.

Age

VoiceLab is strictly limited to users who are at least eighteen (18) years old.

Consent

Before VoiceLab enrollment begins, Real Labs requires affirmative VoiceLab consent and acknowledgements.

The consent process may record:

• Account identity;
• Consent version;
• Date and time;
• Required acknowledgements;
• Relevant security information; and
• Electronic acceptance.

Purpose Limitation

Real Labs processes VoiceLab information for purposes including:

• Creating your private voice profile;
• Generating narration requested by you;
• Maintaining VoiceLab;
• Troubleshooting;
• Security;
• Abuse prevention;
• Enforcing self-voice restrictions;
• Maintaining consent records;
• Providing support; and
• Meeting applicable legal obligations.

No Unrelated Sensitive Profiling

Real Labs does not intentionally use VoiceLab information to infer unrelated characteristics such as:

• Race or ethnicity;
• Health conditions;
• Religious beliefs;
• Political beliefs;
• Sexual orientation;
• Genetic characteristics; or
• Other unrelated sensitive characteristics.

No Public Voice Marketplace

Real Labs does not operate a public VoiceLab voice marketplace.

VoiceLab profiles are intended to remain private to the authenticated user's account.

Generalized Model Training

Real Labs will not use private VoiceLab recordings, VoiceLab templates, embeddings, or private VoiceLab profiles to train a generalized voice model for unrelated users unless Real Labs first provides any additional disclosure and obtains any consent required by applicable law.

9. Cookies and Similar Technology

RealVideoCreator uses essential cookies and similar technologies where necessary for:

• Login sessions;
• Account authentication;
• Security;
• CSRF protection;
• Service preferences;
• Session continuity; and
• Other functionality necessary to operate the service.

As of the effective date of this Privacy Policy, RealVideoCreator does not operate advertising cookies for cross-context behavioral advertising.

If we introduce non-essential cookies or similar technologies that require consent under applicable law, we will provide the required notice and consent controls before using them.

Browser or device storage may also be used for necessary settings and service functionality.

10. Sale, Sharing, and Targeted Advertising

As of the effective date of this Privacy Policy:

Real Labs does not sell personal information.

Real Labs does not share personal information for cross-context behavioral advertising as that term is used by California privacy law.

Real Labs does not process personal information for targeted advertising across unrelated websites or services.

We do not sell or rent VoiceLab profiles or biometric information.

If these practices materially change, we will update this Privacy Policy and provide any opt-out mechanism, consent mechanism, or other notice required by applicable law before engaging in the changed processing.

Where applicable law requires recognition of a universal opt-out mechanism such as Global Privacy Control for covered sale, sharing, or targeted-advertising processing, Real Labs will honor legally applicable signals.

11. When We Disclose Personal Information

We may disclose personal information to the following categories of recipients only as reasonably necessary for their functions.

Payment Providers

Payment and subscription information may be disclosed to or received from payment providers such as PayPal.

Hosting, Database, and Storage Providers

Information may be processed by providers that host applications, databases, media, backups, or related infrastructure.

AI Providers

Prompts, scripts, media, parameters, or other information necessary to perform a generation request may be transmitted to the AI provider selected for the request.

When you use personal API credentials, the selected third-party provider may independently process information under its own terms and privacy practices.

Authentication Providers

Information may be processed by authentication providers such as Google when you choose to use the applicable authentication feature.

Security and Network Providers

Providers such as Cloudflare may process network, IP, device, security, and request information to provide security, availability, or infrastructure services.

Email and Communications Providers

Contact information may be processed to deliver transactional messages, security notices, support communications, or required legal notices.

Professional Advisers

Information may be disclosed where reasonably necessary to:

• Attorneys;
• Accountants;
• Auditors;
• Insurers;
• Security consultants; or
• Other professional advisers.

Government Authorities and Legal Process

We may disclose information when we reasonably believe disclosure is:

• Required by law;
• Required by valid legal process;
• Necessary to protect legal rights;
• Necessary to address fraud or security threats; or
• Otherwise legally permitted.

