Privacy Policy

Welcome to Smuzo (“Smuzo”, “we”, “us” or “our”). Smuzo is an AI song-generation service available at smuzo.ai (the “Website”) and through the Smuzo mobile application (the “App”). This Privacy Policy (“Policy”) explains how we collect, use, store, share and protect your personal data when you use the Website, the App and the products and services provided through them (together, the “Services”).

The Services are offered to users in the United States, the European Economic Area (“EEA”), the United Kingdom (“UK”) and other countries. Sections that apply only to residents of particular regions are marked as such: Section 6.2 for the EEA and UK, Section 6.3 for US states.

By using the Services, you confirm that:

• you have read and understood this Policy;
• you meet the minimum age requirements in Section 7.1 and, if you are under 18, your parent or legal guardian has agreed to this Policy.

If you cannot make this confirmation, do not use the Services. In that case, please:

• contact us and request deletion of your data;
• leave the Website, delete the App and stop using the Services;
• cancel any active trial or subscription.

Where you are in the EEA or UK, our processing does not rely on your acceptance of this Policy; it relies on the legal bases set out in Section 4. Nothing in this Policy limits rights you have under applicable law.

This Policy may be translated from English. If a translation conflicts with the English version, the English version prevails, unless mandatory law requires otherwise.

If you have questions about this Policy, contact us at support@appliks.com.

1.1 Data controller

The controller of your personal data is AppLiks Sp. z o.o., Aleja Jana Pawla II 43A/37B, 01-001 Warsaw, Poland (“AppLiks”). AppLiks operates the Smuzo brand.

• Email: support@appliks.com
• Phone: +1 917 970 2920

We collect data you give us, data we receive from third parties and data collected automatically when you use the Services.

2.1 Data you give us

• Account and contact data. Your email address and, if you provide them, your name and password. We use your email to give you access to your account, send payment confirmations and contact you about the Services.
• Song requests. The story, names, occasion, memories, preferred genre, mood, voice and any lyrics or text you enter to create a song.
• Voice recordings (“My Voice”). If you choose to use the My Voice feature, the audio recordings you upload or record and the voice model created from them. See Section 2.2.
• Generated content. The songs, lyrics, titles and cover images created for you and stored in your library.
• Support communications. The content of messages you send to our support team and your contact details.

Your song requests may contain information about other people, such as the person a song is for. Only share information about others that you are entitled to share. Please do not include sensitive data, such as information about health, religion, sexual life or political opinions, in your requests.

2.2 Voice recordings

If you choose to use My Voice, we process the audio recordings you upload or record and the voice model created from them. Before you first use My Voice, we ask for your separate, explicit consent through a dedicated checkbox. You can withdraw it at any time. Only upload recordings of your own voice, or of a person who has given you permission to do so.

2.2.1 Processing

Your voice recording is transmitted over encrypted HTTPS/TLS connections to our cloud infrastructure provider and processed by our AI audio generation provider to create your voice model. Recordings and voice models are used solely to generate the songs you request in your own voice. Our providers act as our service providers and may process this data only as needed to provide the Services to you. Neither we nor our providers use your voice recordings or voice model to train AI models.

2.2.2 Storage and Retention

We store your voice recordings and voice model so that you can use My Voice for future songs. We keep them until you delete them or your account, and in any event no longer than 3 years after your last use of My Voice.

2.2.3 Deletion and User Control

You can delete your voice recordings and voice model in your account at any time, or by contacting us. We permanently delete them promptly after you delete them or your account. Deleting the App does not delete data stored in your account.

2.2.4 Sharing and Prohibited Uses

Voice recordings and voice models are not sold, rented, licensed or shared with advertising platforms, analytics providers, data brokers or other third parties for their own purposes. We do not use them for:

• advertising or marketing;
• tracking or analytics;
• identity verification or authentication;
• voice or speaker recognition;
• profiling;
• training AI models; or
• any purpose unrelated to generating the songs you request.

