Privacy Policy & Data Security
Your data is your business. We process it transparently, securely, and with clear controls.
1. Scope, Roles, and Applicability
This policy explains how Tuba Intelligence Limited processes personal data when you visit, register for, or use Tubagen. Depending on context, we may act as a data controller (for account and billing operations) or a data processor (when handling customer project data on behalf of a workspace owner).
2. Categories of Data We Process
Account and Workspace Data
Name, email, role, workspace membership, authentication records, support history, and account settings.
Social Login Data
If you register or sign in using a supported third-party login method, we may receive profile information needed to authenticate your account, such as name, email address, profile image, account identifier, and verification status.
Content and Project Data
Uploaded media, scripts, briefs, scene and shot structures, workflow nodes, prompts, parameters, generated outputs, saved assets, templates, tags, task records, review comments, and project metadata.
Technical and Usage Data
Device identifiers, browser and OS information, log files, session events, IP address, and basic analytics telemetry.
Commercial Data
Plan, billing events, invoices, payment status, and credits usage (processed via authorized payment processors).
3. Why We Process Data (Legal Bases)
Contract Performance
To provide the service, authenticate users, generate outputs, maintain projects, and enable workspace collaboration.
Legitimate Interests
To secure the platform, prevent abuse, improve performance, and maintain product reliability.
Aggregated and De-identified Data
We may use aggregated, de-identified, or statistical usage data to improve service performance, reliability, analytics, and product planning. We do not treat aggregated data that cannot reasonably identify a person or workspace as personal data.
Consent
Where required, for specific processing activities such as optional marketing communications or model-training opt-ins.
Legal Obligations
To comply with applicable laws, lawful requests, accounting obligations, and dispute handling requirements.
4. AI Processing and Training Policy
AI Processing Infrastructure
When you run workflow nodes such as image generation, video generation, image or video editing, speech, music, sound effects, AI assistant, frame extraction, composition, or related AI tools, relevant data may be processed through approved AI infrastructure as required to deliver requested outputs.
No Training by Default
We do not use your private uploads or customer project data to train our underlying AI models without your explicit opt-in. Your content remains under your control subject to this policy and the Terms.
Biometric and Likeness-Sensitive Data
If you upload real-person materials, authorization recordings, likeness, face, voice, or other sensitive identity material, you confirm you have the required rights and consents. You are responsible for lawfully obtaining permissions from any person whose likeness or voice is used.
5. Data Residency, Transfers, and Subprocessors
Infrastructure and Hosting
Tubagen uses enterprise-grade cloud infrastructure, including AWS, with layered operational controls and resilient architecture.
International Transfers
Where data is transferred across borders, we apply appropriate safeguards such as contractual clauses and equivalent protections required by applicable law.
Subprocessors
We engage vetted subprocessors for infrastructure, analytics, payments, communications, and AI inference. We require contractual security and privacy commitments from each subprocessor.
Business Transfers and Corporate Changes
If we are involved in a merger, acquisition, financing, restructuring, or sale of assets, relevant data may be transferred as part of that transaction subject to appropriate confidentiality and legal safeguards.
6. Security Controls
Encryption and Transport Security
Data is protected in transit using TLS and protected at rest using industry-standard encryption controls.
Access Management
We apply least-privilege access controls, role-based permissions, and monitored administrative access to production environments.
Operational Security
We maintain logging, monitoring, incident response processes, and periodic control reviews to protect service integrity.
No Perfect Security
No internet transmission, storage system, or cloud service can be guaranteed to be completely secure. You should use strong credentials, protect account access, and access the service from secure environments.
7. Retention and Deletion
We retain personal data for as long as needed to provide services, meet legal obligations, and resolve disputes. Workspace owners can delete projects and assets, and may request account deletion subject to legal and security retention requirements.
8. Your Rights and Choices
Data Rights
Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, object, or request portability of your personal data.
Hong Kong PDPO Rights
Where the Hong Kong Personal Data (Privacy) Ordinance applies, you may request access to personal data we hold about you, request correction of inaccurate data, and withdraw consent where processing is based on consent. We may take reasonable steps to verify your identity and may charge a lawful, reasonable fee for data access requests where permitted.
Workspace Context
If your data is processed under a customer workspace, requests may be routed to that workspace administrator as the primary controller of project data.
Marketing and Preferences
You can opt out of marketing emails at any time via unsubscribe controls or by contacting us.
9. Cookies and Similar Technologies
We use cookies and similar technologies to support authentication, security, session continuity, analytics, and product performance. You can control cookie preferences through browser settings where available.
10. Children and Age Requirements
Tubagen is not intended for children under 18 or under the age required by applicable law to consent to data processing, whichever is higher. If you believe a child has provided personal data in violation of this policy, contact us for removal review.
11. Policy Updates
We may update this policy to reflect legal, technical, or product changes. Material updates will be posted on this page with a revised effective date.
12. Contact Us
For any privacy-related inquiries, please reach out to:
Legal Department
Tuba Intelligence Limited
Registered Office:
Room 701, Unit 108, 7/F, Tower B
New Mandarin Plaza
14 Science Museum Road
Tsim Sha Tsui, Kowloon
HONG KONG
The address above is our registered office address for legal correspondence.
legal@tubagen.ai