We may challenge or narrow requests where legally appropriate.

Business Transactions

Information may be disclosed in connection with a proposed or completed:

• Merger;
• Acquisition;
• Financing;
• Reorganization;
• Asset sale;
• Bankruptcy; or
• Similar business transaction,

subject to applicable privacy law.

12. Service Providers, Processors, and Subprocessors

Real Labs uses third-party providers to perform specific services.

Where a provider processes personal information on behalf of Real Labs, we use contractual and organizational measures appropriate to the nature of the processing and as required by applicable law.

Providers are expected to process information only for authorized purposes and to apply appropriate security measures.

Where required, Real Labs enters into:

• Data-processing agreements;
• Confidentiality obligations;
• International-transfer agreements;
• Security requirements; and
• Other legally required contractual protections.

Real Labs will maintain information regarding material service providers and international processing locations as required by applicable law.

13. International Processing and Data Transfers

Real Labs Development is based in the United States.

Personal information may therefore be transferred to, accessed from, stored in, or processed in the United States.

Information may also be processed in other countries where authorized providers operate.

The privacy and data-protection laws of another country may differ from those in your jurisdiction.

Real Labs uses legally recognized safeguards for restricted international transfers where required.

European Economic Area

Where the EU GDPR applies to a restricted transfer, Real Labs may rely on:

• A European Commission adequacy decision;
• European Commission Standard Contractual Clauses;
• Another safeguard permitted under Articles 46 or 47 GDPR; or
• An applicable derogation under Article 49 where legally available.

Where required, Real Labs will assess transfer risks and implement supplementary technical, contractual, or organizational measures.

United Kingdom

Where UK data-protection law applies to a restricted transfer, Real Labs may rely on:

• UK adequacy regulations;
• The UK International Data Transfer Agreement;
• The UK International Data Transfer Addendum to the EU Standard Contractual Clauses;
• Another approved safeguard; or
• A legally available exception.

Where required, Real Labs will perform the applicable transfer-risk assessment or data-protection test.

Brazil

Where Brazil's LGPD international-transfer rules apply, Real Labs will use a transfer mechanism permitted by the LGPD and applicable ANPD regulations, including recognized contractual or adequacy-based mechanisms where appropriate.

Australia

Where Australian Privacy Principle 8 applies, Real Labs will take the steps required by applicable Australian law concerning disclosures to overseas recipients.

New Zealand

Where New Zealand Privacy Act Principle 12 applies, Real Labs will use the required comparable safeguards, authorization, contractual protections, or other lawful mechanism for an overseas disclosure.

Canada

Where Canadian privacy law applies, Real Labs remains accountable for personal information transferred to a service provider for processing to the extent required by applicable Canadian law and uses appropriate contractual and security protections.

Transfer Information Requests

You may contact:

legal@realvideocreator.com

to request additional information concerning applicable international-transfer safeguards, including information regarding how to obtain a copy of applicable contractual safeguards, subject to legitimate confidentiality limitations.

Overseas Processing Locations

Real Labs is located in and directly operates from the United States.

Because cloud, AI, payment, authentication, security, and infrastructure providers may operate from multiple countries, Real Labs will maintain an up-to-date list of material overseas processing locations where required and practicable.

Before international launch, Real Labs should publish the current provider/country list through its legal pages or a Subprocessor & Transfer Locations page.

14. Retention

Real Labs does not intend to keep personal information indefinitely merely because storage is technically possible.

Retention depends on:

• The type of information;
• Why it was collected;
• Whether the account remains active;
• Whether the information remains necessary to provide a requested service;
• Security requirements;
• Fraud-prevention needs;
• Consent status;
• Legal obligations;
• Tax and accounting rules;
• Limitation periods;
• Disputes; and
• Applicable privacy law.

Account Information

Account information may be retained while your account remains active and for a reasonable period afterward where necessary for security, fraud prevention, dispute resolution, legal compliance, or account administration.