2.3 Data from third parties

• Sign in with Google or Apple (where available). We receive your name, email address and, for Google, your profile picture. With Apple you may choose to share a private relay email instead of your real address.
• Payment processors. Confirmation that a payment succeeded or failed, the payment method type, the last four digits and country of your card, and billing dates. We never receive or store your full card number. For purchases in the App, payment is processed by Apple; we receive only the purchase confirmation, subscription status and transaction ID.
• Advertising and analytics partners. Information about which advertisement or campaign brought you to the Website or the App.

2.4 Data collected automatically

• How you found us. The referring website or app and the campaign parameters in the link you followed (for example, UTM parameters and advertising click identifiers).
• Device and browser data. IP address, approximate location derived from your IP address (country and city), browser type and version, operating system, device type and model, app version, language and time zone. In the App, with your permission, also your Apple Identifier for Advertising (IDFA), see Section 2.6.
• Usage data. Pages viewed, features used, songs created, coins spent, clicks, session times and errors.
• Transaction data. Your plan, trial and subscription status, coin balance, payment and renewal dates, amounts, currency and refunds.

2.5 Plans and payments

• The Services are available as a paid trial and as subscriptions with different billing periods. The price, billing period and features of each plan, including the coins and storage it includes, are shown at checkout and in your confirmation email.

Trials and subscriptions renew automatically until cancelled. To process them we collect the transaction data described in Sections 2.3 and 2.4. Card details are entered directly into our payment processor’s secure form, or into Apple’s payment system for purchases in the App, and are governed by their own privacy policies.

2.6 Cookies and similar technologies

• Cookies are small text files stored in your browser. We also use pixels, local storage and SDKs that work in a similar way (together, “cookies”). We use:
• You can block or delete cookies in your browser settings; some parts of the Services may then not work. In the US you can also opt out of advertising cookies as described in Section 6.3. Third-party partners that set cookies process data under their own privacy policies.

In the App we use SDKs that work in a similar way. On iOS, we ask for your permission through Apple’s App Tracking Transparency prompt before we track you across other companies’ apps and websites, and collect your Apple Identifier for Advertising (IDFA) only if you allow it. You can change this at any time in your device settings.

2.7 Do Not Track and Global Privacy Control

There is no common standard for browser “Do Not Track” signals, so we do not respond to them. We do honor Global Privacy Control (“GPC”) signals: when your browser sends a GPC signal, we treat it as a request to opt out of the sale or sharing of your personal data and of targeted advertising for that browser.

We use your personal data for the following purposes.

• To provide the Services. We create songs, lyrics and cover images from your requests using AI models, apply your voice model when you use My Voice, keep your songs in your library and fix errors.
• To manage your account, plan and coins. We activate your trial or subscription, credit and deduct coins and provide the storage included in your plan.
• To process payments. We charge the trial fee and subscription renewals, handle failed payments and refunds and keep payment records. Payment card data is handled only by our payment processors, or by Apple for purchases in the App.
• To provide customer support. We answer your questions and requests and send you service messages about your account, payments, security and changes to our terms.
• To communicate with you. We send transactional emails, such as payment receipts, renewal notices and notices that a payment failed. You cannot opt out of these while you have an account. In the App we may also send push notifications, for example when your song is ready; you can turn them off in your device settings.
• To send marketing. We send news, offers and new features by email. In the EEA and UK we do this only with your consent, or to existing customers about similar services where the law allows. You can unsubscribe at any time via the link in each email.
• To measure and personalize advertising. We measure which ads lead to sign-ups and purchases and, where permitted, show you relevant ads on social media and other advertising platforms. See Sections 2.6 and 6.3 for your choices.
• To analyze and improve the Services. We study how the Services are used, test new features and offers and fix problems.
• To prevent fraud and enforce our terms. We detect abuse, payment fraud and content that breaks our Terms and Conditions, and we defend our legal rights.
• To comply with the law. We keep tax and accounting records and respond to lawful requests from authorities.

