Sumeru AI Privacy Policy

Last Updated: August 26, 2025

Sumeru AI is an independent platform for creating synthetic media, allowing users to create their interactive video. We understand that your privacy is important and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our websites and uses our platform, and only collect and use information in ways that are consistent with your rights and obligations under applicable laws.

This Privacy Policy applies to the website at https://www.sumeruai.us or any portion of the site (the "Site") or any related services (including but not limited to APIs, embeds, and other off-site functionality) (the "Services") that link to this Privacy Policy. The Services is provided and controlled by SUMERUAI LLC, with its registered address at 1501 86th Ave NE, Clyde Hill, WA, 98004-3338 (the "Company", "we" or "us") to you ("you" or "your"). This Privacy Policy explains what personal information we collect, how we collect and use that information, with whom we share the data, and your rights regarding the data.

For purposes of this Privacy Policy, Sumeru AI is usually the processor of your personal information. We are the controller only if we process data for our own legitimate purposes, as described in this Privacy Policy.

Please read this Privacy Policy carefully and ensure that you understand it. By using any of our Services, you agree to this Privacy Policy and our collection, use, and disclosure of your information as described in this Privacy Policy. If you disagree with this Privacy Policy, you must stop using our Services immediately.

1. Definition

For purposes of this Privacy Policy, "Personal Information" refers to data which identifies, relates to, describes, references, or is reasonably capable of being associated with an identified or identifiable natural person.

2. Collection of Your Personal Information

This Privacy Policy applies only to our collection and processing of Personal Information about users of the Services, including individuals who access and use the Services on behalf of a business customer.

A. Personal Information You Provide

We collect the following types of Personal Information from you when you use the Services:

Registration and Log-in Information. When you use our Services, you need to create an account with us and login to your account. We may ask you to provide certain Personal Information, including your email address, username and password when creating an account and logging in the account to set up your profile. We may provide services through various forms such as websites, applications. To enhance your user experience across all platforms, data associated with your account will be synchronized among the different versions of the platform.

Beta Testing. To help you become one of our invited beta testers, we may ask you to provide certain Personal Information, including your username, organization name and email address, for the purpose of identity verification and to grant you access to a test account.

Service. The Services is an artificial intelligence online service we provide based on large language models of technology, designed to help you complete various tasks more efficiently. When you use the Service, we may ask you to provide certain Personal Information, including text, images, voice, video and file information that you elect to input or provide to our Services (collectively, "Input"). We will perform computation and analysis on the Input in order to better understand your questions, contextual background, and instructions, so as to execute specific tasks and present the results to you.

Communication Information. When you contact us, we may ask you to provide certain Personal Information, including username, organization, feedback, inquiries or other information you choose to send.

Experience Enhancement. You may choose to join our Experience Enhancement which helps us improve our Services, and provide enhanced interaction experience. If you choose to join the Experience Enhancement and provide your authorization, we may ask you to provide certain Personal Information, including the device information (device model, device MAC address, and IP address), usage data (the number of clicks on product function buttons, duration of feature usage, your interactions with product features, usage flow, and personalized settings). The data will be used—under the premise of ensuring privacy and data security—to enhance your experience and support the improvement of our Services. You have the right to withdraw from the Experience Enhance at any time by sending the email to service@sumeruai.com. Adjusting or revoking your prior authorization will not affect your ability to use the features on the Services.

When using our Services, it is essential to provide only your own Personal Information. The use of another individual's Personal Information without their explicit consent is strictly prohibited and may constitute a violation of applicable laws. Unauthorized use of someone else's Personal Information, including but not limited to identity theft, fraud, or any other malicious activity, is not only prohibited within our Site but may also be considered a criminal offense. We are committed to safeguarding the privacy and security of all our users, and we expect every user to respect these principles. Please ensure that the Personal Information you provide is accurate and belongs to you, and refrain from any unauthorized or deceptive use of Personal Information. We take such matters seriously and will cooperate with law enforcement agencies to address any unlawful activities within our platform.

B. Personal Information We May Automatically Collect About You

Our Services may automatically collect certain Personal Information when you visit, use, and interact with the Services. This Personal Information may include the following:

Payment Data: we will collect payment card details if you make the payment by a payment card. We will collect bank account details if you make the payment by wire transfer or ACH. We will also collect the details of the amount paid or refunded, the payment date, and the services purchased.

Usage Information: During your interaction by using the Service, we will collect and process information about how users use or interact with the website, services, and software features and functions, e.g. the most frequently visited pages, features used, preferred sounds and photos, documents (pptx, docx, pdf).

3. Information Provided by Choice

In some instances, our Services may provide you with the option to provide certain Personal Information. While the use of this information is always subject to this Privacy Policy, it is important to note that choosing to withhold certain Personal Information may impact your ability to access specific features, content, or services within our Services.

