Legal

Privacy Policy

Effective date: June 4, 2026

Your privacy matters to us. This Privacy Policy explains how UGC100 ("UGC100", "we", "us") collects, uses, and protects information about you when you use ugc100.com, app.ugc100.com, and related services (the "Service"). The Service is operated by Travly Inc., 1 Lyford Cay, 7776, The Bahamas, which is the entity responsible for your personal data (the data controller). For any data protection question, reach us at contact@ugc100.com.

1. Information we collect

• Account information such as your name, email address, and login credentials, used for authentication and to provide the Service.
• Content and prompts you upload or create on the platform, and the content generated for you.
• Subscription and payment information for account management, processed by our payment providers. We never see or store your full card number.
• Usage data such as device and browser type, IP address, pages visited, and actions taken, used to keep the Service secure and improve it.
• Messages you send us when you contact support.

2. Information we obtain from other sources

Some personal data reaches us from sources other than you directly:

• From authentication providers, when you sign in with a third-party login. We receive your name and email address so we can create and secure your account.
• From third-party social-data providers, when a social account is connected to a workspace. For each connected account we collect public profile and engagement data, namely the display name, profile picture, bio, follower and following counts, and view and performance metrics. This data is sourced from publicly accessible social platforms through our data provider.

We process this data on the basis of our legitimate interests in operating the analytics features of the Service. Where we rely on legitimate interests, you have the right to object to that processing at any time on grounds relating to your situation. Contact contact@ugc100.com.

3. How we use your information

• To provide, operate, and maintain the Service and your account.
• To process payments and manage your subscription.
• To send transactional emails such as receipts and notifications.
• To keep the Service secure and prevent fraud and abuse.
• To diagnose problems and improve the product.
• To meet legal, tax, and accounting obligations.

4. Why we are allowed to use your information

Where EU and UK data protection law (GDPR and UK GDPR) applies, we rely on the following legal bases, matched to the purposes above:

• Performance of our contract with you, to provide the Service and to handle billing.
• Legal obligation, to meet tax, accounting, and legal record-keeping requirements.
• Our legitimate interests, namely keeping the Service secure, preventing fraud and abuse, improving the product, and providing analytics on connected social accounts. Where we rely on legitimate interests, you have the right to object to that processing at any time on grounds relating to your situation. Contact contact@ugc100.com.
• Consent, where we ask for it. You can withdraw your consent at any time, and that does not affect processing we carried out before you withdrew it.

5. AI-generated content

When you generate content, your prompts and any reference media are processed by third-party AI services to produce your output. We send only what is needed to fulfill your request. We do not use your prompts, uploads, or generated content to train our own AI models.

6. Automated decisions

We do not make decisions about you based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

7. Cookies

We use strictly necessary cookies and similar technologies, the ones required to sign you in, keep your session secure, and remember your basic preferences such as language. These are essential to deliver the Service you ask for. If you arrive through a partner link, we also set a first-party referral cookie for up to 30 days so we can credit the partner who referred you; it tracks nothing beyond that referral. We do not set analytics or advertising cookies and we do not run third-party advertising trackers. If we ever introduce non-essential cookies, we will set them only after you give consent, and you will be able to withdraw that consent at any time. You can block or delete cookies in your browser, but parts of the Service may then stop working.

8. Data storage and security

Your data and generated content are stored on secure, professionally managed cloud systems. Traffic is encrypted in transit and access is strictly controlled, so your information is protected against unauthorized access, alteration, or destruction.

9. Data sharing

We never sell or share your personal information. Data leaves our systems only:

• With categories of service providers we use to operate the platform, each only as needed to provide the Service: cloud hosting and infrastructure, payment processing, email delivery, AI model providers that run generations, and analytics and error monitoring.
• Within your workspace, with the team members you invite.
• When required by law or to respond to a legal process.
• To protect the rights, property, or safety of UGC100, our users, or the public.
• As part of a merger, acquisition, or sale of assets, in which case this policy continues to apply.

10. International data transfers

Travly Inc. is established in The Bahamas. The Bahamas is a third country for which the European Commission has not issued an adequacy decision. This means that when you use the Service from the EEA or the UK, your personal data is transferred to a third country without an adequacy decision, both to us as the controller and to our service providers who process data in other countries.

To protect those transfers, we rely on the European Commission's Standard Contractual Clauses (the controller-to-controller and controller-to-processor modules, as applicable) and, for the UK, the UK Information Commissioner's International Data Transfer Addendum to those clauses. Together with supplementary measures such as encryption in transit and strict access controls, these provide the appropriate safeguards required by law.

To request a copy of the relevant Standard Contractual Clauses and related safeguards, email contact@ugc100.com.

11. Data retention

We keep your information while your account is active. After account deletion we remove or anonymize your data within 90 days. We retain billing, tax, and accounting records for 7 years to comply with applicable financial record-keeping law. Where a different statutory retention period applies to specific records, we keep those records for as long as that law requires and no longer.

Encrypted backups are overwritten on a rolling 35-day cycle, after which data you have deleted is purged from those backups.

12. Data breaches

If a breach affects your personal data, we will notify affected users and the competent authorities as required by law.

13. Your rights

You have the following rights over your personal data:

• Access to the personal data we hold about you.
• Rectification of inaccurate or incomplete data.
• Erasure of your data.
• Restriction of processing.
• Data portability.
• Objection to processing. Where we rely on legitimate interests, you have the right to object at any time on grounds relating to your situation, and we will stop unless we have compelling legitimate grounds that override your interests.
• Withdrawal of consent at any time, without affecting processing carried out before you withdrew it.

To exercise these rights, contact us at contact@ugc100.com. We will process your request in accordance with EU and UK data protection law (GDPR and UK GDPR) and other applicable data protection laws.

If you are in the EEA or the UK, you also have the right to lodge a complaint with your local data protection supervisory authority (in the UK, the ICO).

California residents

If you live in California, you have the rights to know and access your personal information, to correct it, to delete it, to opt out of the sale or sharing of personal information, to limit the use of sensitive personal information, and not to be discriminated against for exercising your rights. We do not sell or share personal information as those terms are defined under California law. To make a request, email contact@ugc100.com. We will verify your identity before we fulfill it.

14. Children

The Service is not directed at children. You must be at least 18 years old to use it. We do not knowingly collect data from anyone under 18.

15. Changes to this policy

We may update this policy from time to time. If we make material changes we will notify you through the Service or by email. Continued use of the Service after changes take effect means you accept the updated policy.

16. Contact

Questions about this policy or your data: contact@ugc100.com