3.1 AI processing and model training

Song generation is automated: AI models turn your request into a song. This processing does not produce decisions with legal or similarly significant effects for you.

We do not use your song requests, lyrics or voice recordings to train AI models.

This section applies if you are in the EEA or the UK. We process your personal data under the EU General Data Protection Regulation (“GDPR”) and, for UK users, the UK GDPR and the Data Protection Act 2018.

We rely on the following legal bases:

• performance of our contract with you, to provide the Services and song generation, manage your account, plan and coins, process payments, provide customer support and send transactional messages;
• your consent, for voice recordings and My Voice, analytics and advertising cookies, personalized advertising, and marketing emails where consent is required;
• our legitimate interests, to keep the Services secure and prevent fraud, analyze and improve the Services, market similar services to existing customers, and enforce our terms and defend legal claims;
• legal obligations, such as keeping tax and accounting records and responding to lawful requests from authorities.

You can withdraw consent at any time, through your account, browser or device settings, or by contacting us. Withdrawal does not affect processing carried out before it.

You have the right to object to processing based on our legitimate interests. We will stop unless we have compelling legitimate grounds that override your interests, rights and freedoms, or we need the data to establish, exercise or defend legal claims. You can object to direct marketing at any time, and we will always stop.

We do not sell your personal data for money. We share it only as described below.

5.1 Who we share data with

• Service providers (processors). Companies that act on our instructions: cloud hosting and storage, AI model and audio generation providers, payment processors, analytics providers, email and customer support tools. They may use your data only to provide their services to us.
• Advertising partners. Advertising platforms, such as social media networks, receive data from their pixels on the Website and their SDKs in the App (such as page views, sign-ups, purchases, IP address and device data) to measure and optimize our ads. They process this data under their own privacy policies. You can limit this as described in Sections 2.6 and 6.3.
• People you share songs with. If you share a song link or make a song public, anyone with the link, or anyone visiting the Website, can hear it and see its title and cover.
• Authorities and legal requests. Courts, law enforcement and regulators where the law requires it, or to protect our rights, our users or the public.
• Corporate transactions. A buyer or successor in a merger, acquisition, financing or sale of assets, under confidentiality obligations; and companies in our group.

5.2 International data transfers

We and our service providers may process your personal data in countries other than the one where you live, including outside the EEA and the UK.

When we transfer EEA or UK personal data to a country that does not provide an adequate level of data protection, we use appropriate safeguards recognized under applicable law, such as standard contractual clauses.

5.3 How long we keep your data

We keep your personal data only for as long as reasonably necessary for the purposes described in this Policy, including providing the Services to you, and as needed to comply with our legal obligations, resolve disputes and enforce our agreements.

To determine how long we keep data, we consider:

• how long you have an account with us or keep using the Services;
• the storage included in your plan, and whether you have deleted content yourself;
• legal requirements, for example tax and accounting laws that require us to keep transaction records for a certain period;
• whether retention is advisable in view of our legal position, such as limitation periods, litigation or regulatory investigations.

Voice recordings and voice models are kept as described in Section 2.2. When data is no longer needed, we delete or anonymize it.

To exercise any right below, email support@appliks.com from the address linked to your account. We may ask for information to verify your identity before we act. We respond within the period required by law: one month in the EEA and UK, 45 days in the US. Either period can be extended where the law allows, and we will tell you if it is.

6.1 Rights of all users

• Access and correction. View and update your account data in your account settings, or ask us for a copy.
• Deletion. Delete songs, voice recordings or your whole account, or ask us to do it.
• Marketing opt-out. Unsubscribe via the link in any marketing email.
• Cookie choices. Block or delete cookies in your browser settings, and turn off tracking for Smuzo in your iOS settings.

Deleting your account or the App does not cancel a subscription automatically. Please cancel it first so that you are not charged again; subscriptions bought in the App are cancelled in your Apple ID settings.

