Effective Date: April 16, 2026

Last Updated: April 16, 2026

Version 1.0

Welcome to our creative app (the “Application,” “App,” “Service,” or “Platform”), an AI-powered advertising creative generation tool developed and operated by IBD Ventures LLC (“we,” “us,” “our,” or the “Company”). This Privacy Policy (“Policy”) describes in detail how we collect, use, disclose, store, protect, and otherwise process your personal information when you access or use our Application, including our integrations with Meta Platforms, Inc. (“Meta”), its APIs, products, and affiliated services (collectively, “Meta Services”).

This Policy applies to all users of the Application, including visitors to our website, registered account holders, paying subscribers, and developers integrating with our platform (collectively, “you,” “your,” or “User”). By accessing or using the Application, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and our Terms of Service. If you do not agree with any part of this Policy, please discontinue your use of the Application immediately.

IMPORTANT NOTICE REGARDING META PLATFORM INTEGRATION: This Application integrates with the Meta Marketing API, Meta Graph API, and other Meta developer tools to enable advertising creative generation and campaign management on Meta platforms (including Facebook, Instagram, and the Meta Audience Network). As a result of this integration, certain data you provide may be processed by Meta’s systems in accordance with Meta’s own Privacy Policy and Data Use Policy. We strongly encourage you to review Meta’s Privacy Policy at https://www.facebook.com/privacy/policy/ and Meta’s Platform Terms at https://developers.facebook.com/terms/ to understand how Meta processes data independently of this Application.

TABLE OF CONTENTS

1.  Definitions and Interpretation

2.  Information We Collect

3.  How We Use Your Information

4.  Meta API Integration and Data Sharing

5.  Legal Bases for Processing (GDPR)

6.  Data Sharing and Disclosure

7.  Cookies and Tracking Technologies

8.  Data Retention

9.  Data Security

10. Your Privacy Rights

11. Children’s Privacy

12. International Data Transfers

13. Third-Party Services and Links

14. AI-Generated Content and Data

15. Advertising and Marketing

16. Business Transfers

17. Changes to This Privacy Policy

18. California Privacy Rights (CCPA / CPRA)

19. European Privacy Rights (GDPR / UK GDPR)

20. Contact Information and Data Controller Details

1. DEFINITIONS AND INTERPRETATION

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

2. INFORMATION WE COLLECT

2.1 Information You Provide to Us

We collect information that you voluntarily provide when you create an account, use the Application, or communicate with us, including:

2.1.1 Account Registration Information

2.1.2 Payment and Financial Information

The Application offers a free tier as well as paid plans and subscriptions. When you upgrade to a paid plan, payment processing is handled by our third-party payment processor (such as Stripe, Inc.). We do not store full credit card numbers. We may retain:

2.1.3 Meta Account and Advertising Data

When you connect your Meta account(s) to the Application, we collect and process the following data obtained through the Meta API with your explicit authorization:

2.1.4 Creative Content You Upload

2.2 Information We Collect Automatically

When you access or use the Application, we automatically collect certain technical and behavioral information:

2.2.1 Device and Technical Information

2.2.2 Usage and Interaction Data

2.2.3 Log Data

Our servers automatically record log data whenever you use the Application, including:

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

3. HOW WE USE YOUR INFORMATION

3.1 Provision and Operation of the Service

We use your information primarily to operate and improve the Application, including:

3.2 AI and Machine Learning Features

The Application uses artificial intelligence and machine learning to provide its core functionality. Specifically:

3.3 Analytics and Product Improvement

3.4 Communications and Marketing

3.5 Legal and Compliance Purposes

4. META API INTEGRATION AND DATA SHARING

4.1 Scope of Meta API Usage

Our app is built on top of the Meta Marketing API and related Meta developer tools. Our use of Meta APIs is subject to Meta’s Platform Terms (https://developers.facebook.com/terms/), Meta’s Developer Policies, and Meta’s Data Use Policy. We access only the Meta API permissions and data necessary to provide the features of the Application that you actively use.

4.2 Permissions We Request

When you connect your Meta account, you will be prompted to grant us specific Meta permissions. The permissions we may request include:

We will clearly disclose the scope and purpose of each permission at the time of authorization. You may revoke these permissions at any time through your Meta account settings at https://www.facebook.com/settings?tab=business_tools, although doing so will limit or disable certain Application features.

