# DualCam — Terms of Service, Privacy Notice and Acceptable Use Policy

**Version 2.0 · Draft for legal review**
**Last updated: [PUBLICATION DATE]**

*The Spanish version of this document is the governing text. This translation is provided for convenience.*

This document brings together the instruments that govern the use of the DualCam application (dualcam.io) and all of its services:

1. **DualCam Terms of Service** (Part 1)
2. **DualCam Pro Subscription** (Part 2)
3. **DualCam Cloud** (Part 3)
4. **Privacy Notice** (Part 4, required under Mexico's LFPDPPP)
5. **Acceptable Use Policy** (Part 5)
6. **Copyright Infringement Notices** (Part 6)
7. **Affiliate Program** (Part 7)

> ⚠️ **Internal note (do not publish):** Working draft. Must be reviewed by a lawyer specialising in data protection and technology before publication. Fields in brackets [ ] must be completed with the details of the legal entity operating DualCam. Pending decisions are listed in the Annex.

---

# PART 1 — DUALCAM TERMS OF SERVICE

## 1. Acceptance and scope

1.1. These Terms of Service ("Terms") govern the use of the **DualCam** web application, available at dualcam.io, and all of the services it comprises (the "Services"), operated by **[LEGAL NAME / NAME OF THE CONTROLLER]**, with registered address at **[ADDRESS]**, Monterrey, Nuevo León, Mexico ("DualCam", "we").

1.2. By creating an account or using any of the Services, the user ("you", "the User") accepts these Terms, the Privacy Notice (Part 4) and the Acceptable Use Policy (Part 5) in full. If you do not agree, do not use the Services.

1.3. Some Services carry additional conditions that apply only when you activate or purchase them: the Pro Subscription (Part 2), DualCam Cloud (Part 3) and the Affiliate Program (Part 7).

## 2. Description of the Services

2.1. DualCam is a tool for making video clips. It lets the User:

- **Record** their computer screen and, optionally, their phone's camera as a reaction, together with the computer's microphone, synchronised in a single session.
- **Edit** the recording: trim the segment, frame the camera, choose vertical or horizontal orientation and adjust the audio mix.
- **Export** the result as an MP4 video file. The final composition is rendered on DualCam's servers.
- **DualCaption:** generate automatic subtitles through a third-party transcription service and burn them into the video (paid feature).
- **Live streaming:** relay the session to third-party platforms that accept RTMP, such as Twitch or TikTok, using the User's own streaming credentials (paid feature).
- **DualCam Cloud and Library:** store exported clips in the cloud and access them from other devices (Part 3).

2.2. The Services are provided **"as is"**. DualCam will make commercially reasonable efforts to keep them available, but does not guarantee uninterrupted availability, absence of errors, or compatibility with every browser or device.

2.3. **Technical limits.** The Services have limits on recording length, number of exports, processing time and storage, which vary by plan (free or Pro) and are shown in the application. DualCam may adjust these limits to preserve the stability of the service, with notice in the application.

## 3. Account, requirements and security

3.1. Using the Services requires an authenticated account via Google or email. The User is responsible for keeping their credentials confidential and for all activity carried out from their account.

3.2. The User must notify DualCam immediately ([SUPPORT EMAIL]) of any unauthorised use of their account.

3.3. The Services are intended for people **aged 18 or over**, or minors with the verifiable consent of their parents or guardians under applicable law. By creating an account, you declare that you meet this requirement.

3.4. **Record of acceptance.** DualCam keeps the date and the version of the Terms accepted by each account, as evidence of consent.

## 4. Ownership of content

4.1. **Your content is yours.** The User retains at all times full ownership of the intellectual property rights in the videos, audio, images and other materials they record, edit, export, stream or store through the Services ("User Content"). Using the Services **transfers no ownership rights to DualCam** over your content.