6.2 Additional rights in the EEA and UK

If you are in the EEA or the UK, you also have the right to restrict or object to our processing of your data, to receive your data in a portable format, to withdraw your consent at any time, and to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work. We would appreciate the chance to resolve your concern first.

We may refuse or charge a reasonable fee for requests that are manifestly unfounded or excessive.

6.3 US state privacy rights

This section applies to residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and other US states with similar laws, to the extent those laws apply to us.

Your rights. Depending on your state, you have the right to:

• know and access the personal data we hold about you and obtain a portable copy;
• correct inaccurate personal data;
• delete your personal data;
• opt out of the sale of personal data, “sharing” for cross-context behavioral advertising, and targeted advertising;
• opt out of profiling in furtherance of decisions with legal or similarly significant effects (we do not carry out such profiling);
• not be discriminated against for exercising your rights. We will not deny you the Services, charge you a different price or give you a lower quality of service because you exercised them.

Advertising opt-out. We do not sell personal data for money. However, the advertising pixels on the Website and SDKs in the App may count as “sharing” or “targeted advertising” under some state laws. To opt out:

• in the App, turn off tracking for Smuzo in your iOS settings (Privacy & Security, then Tracking);
• turn on Global Privacy Control in your browser (Section 2.7); or
• email support@appliks.com with the subject “Opt out of targeted advertising”.

Authorized agents. You may use an authorized agent to make a request. We will ask for proof that you gave the agent signed permission, and we may ask you to verify your identity directly with us.

Appeals. If we decline your request, you can appeal by emailing support@appliks.com with the subject “Appeal of privacy request decision”. We will respond in writing within 60 days (45 days in some states) and explain our decision. If your appeal is denied, you may contact your state Attorney General.

California notice at collection

In the past 12 months we have collected the following categories of personal information, as defined by the California Consumer Privacy Act (“CCPA”): identifiers (such as email, name and IP address), commercial information (such as purchases and plan details), internet or network activity, approximate geolocation, audio information (voice recordings, if you use My Voice) and user content (such as song requests and generated songs).

We collect this information from you, your device and the third parties described in Section 2.3, use it for the purposes in Section 3, and keep it as described in Section 5.3. We disclose it for business purposes to service providers, as described in Section 5.1. Identifiers, commercial information, internet activity and approximate geolocation may be shared with advertising partners for cross-context behavioral advertising; audio information and user content are not. We do not collect or use sensitive personal information to infer characteristics about you. We do not knowingly sell or share the personal information of consumers under 16.

Shine the Light. California residents may ask once per year for a list of the personal information we disclosed to third parties for their direct marketing purposes in the previous calendar year. We do not make such disclosures. To ask, email support@appliks.com with “Your California privacy rights” in the subject line.

7.1 Children

To use the Services, you must be at least 13 years old, or at least 16 years old if you are in the EEA or the UK. If you are under 18, you may use the Services only with the consent of your parent or legal guardian, who is responsible for any purchases.

We do not knowingly collect personal data from children below these ages. If you are a parent or guardian and believe your child has given us personal data, contact us and we will delete it.

7.2 Security

We use technical and organizational measures to protect your personal data. These include encryption in transit and at rest, access controls limited to staff who need the data, and regular security reviews. No method of transmission or storage is completely secure. Please use a strong, unique password and do not share your login details.

If a data breach is likely to put your rights at high risk, we will notify you and the competent authorities as required by law.

7.3 Changes to this Policy

We may update this Policy from time to time. The “Last update” date at the top shows when it was last changed. If we make material changes, we will notify you by email or through the Services before they take effect. Where the law requires your consent to a change, we will ask for it.

7.4 Contact us

For questions about this Policy, your account or your personal data, contact:

AppLiks Sp. z o.o., Aleja Jana Pawla II 43A/37B, 01-001 Warsaw, Poland

• Email: support@appliks.com
• Phone: +1 917 970 2920