Privacy Policy

Effective date: 14 June 2026

1. Data Controller

Free Soda Limited ("we", "us", "our") is the data controller responsible for your personal data processed through the Creator Vision platform ("the Service").

Registered address: Free Soda Limited, 2 Old Bath Road, Newbury, Berkshire, RG14 1QL, United Kingdom.
Contact: privacy@freesoda.io

2. Data We Collect

We collect and process the following categories of personal data:

  • Account information — email address, name, and password hash when you register or sign in.
  • Authentication tokens — OAuth 2.0 access and refresh tokens when you connect a Google/YouTube account, a TikTok creator account, a Meta (Facebook/Instagram) account, or a Snap account. These are stored securely and used solely to interact with the respective platform API on your behalf.
  • TikTok creator profile data — when you connect a TikTok account we fetch and store: the creator's TikTok open ID, display name, avatar URL, username, and profile link. This data is used solely to identify the connected creator within Creator Vision and to enable video uploads to that account.
  • Meta (Facebook & Instagram) account data — when you connect a Meta account we fetch and store: Facebook Page identifiers, names and Page access tokens, and the identifiers and usernames of Instagram professional accounts linked to those Pages. This data is used solely to identify the Pages and Instagram accounts you authorise and to publish video content to them on your behalf.
  • Snap public profile data — when you connect a Snap account we fetch and store: the public profile identifiers, display names, usernames and organisation identifiers you authorise. This data is used solely to identify the profiles you authorise and to publish video content to Snapchat Spotlight on your behalf.
  • Usage data — pages visited, features used, timestamps, and IP address for security and service improvement.
  • Content data — video metadata, thumbnails, scene data, and compilation settings you create within the Service.

3. Legal Basis for Processing

We process your data under the following legal bases (GDPR Article 6):

  • Performance of a contract (Art. 6(1)(b)) — processing necessary to provide the Service under your subscription agreement.
  • Legitimate interests (Art. 6(1)(f)) — security monitoring, fraud prevention, and service improvement.
  • Consent (Art. 6(1)(a)) — where you explicitly grant access to third-party accounts (e.g. Google OAuth).

4. How We Use Your Data

  • To provide, maintain, and improve the Service.
  • To authenticate you and manage your account.
  • To interact with the YouTube API on your behalf (uploading, channel management, metadata retrieval).
  • To interact with the TikTok API on your behalf — specifically to fetch your creator profile at connect time and to upload compiled videos to your TikTok creator inbox.
  • To interact with the Meta (Facebook & Instagram) APIs on your behalf — specifically to list the Facebook Pages and linked Instagram professional accounts you authorise, and to publish video content to the Pages and Instagram accounts you select.
  • To interact with the Snap Public Profile API on your behalf — specifically to list the public profiles you authorise and to publish video content to Snapchat Spotlight.
  • To generate AI-powered metadata, content analysis, and assets.
  • To communicate service updates and respond to support requests.

5. YouTube API Services

Creator Vision uses YouTube API Services. By connecting a YouTube channel or a YouTube Content Owner (CMS) account, you also agree to be bound by the YouTube Terms of Service. Our access to, and use of, information obtained through the YouTube API Services is additionally governed by the Google Privacy Policy. Where the Service displays data obtained from YouTube, that data is provided by YouTube.

We access YouTube data only with your authorisation (via Google OAuth, or via a Content Owner service account you authorise), and we use it solely to provide the Service to you in respect of your own channels and content — for example to retrieve your channel and video analytics, read your video metadata, and upload videos and thumbnails on your behalf. You can withdraw this authorisation at any time (see section 13).

6. TikTok API Services

Creator Vision uses TikTok API Services (Login Kit and the Content Posting API). By connecting a TikTok creator account, you also agree to be bound by the TikTok Terms of Service. Our access to, and use of, information obtained through the TikTok API is additionally governed by the TikTok Privacy Policy.

We access TikTok data only with your authorisation (via TikTok OAuth), and we use it solely to provide the Service to you in respect of your own TikTok creator account — specifically to identify the connected account and to upload videos to your creator inbox on your behalf. We do not post to TikTok publicly without the creator first reviewing and approving the content from their TikTok Studio inbox.

TikTok creator profile data (open ID, display name, avatar, username, profile link) and TikTok access tokens are retained only while your authorisation remains active. When you disconnect your TikTok account (see section 13) we immediately cease accessing TikTok on your behalf and delete the associated tokens and profile data within 7 days.

7. Meta (Facebook & Instagram) API Services

Creator Vision uses the Meta APIs (Facebook Login for Business, the Facebook Graph API and the Instagram Graph API). By connecting a Meta account, you also agree to be bound by the Meta Terms of Service and the Meta Platform Terms. Our access to, and use of, information obtained through the Meta APIs is additionally governed by the Meta Privacy Policy.

