Privacy Policy — BasedUGC

At General Automation Labs Pty Ltd ("we", "us", or "our"), protecting your personal information is a priority. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use the BasedUGC platform ("Platform") and related services.

We are committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"). This policy also reflects our obligations under other applicable privacy laws.

1. Who We Are

General Automation Labs Pty Ltd (ACN: [to be inserted])
20–40 Meagher St, Chippendale NSW 2008, Australia
Email: daniel@sellable.pro

2. What Personal Information We Collect

"Personal information" means information or opinions about an identified individual or an individual who is reasonably identifiable. We may collect:

Identity data: full name, email address.
Professional data: company name, role, company size, website, logo.
Account & order data: subscription plan, usage history, invoice records.
Authentication data: login logs, IP address, session tokens. If you sign in via Google or another third-party provider, we receive your name and email from that provider. We do not collect your third-party password.
Usage & technical data: pages visited, features used, device type, browser, operating system, timestamps.
Payment data: billing address, last-four card digits, payment status. Full card details are processed by Stripe and not stored by us.
Communications: support messages, feedback, and any information you send us.
AI-generated content inputs: scripts, prompts, uploaded videos, and product images you provide to generate content on the Platform ("Client Content").

We tell you at collection whether information is mandatory or optional.

3. How We Collect Personal Information

We collect personal information:

Directly from you when you register, subscribe, or contact us.
Automatically via cookies and similar technologies as you use the Platform.
From third-party authentication providers (e.g. Google) when you choose to sign in through them.
From payment processors (e.g. Stripe) in connection with billing.

4. Why We Collect & Use Personal Information

We use personal information for the following purposes:

Providing the Services: operating your account, generating AI videos, processing payments, and delivering features you request.
Improving our Services: analysing usage patterns, fixing bugs, training and improving our AI models (using Client Content in accordance with our Terms).
Communications: sending transactional emails (receipts, subscription alerts), product updates, and — where you have opted in — marketing communications.
Security & fraud prevention: monitoring for suspicious activity, enforcing our Terms, and protecting our users.
Legal compliance: meeting our obligations under applicable Australian and international law.
Customer support: responding to your enquiries and resolving disputes.

5. Legal Bases for Processing

Under Australian privacy law, we rely on the following grounds to handle your personal information:

Performance of a contract — to provide the Services you have subscribed to.
Legitimate interests — to improve our Services, ensure security, and grow our business, balanced against your privacy interests.
Legal obligation — to comply with tax, financial, or other legal requirements.
Consent — for marketing communications and analytics cookies, where required.

6. Data Retention

We retain personal information for as long as necessary for the purposes described:

Account data: retained for the life of your account, then deleted within 90 days of closure (or up to 7 years where required for tax/legal records).
Transaction & invoice records: 7 years from the date of the transaction (to comply with Australian tax law).
Access logs: 90 days.
Marketing data: until you opt out or 3 years after your last interaction, whichever is sooner.
Support communications: 3 years from the date of the interaction.
Generated video content and Client Content: retained while your account is active. You may delete content at any time from your Workspace. After account closure, content is deleted within 90 days.

7. Who We Share Personal Information With

We do not sell your personal information. We may share it with:

Service providers (processors): cloud hosting providers, AI inference providers, payment processors (Stripe), email delivery providers, analytics tools, and customer support software — all bound by data processing agreements.
Professional advisers: accountants, lawyers, and auditors under confidentiality obligations.
Regulators & authorities: where required by law, court order, or to protect our legal rights.
Business transfers: if we merge, acquire, or sell a business, personal information may be transferred as part of that transaction. We will notify you beforehand.

8. International Data Transfers

Our Platform and services are hosted on cloud infrastructure that may be located outside Australia, including in the United States and European Union. Where we transfer personal information overseas, we take reasonable steps to ensure the recipient is subject to comparable privacy protections, such as contractual clauses, adequacy decisions, or other appropriate safeguards consistent with APP 8.

9. Cookies & Tracking

We use cookies and similar technologies for authentication, security, analytics, and Platform functionality. You can control cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality.

We use analytics tools (such as Plausible or similar privacy-respecting analytics) to understand Platform usage in aggregate. We do not use advertising trackers or sell your browsing data.

10. AI & Model Training

Client Content (scripts, prompts, uploaded videos, images) may be used to improve and train our AI models, in accordance with our Terms & Conditions. We do not use Client Content to train general-purpose third-party AI models or sell data for AI training purposes.

AI-generated Videos and outputs are not used to identify or profile individuals unless you explicitly provide that information.

11. Security

We implement industry-standard technical and organisational security measures, including encryption in transit (TLS) and at rest, access controls, and regular security reviews. No system is perfectly secure. In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner ("OAIC") in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

12. Your Privacy Rights

Under Australian privacy law and applicable regulations, you have the right to:

Access the personal information we hold about you (APP 12).
Correct inaccurate or outdated personal information (APP 13).
Request deletion of your personal information, subject to our legal obligations.
Opt out of marketing communications at any time using the unsubscribe link in any email or by contacting us.
Withdraw consent for consent-based processing (e.g. analytics cookies).
Complain to the OAIC if you believe we have mishandled your personal information.

To exercise any of these rights, contact us at daniel@sellable.pro. We will respond within 30 days. We may ask you to verify your identity before processing certain requests.

13. Children's Privacy

The Platform is not directed at individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it promptly.

14. Third-Party Links

The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing personal information.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated policy on the Platform and, for material changes, notify you by email or in-Platform notification. The effective date at the top of this page reflects the latest version.

16. Complaints

If you have a concern about how we handle your personal information, please contact us first at daniel@sellable.pro. We will investigate and respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Website: oaic.gov.au
Phone: 1300 363 992

17. Contact

General Automation Labs Pty Ltd
20–40 Meagher St, Chippendale NSW 2008, Australia
Email: daniel@sellable.pro

This policy is governed by the laws of New South Wales, Australia.