Data processing

1. What we do with your data

We process it to run the service you signed up for: storing your roster, building and holding identities, generating images and video, sharing the work you choose to share, and keeping the consent records. Nothing else. We do not use it to train any model, we do not show it to another customer, and we do not sell it.

Your instructions are how you use the account, plus these terms. If we think an instruction breaks data-protection law we will tell you, and we can decline to carry it out.

2. The data, the people, how long

Whose data. The talent on your roster, the clients and contacts you record, and anyone who appears in an image you upload.

What data. Photographs, including the facial images an identity is built from, and every image and clip generated from them. Names, measurements and appearance. The consent records you create. If your account includes Bouqx Desk, also identity documents, dates of birth, contact details, and job and travel details. Facial images used to keep a likeness consistent may be biometric data; treat them as such.

AI talent is not a person. A face invented in Bouqx depicts nobody, so the images of it are not personal data about anyone.

How long. For as long as your account exists, and then as set out in section 10.

3. Our people

Only people who need access to run the service have it, and they are bound to keep what they see confidential.

4. Keeping it safe

Data travels encrypted and is stored encrypted by our hosting provider. Identity document numbers carry a second layer of encryption with a key only our servers hold, and every time one is revealed it is logged. Consent records and the audit ledger can only be written by our servers, never from a browser, so they cannot be back-dated or edited. Share links are random, can expire, and can be revoked. Access to an account is behind its own sign-in.

One limit you should know: an image someone has already downloaded, or whose direct address they copied while a link was live, cannot be recalled by revoking the link.

5. Sub-processors

You authorise us to use these sub-processors. Each receives only what its job needs.

• Google (Firebase and Google Cloud): hosting, database, file storage, sign-in. Gemini: image generation and checking a face matches.
• Vercel: serves the web app; images pass through it on their way to your screen.
• OpenAI: image generation.
• fal: image and video generation, running ByteDance and Kling models.
• Higgsfield: video generation.
• Topaz Labs: upscaling.
• Anthropic: reading briefs and documents you upload, and writing text.
• Resend: sending email, for Desk accounts.

We bind each one to data-protection terms at least as protective as these. Before we add or replace one we will tell you by email at least 30 days ahead. If you object and we cannot address it, you can leave before the change takes effect and we will refund what you prepaid for the time after it. We stay responsible to you for what our sub-processors do.

6. Where it is processed

Your data is stored and processed in the United States, and our sub-processors may process it there too.

7. Transfers out of the EU and UK

Where you are in the EU or EEA, the EU Standard Contractual Clauses (Commission Decision 2021/914, Module Two, controller to processor) are incorporated into this agreement between you and us, with sections 2 and 4 of this agreement as their annexes. Where you are in the UK, the UK Addendum to those clauses applies as well. For our sub-processors, we rely on their certification under the EU-US Data Privacy Framework or bind them to the same clauses.

8. Helping you

The account gives you the tools to answer most requests from the people in your data yourself: you can find, correct and delete a talent’s records and revoke their consent, and the revocation reaches work you have already shared. Where a request needs us, we will help. We will also help with a data-protection impact assessment or a question from a regulator, as far as the information is ours to give.

If a person asks us directly about data in your account, we will pass the request to you rather than answer it ourselves.

9. If something goes wrong

If we become aware of a breach affecting your data we will tell you without undue delay, and aim to within 48 hours, with what we know: what happened, what data and whose, what we have done, and who to talk to. We will keep you updated as we learn more.

10. When you leave

Deleting your account from Settings erases your roster, images, identities, documents, share links and everything else stored under it. One thing is kept: the consent records, which hold a talent reference, a use and dates, with no image, name or contact detail. They exist to protect the person whose face it was and are kept so a dispute about what was permitted can still be answered. What our sub-processors retain from a request is governed by their own terms.

11. Checking on us

We will give you the information you reasonably need to show we keep to this agreement. If that is not enough, you can audit us once a year, at your cost, with 30 days’ notice, under a confidentiality agreement, and without disturbing the service for others.

12. The rest

The liability limits in the terms apply to this agreement as well, except where the law or the clauses in section 7 say they cannot. This agreement lasts as long as we process personal data for you. Questions go to privacy@bouqx.com.