Project Content

Project files, uploads, generated media, and project state may remain until:

• You delete them using an available product control;
• Your account is deleted;
• A verified deletion request is completed; or
• Retention is no longer reasonably necessary,

subject to applicable legal exceptions and backup lifecycle requirements.

Payment and Transaction Information

Transaction and subscription records may be retained for periods reasonably required for:

• Accounting;
• Tax;
• Payment disputes;
• Chargebacks;
• Fraud prevention;
• Contract records; and
• Legal compliance.

Support Records

Support communications may be retained for a reasonable period necessary to:

• Resolve the request;
• Maintain service history;
• Improve support;
• Prevent abuse; or
• Establish or defend legal claims.

Security and Audit Logs

Security, request, fraud-prevention, and audit information may be retained for periods reasonably necessary to protect accounts and systems, investigate incidents, enforce agreements, and meet legal requirements.

Personal API Credentials

Stored personal API credentials are retained while the associated connection remains enabled or until they are removed through available account controls, subject to limited backup or security retention.

Consent Records

Terms-acceptance and consent records may be retained for longer than the underlying content where necessary to demonstrate:

• Consent;
• Contract formation;
• Compliance;
• Withdrawal;
• Deletion;
• Legal obligations; or
• Defense of legal claims.

VoiceLab Retention

VoiceLab has a separate retention schedule.

Covered VoiceLab biometric information may remain while:

• Your VoiceLab profile is active;
• Required consent remains valid;
• The information remains necessary to provide VoiceLab; and
• Retention remains permitted by applicable law.

When the VoiceLab processing purpose ends, covered information will be scheduled for destruction.

After a valid deletion request, applicable withdrawal, or another event ending the processing purpose:

• Covered VoiceLab biometric information will ordinarily be scheduled for deletion from active production systems within 30 days; and
• Residual protected backup copies will ordinarily be deleted, overwritten, or rendered permanently inaccessible through the normal backup lifecycle within 90 days,

unless a shorter period is legally required or limited continued retention is legally required or permitted.

For covered biometric information subject to the Illinois Biometric Information Privacy Act, Real Labs' policy is to permanently destroy the information when the initial purpose for collecting or obtaining it has been satisfied or within three (3) years after the individual's last interaction with Real Labs, whichever occurs first, subject to applicable law.

Limited non-biometric consent, security, legal, or compliance records may be retained separately where permitted.

15. Security

Real Labs uses administrative, technical, and organizational measures designed to protect personal information against:

• Unauthorized access;
• Unauthorized acquisition;
• Loss;
• Theft;
• Misuse;
• Unauthorized disclosure;
• Unauthorized alteration; and
• Unauthorized destruction.

Measures may include:

• Authentication controls;
• Access restrictions;
• Encryption where appropriate;
• Encrypted credential storage;
• Private file-delivery controls;
• Network protections;
• Service isolation;
• Security logging;
• Audit records;
• Fraud-prevention mechanisms;
• Backup protections; and
• Restricted administrative access.

Security measures are reviewed in light of the nature and sensitivity of the information and reasonably foreseeable risks.

No Internet-connected service can guarantee absolute security.

If a personal-data breach occurs, Real Labs will investigate and provide notification to affected individuals, regulators, or other parties where required by applicable law.

16. Data Minimization

Real Labs seeks to collect and retain personal information reasonably necessary for the disclosed purposes.

We do not intentionally collect unrelated sensitive information merely because RealVideoCreator's technical systems could process it.

Users should avoid submitting unnecessary sensitive personal information in prompts, project files, scripts, or support requests.

17. Automated Processing and Profiling

RealVideoCreator uses automated systems to:

• Perform AI generation;
• Process media;
• Maintain billing, transaction, and entitlement records;
• Detect security risks;
• Enforce service limits;
• Detect suspected abuse;
• Verify VoiceLab consent state; and
• Perform other technical service functions.

