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PRIVACY POLICY

Burlap Application
Effective Date: November 19, 2025
Last Updated: November 19, 2025

1. INTRODUCTION

Third Wall Studio Incorporated ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Burlap application for macOS (the "App").

By using the App, you consent to the data practices described in this policy. If you do not agree with this policy, please do not use the App.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

  • Account Information: Email address, username, and password when you create an account
  • Payment Information: Payment details processed through our payment processor for Burlap Credit purchases. All payment information is processed exclusively by our payment processor; we do not store full payment card numbers.
  • User Content: Text prompts, images, videos, and other content you input for AI processing. You retain full ownership of all content you provide. We do not use your images, text prompts, or videos to train AI models.
  • Support Communications: Information you provide when contacting customer support

2.2 Information Collected Automatically

  • Usage Data: Features used, credits consumed, frequency of use, and interaction patterns
  • Device Information: Mac model, macOS version, App version, and unique device identifiers
  • Log Data: Error reports, crash logs, and performance metrics
  • Analytics Data: Aggregated usage statistics to improve our services

2.3 Information from Third Parties

We may receive metadata or error information from AI providers (OpenAI, Google, Runway) related to your use of their services through our App.

3. HOW WE USE YOUR INFORMATION

We use collected information to:

3.1 Provide and Maintain Services

  • Process AI requests through third-party services (we send your content to these services but do not use it for training)
  • Manage your account and Burlap Credits
  • Process payments and prevent fraud
  • Provide customer support

3.2 Improve and Develop Services

  • Analyze usage patterns to enhance features
  • Debug and fix technical issues
  • Develop new features and services
  • Conduct research and analytics

3.3 Communicate with You

  • Send transaction confirmations and receipts
  • Provide important service updates and security alerts
  • Respond to support inquiries
  • Send marketing communications (with your consent)

3.4 Legal and Safety Purposes

  • Comply with legal obligations
  • Enforce our Terms of Service
  • Protect against fraudulent or illegal activity
  • Protect the rights and safety of users

4. THIRD-PARTY AI SERVICES

4.1 Data Sharing with AI Providers

When you use AI features, your content (text prompts, images, and videos) is transmitted to and processed by:

  • OpenAI: Subject to OpenAI's Privacy Policy (https://openai.com/privacy)
  • Google AI: Subject to Google's Privacy Policy (https://policies.google.com/privacy)
  • Runway: Subject to Runway's Privacy Policy (https://runwayml.com/privacy)

Important:

  • We send your content to these third-party AI services solely for processing your requests
  • We do NOT use your images, text prompts, or videos to train any AI models
  • You retain full ownership of all content you submit
  • Third-party AI providers may have their own data usage policies - we recommend reviewing them

4.2 Third-Party Data Processing

  • We do not control how third-party AI providers process your data
  • Each provider has its own data retention and usage policies
  • We recommend reviewing each provider's privacy policy

4.3 API Usage

We use official APIs provided by these services and implement appropriate security measures for data transmission.

5. DATA SHARING AND DISCLOSURE

We do not sell, trade, or rent your personal information. We may share your information in the following circumstances:

5.1 Service Providers

With trusted third parties who assist in operating our App:

  • Payment processors for credit purchases
  • Cloud storage providers
  • Analytics services
  • Customer support tools

5.2 AI Service Providers

With OpenAI, Google, and Runway as necessary to provide AI functionality

5.3 Legal Requirements

When required by law or to:

  • Respond to legal process or government requests
  • Protect our rights, privacy, safety, or property
  • Prevent fraud or security issues

5.4 Business Transfers

In connection with any merger, sale of company assets, or acquisition

5.5 Consent

With your explicit consent for any other purpose

6. DATA RETENTION

6.1 Retention Periods

  • Account Data: Retained for the duration of your account plus a reasonable period
  • Transaction Data: Retained as required for legal and accounting purposes
  • User Content: Deleted upon request, subject to technical limitations
  • Analytics Data: Retained in aggregated form for up to 2 years

6.2 Deletion Requests

You may request deletion of your personal data, subject to legal retention requirements.

7. DATA SECURITY

7.1 Security Measures

We implement appropriate technical and organizational measures including:

  • Encryption of data in transit and at rest
  • Regular security assessments
  • Access controls and authentication
  • Secure coding practices

7.2 Data Breach Response

In the event of a data breach, we will notify affected users as required by applicable law.

7.3 Limitations

No security system is impenetrable. We cannot guarantee absolute security of your data.

8. CHILDREN'S PRIVACY

The App is not intended for children under 13 (or applicable age in your jurisdiction). We do not knowingly collect personal information from children. If we discover we have collected information from a child, we will delete it immediately.

9. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your own. These countries may have different data protection laws. By using the App, you consent to such transfers.

We rely on European Commission–approved Standard Contractual Clauses (SCCs) for transfers where required.

10. CALIFORNIA PRIVACY RIGHTS

California residents have additional rights under the California Consumer Privacy Act (CCPA):

  • Right to know what personal information is collected
  • Right to know if personal information is sold or disclosed
  • Right to say no to the sale of personal information
  • Right to equal service and price

11. EUROPEAN PRIVACY RIGHTS

If you are in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR):

  • Right to access
  • Right to rectification
  • Right to erasure
  • Right to restrict processing
  • Right to data portability
  • Right to object
  • Rights related to automated decision-making

12. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. We will notify you of any material changes by:

  • Posting the new policy in the App
  • Updating the "Last Updated" date
  • Sending you an email notification (for material changes)

Your continued use after changes constitutes acceptance of the updated policy.

13. CONTACT US

For questions, concerns, or to exercise your privacy rights, contact us at:

Data Protection Officer
Third Wall Studio Incorporated
112 Greene Street
New York, NY 10012
privacy@thirdwallstudio.com
https://burlap.app

14. LEGAL BASIS FOR PROCESSING (EEA)

For EEA residents, our legal bases for processing include:

  • Consent: For marketing communications and optional features
  • Contract: To provide services you've requested
  • Legal Obligations: To comply with laws
  • Legitimate Interests: To improve services and prevent fraud

15. COOKIES AND TRACKING

The App may use local storage and similar technologies to:

  • Maintain session state
  • Store preferences
  • Collect analytics data

16. USER CONTENT OWNERSHIP AND USAGE

16.1 Your Ownership Rights

  • You retain full ownership of all images, videos, and text prompts you submit to the App
  • We do not claim any ownership rights to your content
  • Your content remains yours before, during, and after processing

16.2 How We Use Your Content

  • Processing Only: We transmit your content to third-party AI services (OpenAI, Google AI, Runway) solely to fulfill your AI processing requests
  • No Training: We do NOT use your images, text prompts, or videos to train, improve, or develop AI models
  • No Sharing: We do not share, sell, or distribute your content to any parties other than the AI service providers necessary for processing
  • Temporary Processing: Your content is transmitted to AI providers for immediate processing and is not stored by us beyond what's necessary for service delivery

16.3 Third-Party AI Processing

  • When you request AI processing, your content is sent to the selected third-party AI provider
  • Each provider has their own data policies regarding whether they use API data for training
  • We recommend reviewing the specific API data usage policies of OpenAI, Google AI, and Runway