Privacy Policy

Effective Date: November 4, 2025
Product: Social Pack ("Social Pack", "the Service")
Company: Throttle Labs, Inc. ("Throttle Labs", "we", "us", "our")
Contact: privacy@throttlelabs.ai | 624 E Beale St, Kingman, AZ 86401

1) Overview

Social Pack helps real estate and mortgage professionals create brand-consistent social images from a reference headshot, scenes, and styles. This Privacy Policy explains what we collect, how we use and share it, and your choices. If anything here conflicts with our Terms of Service, this policy controls for privacy matters.

2) Information we collect

A. Account & Contact Info

Name, email, password (hashed), role/company, time zone. Optional: phone, social handles, brand colors.

B. Content You Provide

Reference images/headshots (you must have rights/consent), prompts, captions, brand palettes, uploaded assets, and any outputs you choose to save.

C. Usage & Device Data

App events and logs, IP address, browser/OS, device identifiers, cookies, coarse geolocation inferred from IP (city/region).

D. Billing Data

Billing name/email and transaction metadata processed by our payment processor (e.g., Stripe). We do not store full card numbers.

E. Support & Surveys

Messages to support, feedback, survey responses.

Face data note: Social Pack uses headshots only to maintain likeness in images you request. We do not perform identity verification, and we do not sell or share biometric data.

3) How we use data

  • Provide, operate, and secure the Service.
  • Generate images and captions per your instructions.
  • Personalize features (e.g., seasonal/holiday scenes).
  • Communicate about updates, billing, security, and support.
  • Improve quality via analytics and de-identified aggregates (see Model & Vendor Use).
  • Prevent fraud/abuse and comply with law.

Legal bases (GDPR): Contract (Art. 6(1)(b)), Legitimate Interests (Art. 6(1)(f)) for security/product improvement, Consent (Art. 6(1)(a)) for marketing/optional features, Legal Obligation (Art. 6(1)(c)).

4) AI models & vendors

We use third-party AI and infrastructure providers as processors/sub-processors (e.g., Google, OpenAI, AWS). They process data only under our instructions, apply appropriate security, and are not permitted to use your inputs/outputs to train public models unless you explicitly opt in and vendor terms allow.

5) Face data handling

Purpose: Preserve the person's likeness in your requested outputs.

Processing: The system may create temporary numeric representations (embeddings) from your headshot to render images.

Retention:

  • Ephemeral (default): Reference images and derived embeddings are deleted after generation or session timeout (e.g., within 24 hours).
  • Library mode (opt-in): If you save a "profile," we store the headshot and embeddings until you delete them or close your account.

No sale or sharing of face data for cross-context behavioral advertising.

You confirm you have rights/consent for any person pictured.

6) Sharing your information

  • Service providers: hosting, AI inference, analytics, email, payments, customer support.
  • Legal/compliance: to comply with law, enforce terms, protect rights, or respond to lawful requests.
  • Business transfers: in a merger, acquisition, or sale of assets, we may transfer data with notice.

We do not sell personal information. We do not share personal information for targeted advertising.

7) International transfers

Data may be processed in the U.S. and other countries. We use appropriate safeguards (e.g., Standard Contractual Clauses).

8) Retention

  • Account data: for the life of your account and a reasonable period after closure (or sooner on verified request) for security/audit/legal.
  • Logs/analytics: retained in aggregated or de-identified form.
  • Face data: per Section 5.

9) Security

Encryption in transit, access controls, least-privilege, monitoring, backups, and vendor diligence. No method is 100% secure.

10) Your rights

GDPR/UK: access, rectification, erasure, restriction, portability, objection, and complaint to a supervisory authority.

California (CCPA/CPRA): know, delete, correct, limit use of sensitive info, and opt-out of "sharing." We do not "sell" personal info.

How to exercise: email privacy@throttlelabs.ai. We may need to verify your request.

11) Cookies

We use essential cookies (login/session) and performance analytics. Manage via browser settings or in-app controls.

12) Children

Not for children under 16. Do not upload images of minors without parental/guardian consent and a lawful basis. We delete such data if discovered.

13) Marketing

With consent, we send updates and tips. Unsubscribe any time in emails or app settings.

14) Model improvement

We may use aggregated, de-identified usage data and prompt telemetry to improve features. We do not use identifiable headshots or saved outputs to train public models without your explicit opt-in.

15) Changes

We'll update this page and change the Effective Date. Material changes will be notified in-app or by email.

16) Contact

privacy@throttlelabs.ai
624 E Beale St, Kingman, AZ 86401