4.2. **Limited operating licence.** By using the Services, you grant DualCam a limited, non-exclusive, revocable, worldwide licence to **receive, host, process, transmit, technically reproduce and deliver** your content, solely for the purpose of providing the Services you request: composing your export, transcribing it for subtitles if you ask, relaying it if you enable streaming, and storing it if you enable Cloud. This licence ends when you delete the content or cancel your account, except for the residual and evidentiary copies described in Parts 3 and 4.

4.3. **What we do not do with your content:**

- We do not view, analyse or profile it for commercial or advertising purposes.
- We do not use it to train artificial intelligence models, our own or third parties'. When you request subtitles, the audio is sent to a transcription provider solely to produce the text; see Part 4, section 5.
- We do not sell, license or share it with anyone.
- We do not use it in promotional material without your express written consent.

4.4. The only exceptions are those described in section 7 (Cooperation with authorities) and in Part 6 (copyright infringement).

## 5. Responsibility for content

5.1. **The User is solely responsible** for the content they record, edit, export, stream, store or publish. By using the Services, you represent and warrant that:

- You own the rights to the content, or you have the necessary permissions from the people appearing in it and from third-party rights holders (works, music, trademarks, broadcasts).
- When you record your screen while playing third-party content, you have the right to use it in the way you do, or your use is covered by an applicable legal exception (such as quotation, criticism or review). **DualCam does not and cannot grant rights over third-party content that appears on your screen.**
- Your content and the use you make of it comply with applicable law and with the terms of the platforms where you publish or stream it.

5.2. DualCam is a **software tool provider**. It does not supervise, approve, edit or endorse User Content, and **assumes no liability** for such content or for the use the User makes of it.

5.3. Any legal, civil, criminal or administrative consequence arising from the content or from misuse of the Services falls **exclusively on the User**, who undertakes to hold DualCam, its partners, employees and suppliers harmless from any third-party claim arising from their content or their use of the Services (indemnity obligation).

## 6. Prohibited uses

6.1. It is prohibited to use the Services to record, process, stream, store or distribute content that:

a) Constitutes or documents the commission of a crime, or is intended to plan, facilitate or conceal criminal activity.
b) Involves the exploitation, abuse or sexualisation of minors, in any form. **Zero tolerance** and immediate reporting to the competent authorities.
c) Was recorded without the consent of the people appearing in it, where such consent is legally required (intimate content, private spaces, covert surveillance of third parties).
d) Constitutes threats, extortion, harassment, incitement to violence or hate speech.
e) Infringes copyright, trademarks or other intellectual property rights of third parties.
f) Contains malware or is designed to compromise the security of the Services or of third parties.
g) Violates any federal or local law applicable in Mexico or in the User's jurisdiction.

6.2. It is also prohibited to: circumvent the technical or plan limits of the Services; automate the use of the Services without authorisation; resell or sublicense the Services; and use DualCam's infrastructure for purposes other than those described in section 2.

6.3. Operational detail is set out in the **Acceptable Use Policy** (Part 5), which forms an integral part of these Terms.

6.4. Breach entitles DualCam to suspend or cancel the account immediately, remove the infringing content and, where applicable, preserve evidence and notify the authorities under section 7, without this giving rise to any liability or right to a refund in favour of the User.

## 7. Cooperation with authorities and security

7.1. **DualCam does not proactively monitor User Content.** As a general rule, nobody at DualCam views your files.

7.2. Nevertheless, the User accepts that DualCam may **access, preserve and disclose** User Content and associated data (metadata, access logs, account information) only in the following cases:

a) **Valid legal request:** court order, prosecutorial warrant or formal request from a competent authority, issued in accordance with the law.
b) **Credible third-party report:** a substantiated complaint that specific content breaches section 6 or Part 6, in which case DualCam may review only the content identified.
c) **Emergency:** where DualCam becomes aware of an imminent risk of serious harm to a person's life or physical integrity.

7.3. Where any of the above cases relating to the possible commission of a crime arises, DualCam **will cooperate with the competent authorities** and may hand over the strictly necessary content and data, in accordance with applicable Mexican law.

7.4. DualCam may preserve copies of relevant content and records as evidence for as long as the law or the relevant proceedings require, even if the User deletes their account.

