Privacy Policy

a) The Company (data controller)

Alvin AI Studio LLC, 447 Broadway, 2nd Floor Suite 3007, New York, NY 10013, USA, is the controller of the personal data described in this Policy and is the Seller and Merchant of Record for the Service. All privacy requests should be directed to the Company using the contact details in Section 14.

b) Otto Apps (technical service provider / processor)

Otto Apps Yazılım Uygulama Bilgi Teknoloji Reklamcılık Danışmanlık Sanayi ve Ticaret A.Ş. ("Otto Apps"), İçerenköy Mah. Topçu İbrahim Sk. Quick Tower No:8-10D, Ataşehir / İstanbul, Turkey, develops and operates the software infrastructure of the Service and produces in-app content.

Otto Apps processes personal data only on the Company's behalf, on the Company's instructions, and under a written data processing agreement. Otto Apps is not the controller of your data, is not the Merchant of Record, does not sell subscriptions to you, and does not receive or store your payment card details. Otto Apps does not use your personal data for its own purposes.

c) No affiliation with Instagram or Meta

Buzzfy is an independent service and is not affiliated with, endorsed by, or sponsored by Meta Platforms, Inc. or Instagram.

a) Account Information

When you sign up, we collect your name, email address, and password (hashed). If you sign up via an invite code, we record that code.

b) Instagram Account Data

When you connect your Instagram account, we collect and process the following via the Instagram Graph API:

• Your Instagram account ID, username, and profile information
• Your existing Reels (video files, metadata, view counts)
• Performance metrics via the Instagram Insights API: reach, views, average watch time, likes, comments, shares, and saves
• Audio data from your Reels (for transcription and variant generation)

c) Payment Information

Payments are collected by the Company as Merchant of Record and processed via Stripe as its payment processor. We do not store your credit card number or payment details on our servers, and Otto Apps has no access to payment card data. Stripe's privacy policy applies to all payment data: stripe.com/privacy.

d) Usage Data

We collect information about how you interact with the Service, including pages visited, features used, and actions taken (via Mixpanel analytics).

e) Communications

If you contact us for support or respond to our emails, we retain that correspondence.

• To provide the Service — analyzing your Reels, generating variants, publishing Trial Reels on your behalf, and tracking their performance
• To process payments and manage your subscription
• To send transactional emails (account confirmations, billing receipts, trial expiration notices)
• To send product updates and marketing emails (you may opt out at any time)
• To improve the Service and develop new features
• To train and improve our AI models using aggregated, anonymized performance data from A/B test results across users
• To comply with legal obligations

The technical operations behind these purposes are carried out through the infrastructure operated by Otto Apps on the Company's behalf, as described in Section 1(b).

We access your Instagram account solely to provide the Service. Specifically:

• We read your existing Reels to analyze and generate variants
• We publish content (Trial Reels) to your account on your behalf, only as directed by you
• We read Insights data to measure the performance of Trial Reels
• We do not sell your Instagram data to third parties
• We do not use your Instagram data for advertising purposes unrelated to the Service
• Instagram data is retained only as long as necessary to provide the Service or as required by law

Instagram data may be processed by Otto Apps strictly as the Company's service provider, solely to operate the Service on the Company's behalf and under contractual restrictions no less protective than those set out in this Policy. Our use of Instagram data, including the engagement of service providers, complies with the Meta Platform Terms and Meta Platform Policy.

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

• Technical service provider — Otto Apps, which operates the software infrastructure of the Service on the Company's behalf, as described in Section 1(b). Otto Apps processes data only on the Company's instructions.
• Service providers — Stripe (payments), Mixpanel (analytics), cloud hosting providers (e.g., AWS/S3 for video storage), and email delivery services. These providers access data only as needed to perform services on our behalf.
• AI/ML providers — We use Google Gemini and OpenAI Whisper APIs to analyze video and audio content. Data sent to these services is subject to their respective privacy policies.
• Legal requirements — We may disclose information if required by law, regulation, or valid legal process.
• Business transfers — In the event of a merger, acquisition, or sale of assets, your data may be transferred. We will notify you before your data is subject to a different privacy policy.

The Service is operated from the United States, and the technical infrastructure is operated by Otto Apps from Türkiye (Turkey). Depending on your location, your personal data may therefore be transferred to, stored in, and processed in the United States, Türkiye, and other countries where our service providers operate. These countries may have data protection laws that differ from those in your country of residence.

Where such a transfer is subject to the GDPR, the UK GDPR, or comparable law, we rely on appropriate safeguards for the transfer — including the European Commission's Standard Contractual Clauses (and the UK Addendum where applicable) concluded with Otto Apps and our other processors, together with supplementary technical and organizational measures. You may request a copy of the relevant safeguards by contacting us at bugra@buzzfy.co.

We retain your account data for as long as your account is active. Video files and analysis data are retained to power the Service and, after account deletion, for up to 30 days before permanent deletion. Payment records are retained as required by applicable law. Otto Apps retains data only for as long as the Company instructs, and deletes or returns it on termination of its agreement with the Company.

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete your personal data
• Object to or restrict processing of your data
• Withdraw consent at any time (including revoking Instagram access)
• Request data portability

To exercise these rights, contact us at bugra@buzzfy.co. Requests should be addressed to the Company as controller, not to Otto Apps; the Company will instruct Otto Apps and any other processor to give effect to your request.

You may disconnect your Instagram account from Buzzfy at any time via your account settings or directly through Instagram's app settings. Upon disconnection, we will stop accessing your Instagram data and will delete stored tokens.

We use cookies and similar technologies to maintain your session, remember your preferences, and analyze usage. You may disable cookies in your browser settings, though some features may not function properly as a result.

The Service is not directed to individuals under the age of 13, and our Terms of Service require you to be at least 18 years old to use the Service. 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.

We and Otto Apps implement industry-standard security measures including encrypted data transmission (HTTPS), hashed passwords, and access controls. However, no method of transmission over the internet is 100% secure.

We may update this Privacy Policy from time to time. We will notify you of material changes by email or via a prominent notice on the Service. Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy.

If you have questions about this Privacy Policy, or wish to exercise any of the rights in Section 8, please contact:

Data Controller / Seller / Merchant of Record

Alvin AI Studio LLC
Operating the Buzzfy brand
447 Broadway, 2nd Floor Suite 3007, New York, NY 10013, USA
Email: bugra@buzzfy.co
Website: buzzfy.co

Technical Provider / Processor

Otto Apps Yazılım Uygulama Bilgi Teknoloji Reklamcılık Danışmanlık Sanayi ve Ticaret A.Ş.
İçerenköy Mah. Topçu İbrahim Sk. Quick Tower No:8-10D, Ataşehir / İstanbul, Turkey