Privacy Policy

1.Introduction

Welcome to Cotor! This Privacy Policy explains how Cotor ("we," "us," or "our") collects, uses, shares, and protects information when you use our products or services ("Service"). This policy applies to all visitors, users, and others ("Users," "you," or "your") who use our website at https://Cotor.ai/ or interact and communicate with us through our online channels.

Our Service is provided and controlled by NINETON PTE. LTD., and we are the data controller. If you have questions about how we process your personal information or wish to exercise your privacy rights, please contact us at support@Cotor.ai.

By using our Service, you acknowledge that you have read and understood this Privacy Policy. Where required by applicable law, we will obtain your consent before processing your personal information for a purpose that requires consent.

2. Information We Collect

We collect various types of information to provide and improve our Service to you.

A. Information You Provide to Us:

Account Information: When you create a Cotor account, we collect your email address and user ID. If you sign in using a Google account, we may receive the information made available by Google, such as your user ID and, if you grant permission, your email address. If you sign in using your email address, we may collect the email address and user ID associated with your account.
Communications: If you contact us directly (e.g., for customer support), we will receive your email address, the contents of your message, and any other information you choose to provide.
User Input: When you use our Service, we may collect your text prompts, uploaded audio, images, videos, brand materials, feedback, chat history, generated content, or other content that you provide. These materials may contain personal information. We do not intentionally request or knowingly collect sensitive personal information. We generate responses ("Outputs") based on your Inputs.

B. Information We Collect Automatically:

Device and Technical Information: We collect your IP address and information about your browser, operating system, device, system language, and other technical information necessary to provide and secure our website.
Service Log Information: We automatically collect and store certain information in server logs. This includes your IP address, access times, pages viewed, browser information, device information, and information about errors or crashes.
Usage Data: We collect information about your activity on our Service, such as the types of content that you view or engage with, feature usage, session times, page visits, and interactions within the website.
Transaction Information：If you choose to purchase (a product or prepaid service) or subscription (such as advanced membership), we will receive your transaction information such as orders and transaction status. We do not have access to your sensitive payment details, such as your credit card number or banking information.
Cookies and Similar Technologies: We use cookies and similar technologies, such as web beacons, tags, and scripts, to collect and use information, remember settings, maintain functionality, understand how our website is used, and improve and analyze our Service. You can manage or disable cookies through your browser settings, but some parts of the Service may not function properly.

C. Information from Third-Party Services:

Third-Party Login: You can choose to log in to our Service using a Google account. If you authorize this, we may receive the information made available by Google, such as your user ID and, if you grant permission, your email address. The information we receive depends on your settings with Google. You may also log in using your email address; in that case, we may collect the email address and user ID associated with your account.
Third-Party Payment: If you subscribe to our paid services, we use third-party payment processors. We do not collect or store your full payment card details, but we may receive transaction confirmations.

3. How We Use Your Information

We use the information we collect for the following purposes:

Provide, Operate, and Maintain Our Service, including to:
process transactions and manage subscriptions for our paid services;
provide the essential features of our website and AI-powered tools;
ensure that our Service is working as intended;
facilitate and deliver AI-powered features, such as generating marketing materials, videos, images, and other creative content. When you interact with the AI features of our Service, we collect the text, prompts, audio, images, videos, brand materials, or files you provide ("Inputs"). We may share the minimum information necessary to process your Inputs with third-party AI service providers. We may use Outputs and de-identified or aggregated information to improve Cotor's AI-powered features and services, but we will not use your personal data to train general-purpose AI models.
Manage Your Account.We use your data to create, secure, and manage your user account, allowing you to log in securely to access to different functionalities of the Service that are available to you.
Improve and Optimize Our Service, including to:
understand how our services are used and which service can be improved;
help us develop new products, features, and AI-powered tools;
improve our AI-powered features, algorithms, and service functionality using de-identified or aggregated information;
Ensure the Safety and Reliability of Our Service. For example, we prevent and detect abuse, fraud, illegal activity, and violations of our content restrictions by conducting troubleshooting, data analysis, testing, and research.
To communicate with you, including for customer support and to send you service-related notices.
To comply with legal obligations, including to:
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our compliance with legal and contractual requirements and internal policies.

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

4. Legal Basis for Processing (For Users in the EEA, UK, Switzerland, and Brazil)

If you are a user in the European Economic Area (EEA), United Kingdom (UK), Switzerland, or Brazil, we process your personal information based on the following legal grounds under applicable laws (e.g., GDPR, UK GDPR, Swiss FADP, and LGPD).

Consent: We process certain information based on your explicit consent where required by applicable law, such as optional cookies or other processing activities for which consent is required.
Performance of a Contract: We process your personal information to fulfill our contract with you, such as:
creating and managing your account;
providing the website functionalities and AI-powered services you request;
processing subscriptions and purchases.
Legitimate Interests: We process your personal information for our legitimate interests, such as:
service improvement, troubleshooting, and analytics;
fraud, abuse, and content-policy violation detection and service security;
Legal Obligation: We process your information to comply with our legal obligations, such as:
responding to lawful authority requests;
complying with applicable legal requirements.
Protection of Vital Interests: We process your information in emergency or safety-related situations.
Exercise of Rights in Legal Proceedings: We process your information to defend our rights in legal disputes.