VoiceLab workers may automatically reject requests when required consent is missing, invalid, expired, revoked, or outdated.

Real Labs does not currently use VoiceLab to make decisions concerning:

• Employment;
• Billing entitlement;
• Housing;
• Insurance;
• Education;
• Government benefits; or
• Another person's legal identity.

Where Real Labs engages in solely automated decision-making that produces legal or similarly significant effects and applicable law gives you specific rights concerning that processing, Real Labs will provide required information and any applicable right to human review, explanation, objection, or contest.

18. General Privacy Rights

Depending on where you live and applicable law, you may have rights to:

• Know whether we process your personal information;
• Obtain access;
• Obtain a copy;
• Correct inaccurate information;
• Complete incomplete information;
• Request deletion or erasure;
• Request anonymization;
• Request blocking;
• Restrict processing;
• Object to processing;
• Withdraw consent;
• Request data portability;
• Obtain information concerning recipients;
• Obtain information concerning international transfers;
• Opt out of certain sales, sharing, targeted advertising, or profiling;
• Limit certain sensitive-information processing;
• Appeal certain denied privacy requests;
• Request review of certain automated decisions; and
• Complain to a privacy or data-protection regulator.

Rights vary by jurisdiction and may be subject to legal exceptions.

19. How to Exercise Privacy Rights

Privacy requests may be submitted to:

legal@realvideocreator.com

or through privacy/account controls made available by RealVideoCreator.

Please identify the right you wish to exercise and provide enough information for us to locate the relevant account or records.

We may verify your identity before fulfilling a request, particularly when the request concerns:

• Account access;
• Deletion;
• VoiceLab information;
• Sensitive information;
• Transaction records; or
• Another person's rights.

Verification information will be limited to what is reasonably necessary.

Where legally permitted, an authorized agent may submit a request for you. We may request evidence of the agent's authority and may ask you to verify your identity directly where permitted by law.

We will respond within the time required by applicable law.

We generally do not charge for exercising privacy rights unless applicable law permits a reasonable charge in specific circumstances, such as manifestly unfounded, excessive, or repetitive requests.

If we deny a request, we will provide the reason and information concerning any available appeal or complaint right where required.

20. European Economic Area Privacy Rights

Where the EU GDPR applies, you may have rights including:

• Access;
• Rectification;
• Erasure;
• Restriction;
• Data portability;
• Objection;
• Withdrawal of consent; and
• Rights relating to qualifying automated decision-making.

Where processing is based on legitimate interests, you may object based on circumstances relating to your particular situation, subject to applicable law.

Where processing is based on consent, consent may be withdrawn at any time.

You also have the right to lodge a complaint with the data-protection supervisory authority applicable to you.

You are not required to contact Real Labs before exercising a legal right to contact a supervisory authority.

21. United Kingdom Privacy Rights

Where UK data-protection law applies, you may have rights including:

• To be informed;
• Access;
• Rectification;
• Erasure;
• Restriction;
• Data portability;
• Objection;
• Withdrawal of consent; and
• Rights concerning qualifying automated decisions.

You may also have the right to complain to the United Kingdom Information Commissioner's Office.

Nothing in this Privacy Policy requires you to give up that right.

22. United States State Privacy Rights

Residents of certain U.S. states may have privacy rights under applicable comprehensive state privacy laws.

Depending on the law and whether Real Labs meets the applicable statutory thresholds, rights may include:

• Confirmation of processing;
• Access;
• Correction;
• Deletion;
• Data portability;
• Opt-out of sale;
• Opt-out of targeted advertising;
• Opt-out of certain qualifying profiling;
• Limitation of certain sensitive-information processing;
• Consent rights concerning sensitive data;
• Use of an authorized agent; and
• Appeal of a denied request.

Real Labs will not discriminate against you for exercising a privacy right protected by applicable law.

Where applicable law requires Real Labs to recognize a valid universal opt-out mechanism, we will do so for processing subject to that right.