We access Meta data only with your authorisation (via Facebook Login for Business), and we use it solely to provide the Service to you in respect of your own Facebook Pages and linked Instagram professional accounts — specifically to list the Pages and Instagram accounts you authorise and to publish video content to them on your behalf. We do not access your Meta data for any other purpose, and we do not sell or transfer it.

Tech Provider disclosure. Where you use Creator Vision to manage Facebook Pages or Instagram accounts owned by a business, Creator Vision acts as a "Tech Provider" processing Meta Platform Data on behalf of that business for the sole purpose of the publishing services described above, in accordance with the Meta Platform Terms.

Facebook Page access tokens, Page identifiers and names, and the identifiers and usernames of linked Instagram professional accounts obtained through the Meta APIs are retained only while your Meta authorisation remains active. When you revoke access (see section 13) or ask us to delete your data, we immediately cease accessing Meta on your behalf and delete the associated tokens and account data within 7 days.

8. Snap API Services

Creator Vision uses the Snap Public Profile / Marketing API. By connecting a Snap account, you also agree to be bound by the Snap Terms of Service. Our access to, and use of, information obtained through the Snap APIs is additionally governed by the Snap Privacy Policy.

We access Snap data only with your authorisation (via Snap OAuth), and we use it solely to provide the Service to you in respect of your own Snap public profiles — specifically to list the public profiles you authorise and to publish video content to Snapchat Spotlight on your behalf. We do not access your Snap data for any other purpose, and we do not sell or transfer it.

Snap OAuth tokens and public profile data (profile identifiers, display names, usernames and organisation identifiers) obtained through the Snap APIs are retained only while your Snap authorisation remains active. When you revoke access in-app (see section 13) or request deletion of your data, we immediately cease accessing Snap on your behalf and delete the associated tokens and profile data within 7 days.

9. AI-Generated Content Ownership

All AI-generated metadata, content, and assets produced by the Service are the intellectual property of Free Soda Limited. A licence to use such AI-generated materials is granted to you for the duration of your active subscription agreement. Upon termination of the subscription, this licence expires and you must cease use of all AI-generated materials unless a separate written agreement is in place.

10. Data Sharing, Third Parties and Sub-processors

We do not sell your personal data and we do not share it with third parties for their own purposes. We do, however, rely on a small number of service providers ("sub-processors") that process data on our behalf and under our instructions, solely to operate and provide the Service. This includes any data we obtain from the connected platforms below (such as account identifiers, usernames and access tokens), which may be stored or processed by these sub-processors only to deliver the Service to you. Our current sub-processors are:

  • Amazon Web Services (AWS) — cloud hosting, storage, database, and secrets management. Data is processed in the AWS Europe (Ireland) region (eu-west-1). This is where account credentials, access tokens and related platform data are stored.
  • Sentry (Functional Software, Inc.) — application error monitoring and diagnostics. May process a limited subset of data (such as account or resource identifiers) where it appears in error reports. Processed in the European Union. Access tokens and secrets are excluded from diagnostic data.
  • Google Cloud — additional cloud infrastructure and API access used to provide the Service.
  • AI service providers (OpenAI, Google Vertex AI) — for content analysis and metadata generation. Data sent to these providers is limited to what is necessary for the specific processing task.
  • YouTube / Google APIs — when you authorise us to manage your channel or upload content.
  • TikTok APIs — when you authorise us to connect your TikTok creator account, or to upload compiled videos to your TikTok creator inbox for you to review and publish to your TikTok feed.
  • Meta APIs (Facebook & Instagram) — when you authorise us to connect your Meta account, or to publish video content to the Facebook Pages and Instagram professional accounts you select.
  • Snap APIs — when you authorise us to connect your Snap account, or to publish video content to Snapchat Spotlight on the public profiles you select.

We do not sell your personal data to third parties.

Requests from public authorities. We may occasionally receive requests from government or public authorities for user personal data. For every such request we: review the request for legality and validity before responding, taking legal advice where appropriate; disclose only the minimum information strictly necessary to comply; challenge requests we consider unlawful, overbroad or improperly made; and document each request together with our response, the legal reasoning, and the parties involved. We do not provide any government or authority with bulk or direct, unfettered access to personal data.

11. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States. Where such transfers occur, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.

12. Data Retention and Deletion

We retain your personal data for as long as your account is active or as needed to provide the Service. Upon account deletion or subscription termination, we will delete or anonymise your personal data within 28 days, except where retention is required by law (e.g. financial records).