4.3 Restrictions on Meta Platform Data

We adhere strictly to Meta’s Platform Terms and our obligations as a Meta developer. In particular:

4.4 Meta’s Independent Data Processing

Meta processes your data independently of our Application in accordance with its own Privacy Policy. When you use Meta platforms (Facebook, Instagram, Audience Network) in connection with advertising campaigns you create through our Application, Meta’s data collection and processing practices apply to those interactions. We do not control Meta’s data practices and encourage you to review Meta’s Privacy Policy at https://www.facebook.com/privacy/policy/.

4.5 Meta Business Tools

If our Application uses the Meta Pixel, Conversion API, or other Meta Business Tools in our own marketing or analytics, this data is governed by our agreements with Meta and is subject to Meta’s data processing terms. We use these tools only in accordance with applicable law and with appropriate disclosures to affected users.

5. LEGAL BASES FOR PROCESSING (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we are required under the GDPR or UK GDPR to identify the legal basis for each of our processing activities. Our legal bases are:

For Special Categories of Personal Data (Article 9 GDPR), we do not intentionally collect such data. If we become aware that we have collected such data inadvertently, we will delete it promptly unless processing is required or permitted under one of the conditions in Article 9(2).

6. DATA SHARING AND DISCLOSURE

6.1 We Do Not Sell Your Personal Information

We do not sell your personal information to third parties. We do not engage in the sale or sharing of personal information for cross-context behavioral advertising as defined under the CCPA/CPRA, except where you have provided explicit consent.

6.2 Service Providers and Subprocessors

We share personal information with carefully selected third-party service providers who process data on our behalf, under written data processing agreements that require them to protect your data and use it only for specified purposes. These include:

6.3 Meta Platforms, Inc.

We share data with Meta Platforms, Inc. in the course of operating the Meta API integration. This includes transmitting your API access tokens, ad creative assets, campaign configurations, and related data to Meta’s servers as necessary to fulfill your requests to create and manage advertising campaigns. Meta’s processing of this data is governed by Meta’s own policies.

6.4 Legal Disclosures

We may disclose your personal information if required to do so by law or in response to:

6.5 Business Transfers

In the event of a merger, acquisition, reorganization, asset sale, bankruptcy, or similar transaction, your personal information may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice within the Application prior to your data being transferred and becoming subject to a different privacy policy.

6.6 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for industry research, benchmarking, and other purposes. This data is not considered personal information.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 Types of Cookies We Use

We use cookies and similar tracking technologies (web beacons, pixel tags, local storage objects) to operate and improve the Application. Specifically:

7.2 Managing Cookies

You can control cookies through:

For users in the EEA, UK, and certain US states, we will obtain your consent before placing non-essential cookies.

8. DATA RETENTION

8.1 Retention Periods

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, or to resolve disputes. Our general retention guidelines are:

8.2 Account Deletion

You may request deletion of your account at any time by accessing Account Settings > Delete Account, or by contacting us at [email protected]. Upon deletion, we will initiate the data deletion process described above. Some data may be retained for legal or legitimate business reasons as described in Section 8.1.

9. DATA SECURITY

9.1 Technical and Organizational Measures

We implement industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

9.2 Limitations

No method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

10. YOUR PRIVACY RIGHTS

10.1 Universal Rights

Regardless of your location, you have the following rights with respect to your personal information:

10.2 Additional Rights Under GDPR and UK GDPR

If you are in the EEA or UK, you additionally have the right to:

10.3 Exercising Your Rights

To exercise any of your rights, please contact us at [email protected] or through the privacy request portal in your Account Settings. We will respond to your request within 30 days (or within the timeframe required by applicable law). We may require you to verify your identity before processing your request. We will not discriminate against you for exercising your privacy rights.

11. CHILDREN’S PRIVACY

The Application is not intended for, and we do not knowingly collect personal information from, children under the age of 16 (or under 13 in jurisdictions where the minimum age is 13). If you are under the applicable age in your jurisdiction, please do not use the Application or provide any personal information to us.

If we become aware that we have collected personal information from a child without appropriate parental consent, we will take steps to delete such information as promptly as possible. If you believe that we may have collected information from a child, please contact us immediately at [email protected].

12. INTERNATIONAL DATA TRANSFERS

We are headquartered in the USA and our infrastructure may be located in various countries. If you are accessing the Application from outside the USA, your personal information may be transferred to, stored, and processed in countries with different data protection laws than your own.

For transfers of personal data from the EEA, UK, or Switzerland to countries not recognized as providing an adequate level of data protection, we rely on appropriate safeguards, including:

By using the Application, you understand that your information may be transferred to our facilities and to third parties outside your country of residence. We will ensure appropriate safeguards are in place for such transfers.