23. California Privacy Notice

This Section supplements this Privacy Policy for California residents where the California Consumer Privacy Act, as amended ("CCPA"), applies to Real Labs.

Categories Collected

During the preceding twelve months, Real Labs may have collected categories of personal information corresponding to:

Identifiers

Examples include:

• Username;
• Email address;
• Account identifier;
• IP address; and
• Payment-provider identifiers.

Customer and Commercial Information

Examples include:

• Subscription information;
• Purchases;
• Paid-generation transactions;
• Renewal information;
• Refunds; and
• Transaction history.

Internet or Electronic Network Activity

Examples include:

• Login information;
• Browser information;
• Device information;
• Usage events;
• Request logs;
• Security events; and
• Download activity.

Audio, Visual, and Electronic Information

Examples include:

• Uploaded images;
• Uploaded video;
• Uploaded audio;
• VoiceLab recordings;
• Generated media; and
• Related project information.

Sensitive or Biometric Information Where Legally Classified as Such

Certain account-security information or VoiceLab technical information may be treated as sensitive personal information or biometric information depending on how applicable law classifies the information and its use.

Professional or Other Information Voluntarily Submitted

Information may be contained in support inquiries, project materials, or custom-service requests if you choose to provide it.

Inferences and Technical Representations

Certain technical systems may generate information necessary to provide service functionality.

Real Labs does not intentionally use VoiceLab to create unrelated sensitive inferences about users.

Sources

These categories may be obtained:

• Directly from you;
• Automatically through service use;
• From payment providers;
• From authentication providers;
• From connected providers; and
• From information generated while providing RealVideoCreator.

Business or Commercial Purposes

We use the categories above for the purposes described in Sections 5 and 8 of this Privacy Policy.

Sale and Sharing

During the period covered by this Privacy Policy, Real Labs does not sell personal information and does not share personal information for cross-context behavioral advertising.

Disclosure for Business Purposes

Personal information may be disclosed to service providers, contractors, and other categories described in Section 11 where necessary for legitimate service functions.

Retention

Retention criteria are described in Section 14.

California Rights

Where the CCPA applies, California residents may have rights to:

• Know;
• Access;
• Delete;
• Correct;
• Opt out of sale or sharing;
• Limit certain uses or disclosures of sensitive personal information;
• Use an authorized agent; and
• Receive equal service and pricing without unlawful discrimination for exercising CCPA rights.

Because Real Labs currently does not sell or share personal information for cross-context behavioral advertising, there is currently no covered sale or sharing from which a user needs to opt out.

If that changes, Real Labs will provide legally required controls.

24. Biometric Privacy Rights in the United States

VoiceLab may be subject to biometric-information laws in certain U.S. jurisdictions.

Where applicable law requires:

• Advance notice;
• Written or electronic consent;
• A written release;
• A publicly available retention policy;
• Specific destruction requirements;
• Restrictions on disclosure;
• Restrictions on sale or profit;
• Security protections; or
• Other biometric safeguards,

Real Labs will apply those requirements to covered VoiceLab processing.

The VoiceLab 18+ Consent, Biometric & Voice Data Notice, and Permitted Use provides additional information and controls.

25. Canada

Where applicable Canadian private-sector privacy law applies, Real Labs will process personal information in accordance with applicable principles concerning:

• Accountability;
• Appropriate purposes;
• Meaningful consent;
• Limiting collection;
• Limiting use and disclosure;
• Retention;
• Accuracy;
• Safeguards;
• Openness; and
• Individual access.

Because VoiceLab may involve sensitive biometric information depending on the processing and applicable law, VoiceLab uses an affirmative consent process separate from the general Privacy Policy.

Real Labs limits VoiceLab information to the disclosed purposes and maintains a distinct VoiceLab retention schedule.

Canadian users may contact the Privacy Contact identified in Section 1 with inquiries or complaints.

Where you are entitled to complain to a federal or provincial privacy authority, nothing in this Privacy Policy limits that right.