Where we rely on consent, you may withdraw it at any time. Where we rely on legitimate interests, you may object to such processing.

5. Sharing and Disclosure of Information

We are committed to protecting your privacy. We do not sell, rent or lease your personal information to third parties. We do not transfer your personal information to any company, organization, or individual, except in the following cases:

With Your Separate Consent: We may share your information with third parties when we have obtained your separate and explicit consent to do so.

Service Providers: We share information with third-party vendors that perform services on our behalf, including authentication, AI model processing.

We share only the minimum information with AI service providers necessary for content generation, such as text prompts and uploaded files, including audio, images, videos, and brand materials. The specific information shared with each provider depends on the model or feature you select.

The specific third-party service providers are as follows：

Volcengine Ark (Doubao, Seedream, and Seedance); Kling AI; Vidu; Tencent Cloud (Gemini and Vidu)；Google Sign-in /Apple Sign-In.

We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your personal information.

Business Transfers: We will not transfer your personal information to any third party, except in the case of a merger, acquisition, asset sale, or judicial liquidation where your information may be transferred as part of the transaction. We will ensure the confidentiality of such information during the transfer process and require the new holder to continue to be bound by this Privacy Policy.

Legal Compliance and Safety: We may disclose your information if required to do so by law or to protect the safety of any person or our rights or property.

Professional Advisors, such as lawyers and accountants, where doing so is necessary to facilitate the services they render to us.

Affiliates: We may share personal information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with us. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.

Your Sharing: Your content and personal information are private by default. You may choose to make certain content publicly available through the Service, in which case it may be visible to other users or the public.

6. Cross-Border Data Transfers

Our primary data servers are located in Singapore. To keep our Service safe and reliable, we may also back up or process data in other locations where our cloud providers operate. These jurisdictions may not provide the same protections as the data protection laws in your home country. Where required, we will implement appropriate safeguards for international transfers, including Standard Contractual Clauses for transfers from the EEA, UK, or Switzerland. For more information about international transfers, please contact us at support@Cotor.ai.

7. Data Security

We store your personal information on a secure server, with the latest firewall protection, saved in secure facilities. In addition, we implement administrative, technical and physical safeguards in line with commercially applicable and industry standards to protect the confidentiality and security of your personal information and to prevent unauthorized access.
We have implemented reasonable and appropriate measures designed to protect the security of the personal information we process, including:
For services that involve uploaded audio, images, videos, brand materials, or other user-provided content, we use encryption and access controls to protect that information during transmission, processing, and storage;
We will employ multiple data anonymization techniques to enhance the security of information during use;
We will implement strict data access permission controls and multi-factor authentication technologies to protect information and prevent unauthorized use;
We will establish data classification and grading systems, data security management standards, and data security development standards to regulate the storage and use of information;
We will enforce comprehensive security controls through confidentiality agreements with information handlers and mechanisms about monitoring & audit;
We will organize security and privacy protection training programs to enhance employees' awareness of the importance of protecting personal information.
However, despite our security measures and efforts to protect your information, any electronic transmission or information storage technology through the Internet cannot guarantee 100% security. We cannot promise or guarantee that no hackers, cyber criminals or other unauthorized third party destroy our security measures, nor can we promise that no third party improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, the risk of transferring your personal information to or from our services is at your own expense. You should access the service only in a secure environment. If you have any reason to believe that your interaction with us is no longer safe, please notify us by email immediately.

8. Data Retention

In short: We will retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, or for a longer period if required or permitted by law.

We will retain your personal information only for as long as necessary for the purposes described in this Privacy Policy, unless retention for a longer period is required or permitted by law. This may include retention needed to comply with legal obligations, resolve disputes, and enforce our legal agreements and policies.
Anonymous, aggregated, and other data uncertain of your personal identity, such as your activity data, may be retained indefinitely and shared in any way with third parties.
When we have no ongoing legal business to process your personal information, we will delete or anonymize such information, or if this is impossible (for example, because your personal information is stored in a backup file), we will securely store your personal information and isolate it from any further processing until it can be deleted.

9. Your Privacy Rights

We believe in giving you control over your information. For users from certain jurisdictions (e.g., EU/EEA, UK, California), additional rights or requirements may apply in accordance with local privacy laws. This section outlines your rights and the choices you have regarding your personal information. You can exercise these rights through your account and website settings or by contacting us directly. Note that some of these rights may not be absolute. For example, if this means that we will no longer be able to fulfill our contractual obligations to you, or if this will prevent us from fulfilling our legal obligations, we may reject the request.