## 8. Third-party services

8.1. **Publishing and streaming platforms.** Publishing or relaying your content on Twitch, TikTok, YouTube, Instagram or any other platform is done from your own accounts and under those platforms' terms. DualCam is not a party to that relationship and is not responsible for those platforms' decisions (moderation, suspension, monetisation).

8.2. **Streaming credentials.** For live streaming you provide the URL and stream key of your account on the destination platform. DualCam uses them solely to establish the relay during that session and **does not store them**. You are responsible for keeping them confidential and for regenerating them if you suspect they have been compromised.

8.3. **Infrastructure providers.** DualCam uses third-party providers for authentication, processing, storage, payments and transcription, identified in the Privacy Notice (Part 4, section 5).

## 9. Limitation of liability

9.1. To the maximum extent permitted by law, DualCam shall not be liable for indirect, incidental, special or consequential damages, including loss of content, loss of a recording, loss of business opportunities, revenue or audience, or damages arising from the use or inability to use the Services.

9.2. **Recordings are processed in the browser and on third-party servers, and may be lost** through failures of the browser, the device, the network or the service. DualCam reports the status of each recording and export within the application, but **does not guarantee the preservation of a recording that has not been exported and downloaded**. DualCam Cloud is a convenience feature, not a guaranteed backup system.

9.3. DualCam's total aggregate liability to the User shall not exceed the amount paid by the User for the Services during the **[12] months** preceding the event giving rise to the claim or, if the User has not paid, **[fixed amount]**.

9.4. The foregoing is without prejudice to the User's non-waivable rights as a consumer under the Federal Consumer Protection Law.

## 10. Changes, term and termination

10.1. DualCam may amend these Terms. Material changes will be notified within the application or by email at least **[15] calendar days** in advance, and will require fresh acceptance where the law or the nature of the change so requires. Continued use of the Services after the effective date constitutes acceptance; if you disagree, you may cancel your account and download your content.

10.2. The User may cancel their account at any time from the application or by writing to [SUPPORT EMAIL].

10.3. DualCam may suspend or terminate the Services for a User for breach of these Terms, with immediate effect in the cases under section 6.

## 11. Governing law and jurisdiction

11.1. These Terms are governed by the laws of the United Mexican States. For any dispute, the parties submit to the competent courts of **Monterrey, Nuevo León**, waiving any other forum to which they may be entitled.

11.2. The foregoing is without prejudice to the User's non-waivable consumer rights under the Federal Consumer Protection Law and, where applicable, the mandatory consumer protection rules of the User's country of residence.

## 12. Contact

Questions about these Terms: **[LEGAL/SUPPORT EMAIL]**.

---

# PART 2 — DUALCAM PRO SUBSCRIPTION

## 1. What it includes

1.1. DualCam Pro is a paid subscription that extends the Services. Its current benefits and limits are shown in the application at purchase and may include: exports without watermark, longer recordings, unlimited exports and clips, maximum quality and 4K, DualCaption, DualCam Cloud without a video limit, and live streaming.

1.2. **The maximum recording length is a technical limit of the web platform, not a plan feature.** It is shown in the application for each plan.

## 2. Price, billing and renewal

2.1. The current price is shown at the time of purchase. Unless otherwise stated in the application, the subscription is **monthly** and billed in advance at the start of each period.

2.2. **Automatic renewal.** The subscription renews automatically at the end of each period for an equal period, charged to the registered payment method, **until you cancel it**. By subscribing, you expressly authorise these recurring charges.

2.3. Payments are processed by **Stripe**. DualCam does not store full card numbers. Managing the payment method, invoices and cancellation is done through the subscription portal accessible in the application.

2.4. **Price changes.** DualCam may change the subscription price with at least **[30] calendar days'** notice by email or within the application. The new price applies from the first renewal after the notice period; if you disagree, you may cancel before that date.

## 3. Cancellation and refunds

3.1. You may cancel at any time from the subscription portal. Cancellation takes effect **at the end of the paid period**: you keep the Pro benefits until that date and are not charged again.

