Privacy Policy

GameFrame Limited, a company registered in England and Wales (company number 16139017), whose registered office is at 12 Highgate Road, London, NW5 1AS, trading as Recap ("Recap", "we", "us", or "our"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your information when you use the Recap mobile application and related services (the "Service").

Recap is the data controller for your personal data.

1. Information We Collect

1.1 Information You Provide

• Account Information: Name and email address, collected during account registration via Social Login (currently Google and Apple sign-in). Date of birth may be provided optionally in account settings.
• Payment Information: Subscription and transaction data processed through the Apple App Store. We do not directly collect or store your payment card details.
• Preferences: Settings and choices you make within the app, such as music preferences, highlight styles, and sharing options.
• Communications: Information you provide when contacting support or providing feedback.
• User Content: Videos and footage captured directly through the Service's in-app camera, and associated metadata.
• Your Responsibility for Information You Provide: You are responsible for ensuring you have the appropriate consents from individuals appearing in your footage before uploading it to the Service (see our Terms of Service, Section 5). If you upload content that features minors (anyone under 18), you are solely responsible for obtaining verifiable consent from their parent or legal guardian.

1.2 Information Collected Automatically

• Device Information: Device type, operating system, unique device identifiers, and app version.
• Usage Data: How you interact with the Service, including features used, session duration, and in-app actions.
• Location Data: Approximate location data collected via device settings or Maps API integration for weather overlays and location-based features. We do not track precise GPS location on an ongoing basis. Location collection is optional and can be disabled in the app settings.
• AI Processing Data: Technical data generated during AI analysis and processing of your uploaded footage, including frame analysis metadata and content classification data.

1.3 Information from Third Parties

• Social Login Providers: Basic profile information from Google or Apple when you create an account.
• AI Service Providers: Technical processing data returned by our AI partners (such as Google Gemini, Eleven Labs) during content generation.

1.4 AI Generated Content

Certain AI image generation features within the Service may process the visual characteristics of individuals captured in your footage in order to generate additional content or AI-generated elements (such as commentary, graphics, and effects) based on your footage, such as the creation of highlight videos or stylised poster images as part of a highlight. Such data processing is not used for identification, profiling, or any purpose beyond generating the highlight. We do not use facial recognition technology for the purposes of uniquely identifying individuals. We do not build biometric profiles or extract or store biometric templates from your footage.

Where technically feasible, AI-generated elements within your highlights (such as commentary, graphics, and poster images) are identified as AI-generated content within the Service.

2. How We Use Your Information

• To provide and operate the Service, including processing your footage with AI, generating highlight videos, adding effects and music, and enabling sharing to third-party platforms.
• To improve and develop the Service, including analysing usage patterns and developing new features. We only train or improve our AI models using anonymised, aggregated, or synthetic data. We do not use identifiable User Content for training generative AI models without separate, explicit user consent.
• To personalise your experience, including recommending highlight styles, music, and effects based on your preferences and usage history.
• To communicate with you, including sending service updates, responding to support enquiries, and (with your prior opt-in consent) promotional communications. Promotional communications are disabled by default for users aged 13 to 17. You may opt out of promotional communications at any time.
• To ensure security and prevent fraud, including monitoring for suspicious activity and protecting the integrity of the Service.
• To moderate content, including through automated scanning of footage using automated tools, to identify and prevent the publication of content that violates our Community Guidelines or applicable law.
• To comply with legal obligations, including responding to lawful requests from authorities and meeting our regulatory duties.
• To perform analytics, to produce anonymised data derived from the Service to generate insights (such as sports trends or usage statistics).

3. Legal Basis for Processing

We rely on the following legal bases for processing your personal data:

• Contract: Processing necessary to provide you with the Service under our Terms of Service.
• Legitimate Interests: Processing for purposes such as improving the Service, ensuring security, and conducting analytics, where these interests are not overridden by your rights and freedoms.
• Consent: Where we process data based on your consent (for example, promotional communications or optional features), you may withdraw your consent at any time.
• Legal Obligation: Where processing is necessary to comply with a legal requirement.

4. How We Share Your Information

4.1 Third-Party AI and Service Providers

We share specific data with named third-party providers to deliver the core functionality of the Service.

