Privacy Policy

Effective Date: November 30, 2025 | Last Updated: December 5, 2025

1. Introduction

Welcome to our Video Generation Service. This Privacy Policy explains how Turlan Management Limited ("we", "us", "our") collects, uses, stores, and protects your personal data when you use our AI-powered video generation and checkout service located at https://vidforge.ai.

We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) (EU) 2016/679 and all applicable data protection laws in Ireland and the European Union.

2. Data Controller Information

Turlan Management Limited

Business Office: De La Salle House, 2nd Floor, 10 The Parade, Kilkenny, R95 TYP9, Ireland

Registered Office: 6 Fern Road, Sandyford, Dublin, D18 FP98, Ireland

Email: info@turlanmanagement.ie (for all privacy inquiries)

Phone: +353 89 2173810

Jurisdiction: Ireland (European Union)

3. Personal Data We Collect

We collect and process the following categories of personal data:

Data Type	Purpose	Retention Period
Email Address	To deliver download links and order confirmations	7 years (tax compliance)
Payment Information	Process payments via Stripe (we don't store card numbers)	7 years (tax compliance)
IP Address	Fraud prevention, security, and audit trail	7 years (with payment records)
Video Prompts	Generate requested videos	7 years (order records)
Reference Images	Optional images for video generation	3 days (automatic deletion)
Generated Videos	Delivery to customer	30 days (automatic deletion)

Note: We do not collect or store credit card numbers. All payment card data is handled directly by Stripe in accordance with PCI DSS standards.

4. Legal Basis for Processing (GDPR Article 6)

We process your personal data based on the following legal grounds:

Performance of Contract (Art. 6(1)(b)): Processing payment information, email address, prompts, and images to fulfill your video generation order
Legitimate Interests (Art. 6(1)(f)): Collecting IP addresses for fraud prevention, security monitoring, and maintaining service integrity
Legal Obligation (Art. 6(1)(c)): Retaining transaction records for tax and accounting compliance under Irish law

5. How We Use Your Personal Data

We use your personal data exclusively for the following purposes:

Service Delivery: Processing your payment and generating the requested video content
Communication: Sending download links and order confirmations to your email
Content Moderation: Screening prompts for compliance with content policies
Prompt Enhancement: Optionally improving your prompts using AI assistance (requires explicit consent)
Security: Preventing fraud, abuse, and unauthorized access to our services
Legal Compliance: Maintaining records as required by Irish tax law
Service Improvement: Analyzing aggregated, anonymized usage patterns

Important: We do not sell, rent, or share your personal data for marketing purposes.

6. Third-Party Data Processors

We work with carefully selected third-party service providers who process data on our behalf:

Processor	Service	Location	Data Transferred
Stripe	Payment processing	USA (EU-US Data Privacy Framework)	Payment details, email, IP address
AI Video Provider	Video generation	Processing location varies	Prompts, reference images
Supabase	Video storage	EU/Self-hosted	Generated videos
OpenAI	Content moderation	USA	Prompts only (no personal data)
OpenRouter	Prompt enhancement (optional)	USA (Standard Contractual Clauses)	Prompts, language preference, video duration

Prompt Enhancement: When you use the optional "Enhance" feature to improve your video prompt, your prompt text is sent to OpenRouter for AI-assisted enhancement. This feature requires your explicit consent before use. OpenRouter may retain data as necessary for their business operations. For details, see OpenRouter's Privacy Policy.

All third-party processors are contractually bound to protect your data and process it only according to our instructions and applicable data protection laws.

7. International Data Transfers

Some of our third-party processors operate outside the European Economic Area (EEA). When we transfer your data internationally, we ensure appropriate safeguards are in place:

EU-US Data Privacy Framework: For transfers to US-based processors like Stripe
Standard Contractual Clauses: Where applicable, we use EU Commission-approved clauses
Adequacy Decisions: Transfers to countries deemed adequate by the EU Commission

8. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

Right of Access (Art. 15): Request a copy of your personal data we hold
Right to Rectification (Art. 16): Request correction of inaccurate personal data
Right to Erasure (Art. 17): Request deletion of your data ("right to be forgotten")
Right to Restrict Processing (Art. 18): Limit how we use your data
Right to Data Portability (Art. 20): Receive your data in a machine-readable format
Right to Object (Art. 21): Object to processing based on legitimate interests
Right to Withdraw Consent: Where processing is based on consent (not applicable here)
Right to Lodge a Complaint: File a complaint with the Irish Data Protection Commission

To exercise any of these rights, please contact us at info@turlanmanagement.ie. We will respond to your request within one month, as required by GDPR.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit using TLS/SSL protocols
Secure storage with access controls and authentication
Regular security assessments and updates
Limited access to personal data on a need-to-know basis
Automatic deletion of temporary data (images after 3 days, videos after 30 days)
PCI DSS compliant payment processing through Stripe

10. Data Retention Policy

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy:

Data Category	Retention Period	Reason
Payment & Order Records	7 years	Irish tax law compliance
Generated Videos	30 days	Customer download period
Reference Images	3 days	Processing buffer
Download Tokens	30 days	Access control

After the retention period expires, personal data is permanently deleted from our systems.

11. Cookies and Tracking

Our service uses essential cookies required for the checkout process and security. These include:

Session Cookies: To maintain your checkout session
Stripe Cookies: Required for payment processing and fraud prevention
Security Cookies: To protect against CSRF attacks

We do not use marketing, analytics, or third-party tracking cookies.

12. Children's Privacy

Our service is not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately at info@turlanmanagement.ie and we will take appropriate action to delete such information.

13. Data Breach Notification

In the unlikely event of a personal data breach that poses a high risk to your rights and freedoms, we will notify you without undue delay and within 72 hours of becoming aware of the breach, as required by GDPR Article 33-34. We will also notify the Irish Data Protection Commission as required.

14. Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the supervisory authority:

Irish Data Protection Commission

Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Website: www.dataprotection.ie

Phone: +353 (0)761 104 800

Email: info@dataprotection.ie

15. Changes to This Privacy Policy

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

Update the "Last Updated" date at the top of this policy
Notify you via email for significant changes affecting your rights
Obtain fresh consent where required by law

We encourage you to review this policy periodically to stay informed about how we protect your data.

16. Contact Us

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

DATA PROTECTION INQUIRIES

Email: info@turlanmanagement.ie