13. THIRD-PARTY SERVICES AND LINKS

The Application may contain links to third-party websites, services, or integrations (including Meta’s platforms). This Privacy Policy does not apply to the practices of third parties that we do not own or control. We encourage you to review the privacy policies of any third-party services you interact with through or in connection with the Application. We are not responsible for the privacy practices of such third parties.

Certain features of the Application may rely on third-party APIs, embeds, or widgets. When you interact with these features, your data may be transmitted to those third parties. Notable third-party integrations include:

14. AI-GENERATED CONTENT AND DATA

The Application uses artificial intelligence models to generate advertising creative content. Please be aware of the following:

14.1 Input Data

Text, images, and other content you provide as input to AI generation features may be processed by our AI models and/or transmitted to third-party AI service providers. We implement data minimization practices and select providers with strong data protection commitments.

14.2 AI Output

AI-generated content is produced automatically and may not always be accurate, appropriate, or suitable for your intended purpose. You are responsible for reviewing AI-generated creatives before publishing them. We make no warranties regarding the accuracy or fitness for purpose of AI-generated content.

14.3 Model Training

We may use anonymized and aggregated usage data to improve our AI models. We will NOT use your personally identifiable information or your specific creative assets to train publicly shared models without your explicit opt-in consent. You may opt out of any AI model training involving your data by contacting us at [email protected].

15. ADVERTISING AND MARKETING

We may use your contact information and usage data to send you information about our products, features, and promotions. We will only send you marketing communications where we have a lawful basis for doing so (e.g., your consent, or our legitimate interest where permitted by law).

You can opt out of marketing communications at any time by:

Please note that even if you opt out of marketing communications, we will continue to send you essential transactional communications related to your account and the Service.

16. BUSINESS TRANSFERS

If the Company is involved in a merger, acquisition, sale of assets, financing, reorganization, or insolvency proceeding, your personal information may be transferred as part of such transaction. We will provide notice to you through the Application and/or by email before your personal information becomes subject to a different privacy policy. The acquiring entity will be required to maintain the same or equivalent protections for your personal information.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

For material changes that significantly affect your rights, we may seek your renewed consent where required by law. Your continued use of the Application after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically.

18. CALIFORNIA PRIVACY RIGHTS (CCPA / CPRA)

This section applies to California residents and supplements the rest of this Privacy Policy.

18.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information from California residents:

18.2 Your California Rights

California residents have the following rights:

18.3 Submitting Requests

California residents may submit privacy requests by emailing [email protected] or using the Request Portal in Account Settings. We will verify your identity before processing requests. Authorized agents may submit requests on your behalf with written authorization.

19. EUROPEAN PRIVACY RIGHTS (GDPR / UK GDPR)

This section applies to individuals in the European Economic Area (EEA) and the United Kingdom and supplements the rest of this Privacy Policy.

19.1 Data Controller

IBD Ventures LLC is the Data Controller for personal data processed through the Application. Our contact details are provided in Section 20.

19.2 Privacy Contact

We have not appointed a Data Protection Officer (DPO), as we are not required to do so under Article 37 GDPR. All data protection and privacy-related inquiries should be directed to our Privacy Team at [email protected]. We are committed to responding to all requests within the timeframes required by applicable law.

19.3 Supervisory Authority

You have the right to lodge a complaint with your local data protection supervisory authority. A list of EU supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en. UK residents may contact the Information Commissioner’s Office (ICO) at: https://ico.org.uk.

19.4 Automated Decision-Making

We may use automated processing to generate ad creative recommendations and to detect fraud. Where such automated processing has a significant legal or similarly significant effect on you, you have the right to request human review, contest the decision, and obtain an explanation. Please contact us at [email protected] to exercise this right.

20. CONTACT INFORMATION AND DATA CONTROLLER DETAILS

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the information below:

IBD Ventures LLC

Attn: Privacy / Data Protection Team

Address: 30 N Gould St Ste R, Sheridan, Wyoming 82801, United States

Email: [email protected]

Website: https://ibd-ventures.com

For urgent matters involving potential security incidents or data breaches, please use the subject line ‘URGENT: Data Security Incident’ when contacting us by email.

We are committed to resolving privacy concerns promptly. If you are not satisfied with our response, you have the right to lodge a complaint with the appropriate supervisory authority as described in Section 19.3.

This Privacy Policy was last updated on April 16, 2026 and is effective as of that date.

© 2026 IBD Ventures LLC. All rights reserved.