26. Brazil — LGPD

Where Brazil's Lei Geral de Proteção de Dados Pessoais ("LGPD") applies, Real Labs acts as the controller where it determines the purposes and essential means of processing.

Depending on the circumstances and applicable law, Brazilian data subjects may have rights concerning:

• Confirmation of processing;
• Access;
• Correction;
• Anonymization;
• Blocking;
• Deletion;
• Portability;
• Information regarding shared use;
• Information regarding the consequences of withholding consent;
• Withdrawal of consent;
• Objection;
• Review of qualifying automated decisions; and
• Requests for information concerning automated-decision criteria where applicable.

Certain VoiceLab information may constitute sensitive personal data under the LGPD where it meets the applicable definition.

Requests may be submitted to:

legal@realvideocreator.com

Where required, this address will serve as a communication channel for Real Labs' applicable Brazilian privacy contact or encarregado.

If applicable law requires Real Labs to formally designate and publicly identify an encarregado, the required information will be published through this Privacy Policy or the RealVideoCreator legal pages.

You may also have rights to petition the Brazilian National Data Protection Authority (ANPD) or an applicable consumer-protection body.

27. Australia

Where the Australian Privacy Act and Australian Privacy Principles apply, this Privacy Policy is intended to describe:

• The kinds of personal information Real Labs collects and holds;
• How information is collected and held;
• The purposes for which information is collected, held, used, and disclosed;
• How to request access or correction;
• How to make a privacy complaint;
• Whether information is likely to be disclosed to overseas recipients; and
• Where practicable, countries in which those recipients are located.

Real Labs is located in the United States, and Australian personal information may be disclosed or made available to recipients located in the United States.

Additional countries used by material providers must be identified through Real Labs' current Subprocessor & Transfer Locations information where practicable.

Australian users may submit an access, correction, or privacy complaint to:

legal@realvideocreator.com

We will investigate privacy complaints and respond within the period required by applicable law.

Where applicable, you may also have the right to complain to the Office of the Australian Information Commissioner.

Nothing in this Privacy Policy excludes rights that cannot legally be excluded under Australian law.

28. New Zealand

Where New Zealand's Privacy Act 2020 applies, Real Labs will process personal information in accordance with applicable information privacy principles.

New Zealand users may have rights including:

• Notice concerning collection;
• Access;
• Correction; and
• Rights relating to appropriate use and disclosure.

Where Real Labs obtains covered personal information indirectly, we will provide the notification required by applicable New Zealand law unless an exception applies.

Where Principle 12 applies to an overseas disclosure, Real Labs will use an applicable lawful mechanism designed to preserve appropriate privacy safeguards.

New Zealand users may submit privacy inquiries or complaints to:

legal@realvideocreator.com

You may also have the right to contact the Office of the Privacy Commissioner of New Zealand.

29. India

Where India's Digital Personal Data Protection Act and implementing rules apply to Real Labs processing, Real Labs will provide the notices, consent mechanisms, rights processes, security measures, grievance channels, and other protections required by the provisions that are legally in force and applicable to the processing.

Where consent is the applicable basis, Real Labs will provide information necessary for specific and informed consent and a mechanism to withdraw consent as required by applicable law.

Indian users may submit privacy requests or grievances through:

legal@realvideocreator.com

VoiceLab remains strictly 18+ regardless of whether another portion of RealVideoCreator may legally be used by a younger person.

30. Children and Younger Users

RealVideoCreator is not directed to children under thirteen (13).

Real Labs does not knowingly permit children under thirteen to create ordinary consumer accounts or knowingly collect their personal information through such accounts without legally sufficient authorization where an applicable law permits and requires it.

Non-VoiceLab eligibility for users above that age but below the age of legal majority depends on applicable law and the RealVideoCreator Terms of Service.

Where applicable law requires parental or guardian consent or another authorization for a younger person's use of a non-VoiceLab service, the required authorization must be obtained.