3.2. **[PENDING DECISION — refund policy.]** Except as required by applicable law, no refunds are given for unused partial periods.

3.3. **Effects when Pro ends.** When the subscription ends, your account returns to the free plan and its limits. Files stored in DualCam Cloud above the free plan limit **[PENDING DECISION: are kept for N days so you can download them / become inaccessible / are deleted]**.

3.4. **Granted Pro.** DualCam may grant Pro access free of charge to certain accounts (for example, for testing or collaborations). Such access has no renewal date or charge, and may be withdrawn by DualCam at any time with notice.

## 4. Fair use

4.1. "Unlimited" benefits are subject to reasonable use by an individual creator. DualCam may temporarily limit usage that compromises the stability of the service for other users, with notice.

---

# PART 3 — DUALCAM CLOUD

## 1. Activation

1.1. DualCam Cloud is an **optional feature** that is expressly activated from the Library. By activating it, you accept this Part in addition to the general Terms.

1.2. DualCam Cloud lets you store exported clips in the cloud, keep a personal library and download them from other devices with your account.

## 2. Storage, retention and deletion

2.1. Content is stored on the cloud infrastructure of specialised providers (Part 4, section 5). Files are transmitted and stored encrypted.

2.2. You may delete any file from your library at any time. Deletion removes the file from active systems; residual copies, if any, are deleted within a maximum of **[30] calendar days**, except where preservation is legally required.

2.3. When the account is cancelled, all stored content is deleted as above. It is the User's responsibility to download their files before cancelling.

2.4. Storage and video-count limits per plan are shown in the application.

2.5. DualCam Cloud is a **convenience feature, not a guaranteed backup system**. Keep local copies of any files you consider critical.

---

# PART 4 — PRIVACY NOTICE

*(Comprehensive privacy notice under Mexico's Federal Law on the Protection of Personal Data Held by Private Parties, published 20 March 2025, and other applicable regulations.)*

## 1. Controller

**[LEGAL NAME / NAME OF THE CONTROLLER]**, with registered address at **[FULL ADDRESS]**, Monterrey, Nuevo León, Mexico, is the controller of your personal data under this Notice.

Privacy contact: **[PRIVACY EMAIL]**.

## 2. Personal data we process

- **Identification and account data:** name, email address, account identifier and, where applicable, the profile photo provided by the authentication provider (for example, Google sign-in).
- **User Content:** the screen recordings, camera video and microphone audio you produce with the Services, and the exported files. This content **may contain personal data of yours or of third parties** (image, voice, and anything that appears on your screen). Its processing is limited to what is described in section 4.
- **Service usage data:** plan, export dates, processed duration per day, number of videos in the library, accepted terms version and acceptance date.
- **Technical metadata:** file name, duration, resolution, size, upload date, device and browser type.
- **Log data:** IP addresses, access dates and times, account activity records.
- **Billing data** (if you subscribe to Pro): processed directly by the payment provider; DualCam receives the subscription status and a customer identifier, not your card details.
- **Affiliate reference:** if you reach DualCam through an affiliate link, a reference code is stored in your browser and associated with your subscription to calculate the affiliate's commission.

We do not deliberately collect sensitive personal data. If your content includes sensitive information, it remains under your control and is not analysed by DualCam.

## 3. Purposes of processing

**Primary purposes (necessary for the service):**

1. Creating and managing your account and authenticating your access.
2. Receiving and processing your recordings to produce the exports you request.
3. Generating subtitles when you request them (DualCaption).
4. Relaying your session to the platform you specify when you enable live streaming.
5. Storing, syncing and delivering your files across devices (DualCam Cloud).
6. Applying the limits of the plan you hold.
7. Providing technical support.
8. Billing, subscription management and tax compliance.
9. Service security: preventing fraud, unauthorised access and abuse.
10. Complying with legal obligations and responding to requests from competent authorities.

**Secondary purposes (you may opt out without affecting the service):**

11. Sending communications about DualCam news and improvements.
12. Aggregated, anonymised usage statistics (never about the content of your videos).