• Google Gemini (Vertex AI): Uploaded video footage (via GCS URI), event metadata, approximate location, venue frames. Purpose: Highlight detection, commentary generation, poster frame selection, aerial imagery.
• Google Veo (Vertex AI): AI-enhanced satellite images, text prompts. Purpose: Aerial intro sequences and AI pundit presenter video generation.
• ElevenLabs: Text scripts only (no personal data, no video). Purpose: Text-to-speech commentary synthesis.
• Google Maps Platform: Approximate latitude and longitude. Purpose: Satellite imagery fetch and reverse geocoding.
• Google Weather API: Approximate latitude, longitude, and event timestamp. Purpose: Weather conditions for AI-generated commentary.
• Firebase Cloud Messaging: Device push notification token. Purpose: Processing updates and service notifications.
• Google Cloud Platform: Raw footage, processed outputs, account data. Purpose: Cloud hosting, storage, and compute infrastructure.
• Temporal Cloud: Event metadata and processing instructions (no raw footage). Purpose: Orchestrates video processing task sequences.

All service providers are bound by data processing agreements that require them to process your data only as instructed and to maintain appropriate security measures.

4.2 Sharing at Your Direction

When you choose to share highlights to external platforms (such as YouTube, TikTok, Instagram, or Facebook), your content is shared in accordance with the terms and privacy policies of those platforms.

4.3 Legal and Safety Reasons

We may disclose your information where required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect the rights, property, or safety of Recap, our users, or the public.

4.4 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and of any choices you may have regarding your information.

4.5 No Sale of Personal Data

We do not sell your personal data to third parties.

5. International Data Transfers

Your data may be processed outside the United Kingdom or European Economic Area, including in the United States, where some of our AI service providers are based.

We can deploy and control the regional location of AI model processing, and may route data through EU-based infrastructure for EU users and UK-based infrastructure for UK users where technically feasible.

Where personal data is transferred outside the UK or EEA, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (for UK-to-third-country transfers) and/or Standard Contractual Clauses approved by the European Commission (for EEA-to-third-country transfers)
• Adequacy regulations where applicable, including the EU/UK/Swiss Data Privacy Framework for transfers to recipients in the United States that are certified under that framework
• Other transfer mechanisms permitted under applicable privacy laws

6. Data Retention

• Account Data: Retained for as long as your account is active. If you delete your account, we will delete or anonymise your data within 30 days, except where retention is required for legal or compliance purposes.
• User Content: Retained until you delete it or your account is terminated. Following deletion, we will permanently delete or irreversibly anonymise the data within 30 days. Limited backup copies may be retained for no longer than 90 days. Where a specific statutory obligation requires longer retention of a particular item, only that item will be retained for the period strictly required.
• Usage and Analytics Data: Retained in anonymised or aggregated form and may be kept indefinitely for analytical purposes.
• Legal and Compliance Data: Retained as required by law.

7. Data Security

We implement industry-standard technical and organisational measures to protect your data, including encryption in transit and at rest, access controls, and regular security assessments.

However, no method of electronic transmission or storage is completely secure. Whilst we strive to protect your personal data, we cannot guarantee its absolute security.

8. Children

8.1 Users Under 13

The Service is not intended to be accessed by children under 13. We do not knowingly allow children under 13 to create accounts. If we become aware that a child under 13 has created an account, we will take steps to delete that account and its associated data promptly.

8.2 Users Aged 13 to 17

The Service includes a Teen Mode feature that, if available, allows a parent or guardian to set up an account to be accessed by children between 13-17. For these users:

• All accounts default to Private profile and Private video visibility.
• A parent or guardian may lock settings with a PIN.
• We do not use personal data from users in this age group for marketing, profiling, or behavioural advertising purposes. Promotional communications are disabled by default.

9. Your Rights

You may have the following rights in relation to your personal data under applicable privacy laws:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete data.
• Right to Erasure: You may request deletion of your personal data in certain circumstances.
• Right to Restrict Processing: You may request that we limit how we use your data.
• Right to Data Portability: You may request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at legal@recap.mobi or use the relevant options in the app settings. Parents or legal guardians may request the review or removal of content featuring their child by contacting us at legal@recap.mobi. We will respond to your request within one month.

If you are not satisfied with our response, you may have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or your local data protection authority or regulator.

10. Third-Party Links and Services

The Service may contain links to third-party websites, platforms, or services (such as social media platforms for sharing highlights). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before sharing your information.

This Privacy Policy should be read alongside our Terms of Service and Community Guidelines.

11. Contact Us

Email: legal@recap.mobi

Post: GameFrame Limited, 12 Highgate Road, London, NW5 1AS

Website: www.recap.mobi