4. Use of Your Personal Information

We use your Personal Information to provide you with the best possible products and services. Depending on the jurisdiction in which you are located, we will only process your Personal Information based on valid legal basis. In general, Sumeru AI acts as a data processor when processing Personal Information on behalf of our business customers in accordance with their instructions. However, Sumeru AI acts as a data controller when processing Personal Information for purposes such as marketing, service improvement, and regulatory compliance.

Below, we list the purposes and appropriate legal grounds for processing:

• Providing and managing your Account and access to and use of our Services. It is necessary to perform our obligations under the Terms of Service agreement between you and us.

• Ensure a consistent service experience and to guarantee interconnection between services, by using a unified account service to collectively collect and process your personal data;

• Provide, administer, maintain the Services, such as enabling you to use the Services, browse the regulation compilations and provide user support;

• Improve, review and develop our Services (e.g. train the large language model that support the Services) and conduct analysis, by monitoring interactions on the Services and collecting feedbacks from you;

• Providing customer support, responding to communications from you, sending you emails that you have subscribed to, or announcements relating to your account. It is necessary to perform our obligations under the services agreement between you and us;

• Training and enhancing the models that power our products and services, including making our avatar creation models more accurate. It is necessary for our legitimate interest and subject to appropriate safeguards.

• Understanding the usage of our services, understanding trends and preferences, improving and repairing errors in the services, and in this context developing new products, services, features, and functionalities. We have a legitimate interest in using your Personal Information for the purpose of understanding usage.

• Complying with applicable legal obligations, enforcing our contractual arrangements and policies, and protecting or defending the Services, our rights and the rights of our users or others. We may need it to comply with a legal obligation, for instance, to comply with court order.

• Enforcing our contractual arrangements and policies, and protecting or defending the Services, our rights, and the rights of our users or others. We have a legitimate interest in using your Personal Information to safeguard our contracts and legally recognized interests.

• Sending you marketing communications, including news and offers on our products or services (with your permission/consent or where otherwise permitted by applicable law). Unless permitted by law, we will not send you unsolicited marketing communications. We will also take all reasonable steps to ensure that we comply with our obligations under applicable email marketing laws. You can unsubscribe from our emails at any time by using the unsubscribe function in the email communication to you. We will remove your email address from our subscriber list upon receipt of such a request.

5. Sharing of Your Personal Information

We do not sell or share your Personal Information.

We will not share your Personal Information with any other party not mentioned above, unless:

• we are required to do so by law or in the good faith belief that such action is required to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud or criminal activity,(iv) respond under urgent circumstances to protect the personal safety of any entity, person or group, or (v) to avoid or mitigate against legal liability

• As part of a legal proceeding, it is necessary that we share your Personal Information with our legal advisors

• where we are involved in a sale, transfer, reorganization, bankruptcy, receivership, merger or listing of our business, we will continue to ensure the confidentiality of your Personal Information and give you advance notice that your Personal Information will be transferred or become subject to a different Privacy Policy.

If we decide to disclose your Personal Information to other parties not mentioned above, we will post a notice of the change and update this Privacy Policy thirty (30) days prior to the implementation of such change. You have the right to opt out of this change. Please contact us service@sumeruai.com to exercise this right.

6. Privacy Policy Change and Opt-Out Rights

Changes to Privacy Policy. If we decide to use Personal Information for materially different purposes, or there is any material change to the Privacy Policy, we will post a notice of the change and update this Privacy Policy five (5) days prior to the implementation of such change. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our website and this privacy policy to check for any changes.

Opt-Out Right. You have the right at any time to cease permitting your Personal Information to be collected, used, or disclosed by us and/or by any third party with whom we have shared or transferred such Personal Information. Please see below "Your Rights" as provided in Section 13 for how to exercise this right.

7. Personal Information Retention

Your Personal Information is stored digitally within our systems and may also be securely maintained by our trusted external service providers when necessary for the purposes of our business operations. We retain your Personal Information only for as long as is reasonably necessary to fulfill the purposes for which it was collected. This includes purposes related to providing our Services, as well as meeting any legal, regulatory, accounting, and reporting requirements. In certain circumstances, we may retain your Personal Information for a longer period, for example, when there is a complaint or dispute concerning the information, or when we reasonably anticipate litigation arising from our relationship with you.

8. Data Aggregation

Aggregated Personal Information refers to data that has been anonymized so that it cannot be linked back to any specific individual. We may aggregate Personal Information or collect aggregated data from our users, which is essential for enhancing the functionality and performance of our Services. This enables us to analyze user behavior, improve our Service's features, develop new products and services, conduct research, and other similar purposes. We use this information to gain insights into overall usage patterns and trends, helping us make data-driven decisions to enhance the user experience. In some cases, we may also choose to share or publish this aggregated information.

We are committed to adhering to relevant privacy and data protection regulations and our Privacy Policy in all our data aggregation activities. If you have any questions or concerns regarding data aggregation, please read our full Privacy Policy for more details on how we handle and safeguard your information. Your privacy and security are our top priorities.