You may opt out of the secondary purposes by writing to **[PRIVACY EMAIL]**.

## 4. When and how your content is processed

This section describes **the moment your content leaves your device** and what happens to it. It is the part of this Notice that matters most to understand.

4.1. **While recording**, video and audio remain on your computer. The phone camera's video travels to your computer over a direct encrypted connection between the two devices; where the network does not allow a direct connection, it passes through a relay server (TURN) that does not store it.

4.2. **When you stop recording**, the complete recording (screen, camera and microphone) is sent automatically to DualCam's processing servers, so that the export is ready. This happens **before you press "Export"** and even if you ultimately do not export. That copy is kept while you remain on the export screen and is deleted when you leave it or, at the latest, after **2 hours** of inactivity.

4.3. **When you export**, the servers compose the final file and deliver it to you. The file is deleted from the processing servers after delivery, unless you have DualCam Cloud enabled, in which case it is saved to your library.

4.4. **When you request subtitles**, the video's audio is sent to an automatic transcription provider (section 5), which returns the text. DualCam does not keep the audio sent beyond what is needed to complete the operation.

4.5. **When you live stream**, the session is relayed in real time to the platform you specify. DualCam does not record or store the stream.

4.6. **Technical diagnostics.** The application keeps a technical log of the session in your browser's memory (status messages, errors, codecs — no video or audio) to help resolve problems. **This log is not sent to DualCam**; it only leaves your device if you copy and share it voluntarily. Access signatures and credentials are removed from the log before it can be copied.

4.7. **What we do not do.** We do not view, analyse or profile your content, and we do not use it to train artificial intelligence systems, our own or third parties'. The only situations in which we might access specific content are those set out in Part 1, section 7.

## 5. Processors and transfers

To operate the Services we use providers that act as **processors**, bound by confidentiality and to process data only on our instructions:

| Function | Provider | Data location |
|---|---|---|
| Authentication and account database | Google Firebase | United States and other provider regions |
| Application hosting | Vercel | United States and global delivery network |
| Recording and export processing | Railway | United States |
| File storage (DualCam Cloud) and connection relay (TURN) | Cloudflare | United States and other provider regions |
| Payments and subscriptions | Stripe | United States and other provider regions |
| Automatic transcription (DualCaption) | OpenAI | United States |

These transfers are necessary to provide the service you request and are made under the exceptions provided by law (performance of the contract between the data subject and the controller). Beyond this, **we do not transfer your personal data or your content to third parties**, except on a lawful request from a competent authority.

**[PENDING VERIFICATION — lawyer:** confirm against each provider's terms, in particular OpenAI's API data-usage policy regarding model training, before publishing.]

## 6. Retention

| Data | Period |
|---|---|
| Recording sent on stop (processing copy) | Until you leave the export screen, or at most 2 hours of inactivity |
| Exported file without DualCam Cloud | Deleted after delivery to you |
| Exported file with DualCam Cloud | For as long as you keep it in your library; residual copies up to [30] days after deletion |
| Audio sent for subtitles | As long as needed to complete the transcription |
| Live-streaming credentials | Not stored |
| Account and usage data | While the account is active, and thereafter for the applicable legal periods |
| Access logs | [PENDING DECISION: N days] |
| Evidence preserved under a legal request | As long as the law or the proceedings require |

## 7. ARCO rights and withdrawal of consent

You have the right to **Access** your data, **Rectify** it, **Cancel** it and **Object** to its processing (ARCO rights), as well as to withdraw your consent and to limit the use or disclosure of your data.

To exercise them, send a request to **[PRIVACY EMAIL]** with: (i) your name and the email associated with the account, (ii) a document proving your identity, (iii) a clear description of the right you wish to exercise. We will respond within the periods provided by law.

In addition, from the application itself you may at any time: download your files, delete them, disable DualCam Cloud, cancel your subscription and cancel your account.

If you believe your right to data protection has been violated, you may apply to the competent personal-data-protection authority (currently, the Secretaría Anticorrupción y Buen Gobierno, through the Transparencia para el Pueblo unit).