A. Rights You Can Exercise Yourself

You can access and manage much of your information directly through your account and website settings:

Access and Update Your Account Information: You can review and change your account information, such as your email address and user ID, through your account settings.
Delete Your Account: You can permanently delete your account and associated personal information through the account deletion option, if available, or by contacting us at support@Cotor.ai.
Manage Cookies: You can manage or disable cookies and similar tracking technologies through your web browser settings.
Manage Third-Party Logins: You can manage the information we receive from Google by reviewing and adjusting your privacy settings with Google or by contacting us at support@Cotor.ai.

B. Rights You Can Exercise by Contacting Us

To exercise the rights below, or if you have any questions or special requests, please contact us at support@Cotor.ai. For your protection, we may need to verify your identity before fulfilling your request.

Right to Access and Data Portability: You have the right to request a copy of the personal information we hold about you. You may also have the right to receive this information in a structured, commonly used, and machine-readable format to transmit to another service.
Right to Deletion: You can request the deletion of your account and personal information. Upon receiving and verifying your request, we will delete your data, subject to certain exceptions. For instance, we may be required to retain some information to comply with legal obligations, resolve disputes, or for security and fraud prevention purposes.
Right to Correct Inaccurate Information: If you believe that any personal information we hold about you is incorrect or incomplete, you have the right to request that we correct it.
Right to Review AI-Generated Content and Automated Decisions: You have the right to know when you are interacting with an AI and, where required by applicable law, to request human review of automated decisions that significantly affect your legal rights.

C. Region-Specific Rights

Depending on where you reside, you may have additional rights under local law. To exercise the rights below, or if you have any questions or special requests, please contact us at support@Cotor.ai.

For Residents of California and Virginia of the USA (under CCPA/CPRA and VCDPA)

In addition to the rights above, residents of California and Virginia have the following rights:

Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the sources from which we collected it, the purposes for collecting it, and the categories of third parties with whom we have shared it.
Right to Opt-Out of "Sale" or "Sharing": You have the right to direct us not to “sell” or “share” your personal information as defined by California law.
Right to Limit Use of Sensitive Personal Information: Where applicable law provides this right, you may request that we limit the use and disclosure of sensitive personal information. We do not intentionally request or knowingly collect sensitive personal information.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights, including by denying you services, charging you different prices, or providing you a different level or quality of service.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory data protection authority about our collection and use of your personal information.
Right to Object (under VCDPA) – You have the right to object to our processing of your personal information when it is based on our legitimate interests.
Right to Review Automated Decision-Making(under VCDPA): You have the right to request information about automated decisions and profiling that significantly affect you, and ask for human review.
For Residents of the European Economic Area (EEA), United Kingdom, and Switzerland (under GDPR/GDPR(UK)/FADP)

If you are a resident of the EEA, UK, or Switzerland, you have the following data protection rights:

Right to Object: You have the right to object to our processing of your personal information when it is based on our legitimate interests.
Right to Restrict Processing: You can ask us to suspend the processing of your personal information in certain circumstances.
Right to Withdraw Consent: Where we have collected and processed your information with your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.
Right to Object Automated Decision-Making: You have the right to object automated decisions and profiling that significantly affect you, or ask for human review for such decisions.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory data protection authority about our collection and use of your personal information.
For Residents of Brazil (under LGPD)

If you are a resident of Brazil, you have the following rights under the Lei Geral de Proteção de Dados (LGPD):

Confirmation of Processing: You have the right to confirm the existence of processing of your data.
Anonymization, Blocking, or Deletion: You have the right to request the anonymization, blocking, or deletion of unnecessary or excessive data or data processed in noncompliance with the LGPD.
Information on Data Sharing: You have the right to request information about the public and private entities with which we have shared your data.
Information on Consent: You have the right to be informed about the possibility of denying consent and the consequences of such denial.
Revocation of Consent: You have the right to revoke your consent at any time.
Review Automated Decision-Making: You have the right to request information about automated decisions and profiling that significantly affect you, and ask for human review.
Lodge a Complaint: You have the right to lodge a complaint with a supervisory data protection authority about our collection and use of your personal information.

10. Social Media and Third Party Services

We may provide links to third-party websites and services, including Google and other services used to provide or support our Service. Any data collected by those third parties is governed by their own privacy policies. You should review those policies before using the relevant third-party service.

11. Children's Privacy

Our Service is not directed to children or minors under 18, and we do not knowingly process personal information from them. If we learn that we have collected personal information from a child or minor, we will promptly delete that information. If you believe that we have processed personal information from a child or minor, please contact us at support@Cotor.ai.

12. Changes to This Privacy Policy

Our Privacy Policy may be amended or updated.

Without your explicit consent, we will not reduce the rights you are entitled to under this Privacy Policy. We will post any changes to this Privacy Policy on this page.
If this Privacy Policy is updated or undergoes significant changes, we will notify you through the website or other reasonable means and indicate the updated Effective Date and Last Updated date.

13. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

For general inquiries: support@Cotor.ai

For privacy-specific requests: support@Cotor.ai

Legal Entity: NINETON PTE. LTD., 60 PAYA LEBAR ROAD, #04-27, PAYA LEBAR SQUARE, SINGAPORE 409051