9. Third Party Links

Our Services may contain links to external websites, apps, and platforms for your convenience and enhanced user experience. However, it's important to note that our Privacy Policy applies solely to our own data practices, and we are not responsible for the data handling policies or content of these other websites, apps, and platforms.

When you click on such third-party links, you may be redirected to a different environment with its own privacy policies and practices. We strongly recommend that you review the privacy policy of any specific website, app, or platform you visit through our links. This will help you understand how your Personal Information is collected, used, and protected within those external environments. We strongly encourage you to exercise caution and discretion when navigating to external websites, apps, or platforms. We cannot ensure or warrant the security of any data you provide to any third party.

10. Data Security

• Designation of Responsible Employees. We have designated specific employees responsible for the oversight and management of our data security program. They are accountable for ensuring that data security practices are implemented and maintained consistently.

• Identification and Assessment of Risks. We regularly identify and assess data security risks to protect your Personal Information. This ongoing risk assessment helps us stay proactive in addressing potential threats.

• Policy Development and Implementation. We have established comprehensive policies for the secure storage, access, and transportation of user Personal Information. These policies govern how data is collected, stored, and transmitted within our organization.

• Disciplinary Measures. Any breach or non-compliance with data security policies will result in appropriate actions to address the issue and prevent future violations.

• Access Limitation for Terminated Employees. Access to personal information is promptly revoked for terminated employees. This ensures that former employees do not retain access to user sensitive information.

• Third-Party Vendor Oversight. We carefully oversee the security practices of third-party vendors who have access to our data. We require them to adhere to the same high standards of data security and privacy.

• Access Restrictions. All our user information is in digital format. We restrict digital access to records containing our user Personal Information to authorized personnel only. This includes robust access controls.

• Monitoring and Review. We continuously monitor and review the scope and effectiveness of our data security policies. Regular assessments help us identify areas for improvement and ensure that our data security practices remain up to date.

• Incident Documentation. In the event of data security incidents, we diligently document the details of the incident and our response. This documentation helps us learn from past incidents and refine our data security procedures to enhance protection.

While we take every precaution to protect Personal Information, it's important to note that no data security measures are perfect, and data transmission over the internet is inherently risky. We cannot ensure or warrant the security of any data you provide to us.

11. International Data Transfer

By using our Services, you understand and acknowledge that your Personal Information may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside the United States and may have different data protection laws than in the United States.

12. Business Changes

We may, from time to time, expand or reduce our business, and this may involve the sale and/or the transfer of control of all or part of our business, which could take various forms, such as an asset sale, merger, bankruptcy or other business transaction. Personal Information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part, and the new owner or newly controlled party will, under the terms of this Privacy Policy, be permitted to use the information for the purposes for which it was originally collected by us. We may also disclose Personal Information to third parties assisting with such a business transaction, such as legal advisors involved in the due diligence process.

If any of your Personal Information is transferred in this manner, you will be contacted in advance and informed of the changes.

13. Your Rights

Depending on where you live, you may have certain statutory rights in relation to your Personal Information. For example, you may have the right to:

• Access your Personal Information and information relating to how it is processed;

• Delete your Personal Information from our records;

• Update or correct your Personal Information;

• Transfer your Personal Information to a third party (right to data portability);

• Withdraw your consent—where we rely on consent as the legal basis for processing at any time;

• Object to how we process your Personal Information;

You can exercise some of these rights through service@sumeruai.com and we will response to your inquiry or request in a timely manner. We will not discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before exercising these rights, such as your email address or government issued ID. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. If we deny your request, you may appeal our decision by contacting us through the methods described below.

Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights. To appeal a decision, please send your request to service@sumeruai.com.

We process your Personal Information for the purposes described in this Privacy Policy on servers located in various jurisdictions, including processing and storing your Personal Information in our facilities and servers in the United States. While data protection law varies by country, we apply the protections described in this policy to your Personal Information regardless of where it is processed, and only transfer that data pursuant to legally valid transfer mechanisms.

14. Appropriate Content

By using our Service, you understand that your use of the Site may be monitored, restricted, or prohibited in certain circumstances. Your privacy is important to us, and any data collected during this monitoring will be handled in accordance with this Privacy Policy. Please review our full Privacy Policy for more information on data usage and protection.

15. Age Requirement

Our Services are not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If you are under 13, please do not use or provide any information through our Services or on or through any of its features/register for our Services, make any purchases through our Services, use any of the interactive or public comment features of our Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at service@sumeruai.com.

Contact Us

For any inquiries, concerns, or requests related to our data practices and your Personal Information, please do not hesitate to reach out to our dedicated Data Protection Officer via email service@sumeruai.com. We are committed to ensuring the protection of your privacy and are here to address any questions or concerns you may have regarding the handling of your Personal Information. Your privacy and data security are of utmost importance to us. Please feel free to contact our Data Protection Officer for assistance or further information.