Legal
Privacy Policy
Effective date: September 25, 2025
This Privacy Policy explains how Illuminate Payment Pty Ltd (“Illuminate,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you use our websites and services.
1) Data controller & contact
- Controller: Illuminate Payment Pty Ltd, [REGISTERED OFFICE ADDRESS], United Kingdom
- Email: team@illuminate.money
2) Information we collect
- Account data (name, email, role).
- Payment & payout data via Stripe (card tokens, bank info, identity/KYC). We do not store full card numbers.
- Campaign & stream data (uploaded assets, titles/tags, targeting, seconds displayed, Boost, logs/metrics).
- Safety & context signals (derived audio/metadata signals for brand safety; we minimize raw audio retention).
- Device & usage (IP, device, browser, pages, cookies/SDK events).
- Support (messages, tickets, attachments).
3) How we use information
- Provide and improve the service (CPS billing, Boost scheduling, reporting).
- Run safety features (AudioGuard) and prevent abuse/fraud.
- Process payments/payouts with Stripe; issue invoices/receipts.
- Communicate with you (service notices, support, product updates) with opt‑outs where applicable.
- Comply with legal obligations and enforce our Terms.
4) Lawful bases (UK GDPR/GDPR)
- Contract (to provide the service you request).
- Legitimate interests (security, fraud prevention, reliability, product analytics, and model training/service improvement described below—subject to your right to object).
- Legal obligation (tax, accounting, KYC where applicable).
- Consent (only where we specifically ask, e.g., certain cookies or marketing).
5) AI training & service improvement
To improve our AI systems that power campaign generation, placement predictions, and brand‑safety features, we may use uploaded creative assets and related metadata to train, fine‑tune, evaluate, and improve our models and safety systems. Examples include images/video/text you upload, titles/tags, derived features, and anonymized performance metrics.
- We do not use payment or payout data, your personal contact details, or support conversations to train models.
- Legal basis: legitimate interests (Art. 6(1)(f)), balanced against your rights. You may object at any time (see below).
- How to object: email team@illuminate.money. We will stop using your assets in future training and remove them from active training sets where feasible. Previously trained model weights may not be technically reversible.
- Vendors: We may use trusted compute vendors as sub‑processors under contracts limiting processing to our instructions.
8) Data retention
We retain personal data only as long as necessary for the purposes above. Account/billing records follow statutory periods. Safety logs are kept for a limited time. For AI training, we attempt to minimize raw assets and maintain curated training sets; upon objection we remove assets from active training sets where feasible and cease further use for training.
9) Security
We use administrative, technical, and physical safeguards (encryption in transit, access controls, segregation of payment data via Stripe). No method is 100% secure.
10) International data transfers
Where required, we use appropriate safeguards (e.g., EU SCCs and the UK Addendum/IDTA) for cross‑border transfers.
11) Your rights
- UK GDPR/GDPR: access, rectification, erasure, restriction, portability, and objection (including to AI training under legitimate interests) and to direct marketing.
- California (CPRA): right to know, delete, correct, and opt‑out of certain sharing. We do not sell personal information.
- To exercise rights, email team@illuminate.money. We may verify your request.
12) Children
Our service is not directed to children under 13; accounts are limited to users 18+ (or age of majority in your region).
13) Changes to this Policy
We may update this Policy; material changes will be posted with a new effective date. Continued use after updates means acceptance.
14) Contact us
Questions? Email team@illuminate.money or write to us at [REGISTERED OFFICE ADDRESS], United Kingdom.