## 8. Security

We apply administrative, technical and physical security measures: encryption in transit (TLS) and at rest, per-account access control, server-side plan verification (never trusting what the browser declares), audit logs and segregation of storage infrastructure.

## 9. Cookies and local storage

The application uses your browser's local storage to remember your session, your language preference, your acceptance of the terms and, where applicable, an affiliate reference code. We do not use advertising cookies or third-party tracking tools. **[VERIFY if analytics tools are added in the future.]**

## 10. Changes to this Notice

Any change will be published at **[NOTICE URL]** and, in the case of material changes, notified within the application or by email.

---

# PART 5 — ACCEPTABLE USE POLICY

## What DualCam is

DualCam is a tool for creators: record your screen with your reaction, trim, frame, subtitle and export clips ready to publish. It is made for **your own, lawful, authorised content**.

## What is prohibited

By using DualCam you undertake **not** to record, process, stream, store or distribute through the service:

**1. Criminal content.** Material that documents, plans, facilitates or conceals the commission of crimes: real violence, trafficking in substances or weapons, fraud, extortion, or any unlawful activity.

**2. Child exploitation material.** Any content that sexualises, exploits or endangers minors. **Zero tolerance:** on a verified report or a request from an authority, evidence is preserved, the account is cancelled and the competent authorities are notified immediately.

**3. Non-consensual recordings.** Intimate content or content from private spaces recorded without the consent of the people appearing, or shared without their authorisation (including so-called "revenge porn", punishable in Mexico under the Ley Olimpia).

**4. Harassment, threats and hate.** Content intended to threaten, extort, harass, dox or incite violence or discrimination against people or groups.

**5. Infringement of third-party rights.** Content you use without holding the rights: works, music, trademarks, broadcasts or third-party material without licence, authorisation or an applicable legal exception. Recording your screen does not make what appears on it yours.

**6. Technical abuse.** Malware, attempts to compromise the security of the service, circumvention of plan limits, unauthorised automation, use of storage for purposes other than clips made with DualCam, or unauthorised resale of the service.

## How this policy is enforced

- **We do not monitor your content.** There is no routine review of your files, human or automated.
- We act only on: (a) a valid legal request from a competent authority, (b) credible third-party reports, including notices under Part 6, or (c) emergencies involving a risk to a person's life or physical integrity.
- On a confirmed breach we may: remove the content, suspend or cancel your account, preserve evidence and **hand over the content and associated data to the competent authority** where the law permits or requires it.
- Misuse of the service is the sole responsibility of whoever commits it.

## Reports

If you detect content or conduct that breaches this policy, report it to **[ABUSE EMAIL, e.g. abuse@dualcam.io]**. Reports are reviewed confidentially.

---

# PART 6 — COPYRIGHT INFRINGEMENT NOTICES

## 1. Purpose

DualCam respects intellectual property rights. This Part sets out the procedure for a rights holder to notify that content stored in DualCam Cloud infringes their rights, in accordance with Mexico's Federal Copyright Law and, as applicable to users in other countries, equivalent legislation.

It applies to content **stored** in DualCam Cloud. Recordings the User exports and downloads without enabling Cloud do not remain with DualCam and fall outside this procedure.

## 2. How to notify

Send your notice to **[COPYRIGHT EMAIL, e.g. copyright@dualcam.io]** with:

a) Identification of the work whose rights you consider infringed.
b) Identification of the allegedly infringing content, with enough information to locate it (for example, the account or the download link).
c) Your contact details: name, email address and, where applicable, the capacity in which you act.
d) A statement that you believe in good faith that the use is not authorised by the rights holder, their agent or the law.
e) A statement, under penalty of perjury, that the information is accurate and that you are the rights holder or authorised to act on their behalf.
f) A physical or electronic signature.

## 3. What we do

3.1. On receiving a complete notice, DualCam will promptly remove or disable access to the identified content and notify the affected User, providing them with a copy of the notice.