YouTube data. Data we obtain from the YouTube API Services on your behalf — your channel and video analytics and YouTube-sourced metadata (together, "YouTube Authorized Data") — is retained only while your authorisation remains active. When you revoke access (see section 13) or ask us to delete your data, we:

  • immediately cease accessing your YouTube data on revocation; and
  • delete your stored YouTube Authorized Data within 7 days where you revoke in-app or make a data-deletion request, and within 30 days where you revoke access via your Google Account settings.

TikTok data. TikTok OAuth tokens and creator profile data (open ID, display name, avatar, username, profile link) obtained through the TikTok API are retained only while your TikTok authorisation remains active. When you disconnect your TikTok account in-app (see section 13) or request deletion of your data, we immediately cease accessing TikTok on your behalf and delete the associated tokens and profile data within 7 days.

Meta (Facebook & Instagram) data. Facebook Page access tokens, Page identifiers and names, and the identifiers and usernames of linked Instagram professional accounts obtained through the Meta APIs are retained only while your Meta authorisation remains active. When you revoke access in-app (see section 13) or request deletion of your data, we immediately cease accessing Meta on your behalf and delete the associated tokens and account data within 7 days.

Snap data. Snap OAuth tokens and public profile data (profile identifiers, display names, usernames and organisation identifiers) obtained through the Snap APIs are retained only while your Snap authorisation remains active. When you revoke access in-app (see section 13) or request deletion of your data, we immediately cease accessing Snap on your behalf and delete the associated tokens and profile data within 7 days.

How to request deletion. To request deletion of the data Creator Vision holds about you — including any YouTube, TikTok, Meta or Snap data described above — revoke the relevant connection on the User Admin page (see section 13) or email privacy@freesoda.io. We complete deletion within 7 days of an in-app revocation or a deletion request.

AI-generated metadata, knowledge-graph data, and other materials the Service generates about your content are the intellectual property of Free Soda Limited (see section 9) and are retained as set out in that section; they are not part of the YouTube, TikTok, Meta or Snap authorised data described above.

13. Revoking Access

You can revoke Creator Vision's access to your connected platform accounts at any time.

YouTube / Google:

  • In the app — on the User Admin page, click "Revoke access" for the relevant channel. This immediately revokes our access and schedules deletion of the related YouTube Authorized Data within the timeframes set out in section 12.
  • Via your Google Account — visit myaccount.google.com/permissions and remove Creator Vision.
  • Content Owner / Service Account customers — remove the Creator Vision service account from your YouTube Content Manager (CMS) Content Owner settings.

TikTok:

  • In the app — on the User Admin page, click "Disconnect TikTok" for the relevant creator account. This immediately revokes our access and schedules deletion of the associated TikTok tokens and profile data within 7 days.
  • Via TikTok — visit your TikTok account settings under "Apps and Websites" and remove Creator Vision.

Meta (Facebook & Instagram):

  • In the app — on the User Admin page, click "Revoke access" for the relevant Meta connection. This immediately disconnects the connected Facebook Pages and Instagram professional accounts, permanently removes the stored Meta credential, and schedules deletion of the associated tokens and account data within 7 days.
  • Via Facebook — visit your Facebook settings under "Business Integrations" (Settings & privacy → Settings → Business integrations) and remove Creator Vision.

Snap:

  • In the app — on the User Admin page, click "Revoke access" for the relevant Snap connection. This immediately disconnects the connected public profiles, permanently removes the stored Snap credential, and schedules deletion of the associated tokens and profile data within 7 days.
  • Via Snapchat — manage connected apps in your Snap Business Manager / account settings and remove Creator Vision.

14. Your Rights

Under the GDPR, you have the following rights:

  • Access — request a copy of your personal data.
  • Rectification — correct inaccurate data.
  • Erasure — request deletion of your data ("right to be forgotten").
  • Restriction — restrict processing in certain circumstances.
  • Portability — receive your data in a structured, machine-readable format.
  • Objection — object to processing based on legitimate interests.
  • Withdraw consent — where processing is based on consent, withdraw it at any time.

To exercise any of these rights, contact us at privacy@freesoda.io. We will respond within 30 days.

15. Cookies

The Service uses essential cookies required for authentication and session management. These cookies are strictly necessary for the Service to function and do not require consent under GDPR. We do not use advertising or tracking cookies.

16. Security

We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit (TLS), access controls, and regular security reviews.

17. Children's Privacy

The Service is not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly.

18. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on this page and updating the effective date. Your continued use of the Service after any changes constitutes acceptance of the updated policy.

19. Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local data protection supervisory authority. In the UK, this is the Information Commissioner's Office (ICO): ico.org.uk.