VoiceLab is different.

VoiceLab is strictly limited to users who are eighteen (18) years old or older.

There is no parent, guardian, employer, or other consent exception permitting a person under eighteen to use VoiceLab.

If you believe a child has provided personal information in violation of applicable law or these requirements, contact:

legal@realvideocreator.com

31. Privacy Complaints

If you believe Real Labs has handled your personal information improperly, you may submit a complaint to:

legal@realvideocreator.com

Please describe:

• The privacy issue;
• The account or transaction involved where applicable; and
• The resolution you are requesting.

We will investigate and respond in accordance with applicable law.

Depending on your jurisdiction, you may also have the right to complain to:

• A data-protection authority;
• Privacy commissioner;
• Attorney general;
• Consumer-protection authority;
• Supervisory authority; or
• Other competent regulator.

You do not waive such rights by contacting Real Labs.

32. No Retaliation or Unlawful Discrimination

Real Labs will not unlawfully discriminate against, retaliate against, or deny legally protected treatment to a person solely because they exercised an applicable privacy right.

Certain functionality may necessarily become unavailable when the information required to provide that functionality is deleted or consent is withdrawn.

For example, VoiceLab cannot continue operating after information necessary to maintain a VoiceLab profile is deleted.

That functional consequence is not intended as retaliation for exercising a privacy right.

33. Changes in Processing Purposes

If Real Labs intends to process personal information for a materially different purpose that is incompatible with the purpose disclosed when the information was collected, we will provide additional notice and obtain consent where required by applicable law before beginning that processing.

Materially expanded VoiceLab biometric or sensitive-data processing will receive additional notice and consent where legally required.

34. Privacy by Design and Assessments

Where appropriate or legally required, Real Labs may conduct privacy, data-protection, security, biometric, or transfer assessments before beginning or materially changing processing that presents elevated risk.

This may include assessments concerning:

• VoiceLab;
• Sensitive information;
• New AI functionality;
• International transfers;
• Security;
• Profiling;
• Children;
• New service providers; or
• Other high-risk processing.

35. Changes to This Privacy Policy

We may update this Privacy Policy prospectively to reflect:

• Changes in RealVideoCreator;
• New functionality;
• Changes in service providers;
• Changes in privacy law;
• Security requirements;
• Regulatory guidance;
• New countries in which services are offered; or
• Changes in our processing practices.

The current Privacy Policy will display an updated effective date and version number.

Where applicable law requires additional notice or consent for a material change, we will provide that notice or obtain that consent before the change applies.

We will not rely solely on a silent policy update where applicable law requires affirmative consent.

36. Translations

Real Labs may provide this Privacy Policy in multiple languages.

We will make reasonable efforts to ensure translations accurately reflect the English version.

Where applicable law requires a local-language privacy notice to control, that version will control to the extent required by law.

Otherwise, the English version will control in the event of a material inconsistency to the extent permitted by applicable law.

37. Contact Information

Controller / Business

Real Labs Development 1043 Pinegrove Dr Holland, MI 49423 United States

Privacy, Data Protection, VoiceLab, and Legal Requests

Email: legal@realvideocreator.com

Data Protection Officer / Privacy Officer

Real Labs' general privacy contact is:

legal@realvideocreator.com

If applicable law requires Real Labs to formally appoint a Data Protection Officer, encarregado, representative, or other designated privacy official, the applicable identity and contact information will be published here or through the RealVideoCreator legal pages.

VoiceLab Privacy Rule

For clarity:

VoiceLab is strictly 18+ and strictly self-voice only.

VoiceLab processes recordings and technical representations of the authenticated user's own voice to provide private synthetic narration functionality.

Another person's voice may never be submitted to VoiceLab.

Another person's permission or consent does not create an exception.

VoiceLab information is subject to the additional consent, biometric-data, security, retention, destruction, and privacy requirements contained in the current:

VoiceLab 18+ Consent, Biometric & Voice Data Notice, and Permitted Use.