3.2. **Counter-notice.** The User may send a counter-notice to the same address, identifying the removed content, stating under penalty of perjury that they believe in good faith it was removed by mistake or misidentification, and accepting the jurisdiction in Part 1, section 11. If the rights holder does not inform us within the statutory period that they have filed an action, DualCam may restore the content.

3.3. **Repeat infringers.** DualCam will cancel the accounts of Users who, in appropriate circumstances, are the subject of repeated infringements.

3.4. False or bad-faith notices and counter-notices may give rise to legal liability for the person submitting them.

---

# PART 7 — AFFILIATE PROGRAM

**[PENDING DECISION — this Part requires the program's commercial conditions to be defined before publication.]**

## 1. Participation

1.1. DualCam may offer certain users ("Affiliates") a referral link. When a person reaches DualCam through that link and subscribes to DualCam Pro, the subscription is associated with the Affiliate.

1.2. Participation is by invitation or acceptance by DualCam and may be terminated by either party with notice.

## 2. Commissions

2.1. The Affiliate will receive **[PERCENTAGE / AMOUNT]** for **[each monthly payment / the first payment]** of referred subscriptions, for **[PERIOD]**.

2.2. Commissions are calculated on payments actually collected, settled **[FREQUENCY]** by **[PAYMENT METHOD]**, with a minimum of **[MINIMUM AMOUNT]**, less refunds and chargebacks.

## 3. Prohibited practices

The Affiliate may not: use misleading advertising or impersonate DualCam; bid on DualCam trademarks in paid advertising; send unsolicited communications (spam); self-refer or refer accounts under their control; or promote DualCam in contexts that breach the Acceptable Use Policy. Breach results in forfeiture of pending commissions and termination from the program.

## 4. Data

The Affiliate receives only aggregated information about their referrals (number of conversions and commissions), never personal data of the referred users.

---

# ANNEX — IMPLEMENTATION NOTES AND PENDING DECISIONS (internal, do not publish)

## A. Entity details (required for publication)

- [LEGAL NAME / NAME OF THE CONTROLLER] · [FULL ADDRESS]
- [PRIVACY EMAIL] · [SUPPORT EMAIL] · [LEGAL/SUPPORT EMAIL] · [ABUSE EMAIL] · [COPYRIGHT EMAIL]
- [PUBLICATION DATE] · [NOTICE URL]

## B. Product/business decisions

1. **Refunds** (Part 2, 3.2): concrete policy.
2. **Effects of Pro ending on the Library** (Part 2, 3.3): what happens to videos above the free limit.
3. **Price-change notice period** (Part 2, 2.4): [30] days proposed.
4. **Retention of residual Cloud copies** (Part 3, 2.2): [30] days proposed — verify whether R2 keeps real residual copies or deletion is immediate.
5. **Access-log retention** (Part 4, 6).
6. **Affiliate program** (Part 7): percentage, period, frequency, minimum, payment method.
7. **Liability cap for free users** (Part 1, 9.3).
8. **Markets outside Mexico:** if the service is offered in the EU, assess GDPR (legal basis, processor contracts, transfer mechanism to the US); if in the US, CCPA and state auto-renewal laws, and DMCA agent registration.

## C. Legal verifications

1. OpenAI API data-usage policy regarding training (Part 4, 5).
2. Cooperation-with-authorities clause (Part 1, 7), indemnity (5.3) and limitation of liability (9) against the Federal Consumer Protection Law.
3. Part 6 procedure against the LFDA mechanism (2020 reform) and, if applicable, the DMCA.
4. Age requirement (3.3) and its verification.

## D. In-app implementation (status)

- Acceptance recorded in Firestore with version and date at sign-in — **implemented in v2.0**.
- Separate Cloud acceptance, from the Library — **already existed**.
- Versioning: `TERMS_VERSION` constant in code; a version change requires fresh acceptance — **implemented in v2.0**.
- No automated content detection: AUP enforcement is 100% reactive. If detection technology is ever integrated, update the documents and notify before activating it.
- DE/FR/PT translations of v2.0: **pending**; until then those languages show the English version with a notice.
