Privacy Policy

This policy details our commitment to protecting your personal data and privacy when you use the Ruwaa platform.

Effective Date: August 28, 2025

INTRODUCTION: This Privacy Policy explains how Cibeeo Inc. SRL ("Company," "we," "us," or "our") collects, uses, shares, and protects information in relation to our services, including the Ruwaa AI platform, website, and applications (collectively, the "Service"). We are the "data controller" for the information described in this policy.

1. Definitions

"Personal Data" means any information that relates to an identified or identifiable individual.

"Creator" refers to any individual user of the Service who creates content or participates in campaigns. This includes, but is not limited to, influencers, artists, photographers, videographers, musicians, singers, actors, models, and other creative professionals.

"Brand" refers to any business or organizational user of the Service. This includes, but is not limited to, companies, marketing agencies, talent representatives, production studios, ad-supported platforms, and other commercial entities.

2. Information We Collect

We collect information in the following ways to provide and improve our Service:

2.1. Information You Provide Directly

  • Account Information: When you register, we collect your name, email address, password, and account type (Creator or Brand).
  • Creator Profile Information: If you are a Creator, you may provide additional information such as a profile picture, portfolio links, social media handles, skills, niches (e.g., fashion, beauty), and a personal biography.
  • Brand Profile Information: If you are a Brand, you may provide your company name, website, industry, and contact information for your representatives.
  • Payment & Financial Information: For Creators, we collect bank account or payment service details to process payouts. For Brands, we collect payment card or billing information to process subscription fees and campaign budgets. This is securely handled by our third-party payment processors.
  • Identity Verification Information: In certain jurisdictions or to comply with financial regulations, we may require Creators to provide a government-issued ID for identity and age verification before processing payouts.
  • Campaign & Communication Data: We collect information you provide when creating a campaign brief (for Brands), applying to a campaign (for Creators), and any communications exchanged between users on the platform.

2.2. Information From Your Use of the Service

  • Content and Input Data: We process the text prompts, images, videos, brand assets, and other files you input into our AI generation tools. For Creators adapting brand assets, this may include images or videos of your likeness.
  • Usage Data: We automatically collect information about your interactions with the Service, such as features used, content viewed, credits consumed, and actions taken.
  • Technical Data: We collect technical information from your device, including IP address, browser type and version, operating system, and device identifiers.
3. How and Why We Use Your Information (Legal Basis)

We process your Personal Data based on the following legal grounds, particularly under the GDPR:

To Perform Our Contract With You:

We use your data to create and manage your account, provide the core functionalities of the Service, facilitate campaigns between Brands and Creators, and process all related payments and payouts.

For Our Legitimate Interests:

We use data to monitor and improve the Service, personalize your experience, ensure platform security, prevent fraud, and (where permissible) to inform you about new features or services. You have the right to object to this processing.

To Comply With Legal Obligations:

We process data as required by law, such as for tax purposes, financial reporting, and to respond to lawful requests from authorities.

With Your Consent:

We will ask for your explicit consent to process certain data, such as using your image for our own promotional materials, or for sending non-essential marketing communications. For any content you provide that may be considered "biometric data" (e.g., a video of your face used for AI adaptation), your act of uploading and using this feature constitutes your explicit consent for us to process it for that specific purpose.

4. How We Share Your Information

We do not sell your Personal Data. We may share your information with the following parties for legitimate business purposes:

  • Between Brands and Creators: A Creator's public profile information (name, portfolio, social links) is visible to Brands. When a Creator applies to a campaign, further details may be shared. When a Brand launches a campaign, its profile and campaign details are visible to Creators.
  • Service Providers: We share information with trusted third-party vendors who perform services on our behalf, such as payment processing (e.g., Stripe), cloud hosting (e.g., AWS), and customer support tools. They are contractually obligated to protect your data.
  • Legal and Safety Reasons: We may disclose information if we believe it's necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security, or technical issues; or to protect our rights or property.
  • Business Transfers: In connection with a merger, acquisition, bankruptcy, or sale of assets, your information may be sold or transferred as part of that transaction. We will notify you before your Personal Data is transferred and becomes subject to a different privacy policy.
5. International Data Transfers

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. If you are located in the European Economic Area (EEA), we will ensure that any transfer of your Personal Data to countries outside the EEA is protected by appropriate safeguards, primarily through the use of Standard Contractual Clauses approved by the European Commission.

6. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your Personal Data:

  • The right to access – You have the right to request copies of your personal data.
  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • The right to erasure (or "to be forgotten") – You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

To exercise any of these rights, please contact us at the email provided in Section 9.

7. Data Security and Retention

Security: We implement appropriate technical and organizational security measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

Retention: We retain your Personal Data for as long as your account is active or as needed to provide you with the Service. We may also retain data to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer have a legitimate business need to process your information, we will either delete or anonymize it.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last Updated" date. We encourage you to review this Privacy Policy periodically for any changes.

9. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your Personal Data, please contact our Data Protection Officer at:

Email: privacy@ruwaa.ai

Mailing Address:
Cibeeo Inc. SRL
Attn: Data Protection Officer
Prahova, Romania