Privacy Policy of the products of movingimage EVP GmbH

This Privacy Policy provides information about the processing of personal data in connection with the provision, registration, use and administration of the products of movingimage EVP GmbH (hereinafter referred to as “movingimage”). It does not apply to the use of the movingimage website. The separately published Website Privacy Policy applies exclusively to the use of the website.

1. Responsibility and Allocation of Roles

The controller within the meaning of Art. 4 No. 7 GDPR for the processing activities described in this Privacy Policy that are carried out under movingimage’s own responsibility is:

‍movingimage EVP GmbH
Tempelhofer Ufer 1
10961 Berlin

Email: legal@movingimage.com

You may also contact our Data Protection Officer using these contact details. Please include the designation “For the Attention of the Data Protection Officer”.

‍We expressly point out that when using the email address, the contents are not reviewed exclusively by our Data Protection Officer. If you wish to exchange confidential information, please first contact us via this email address and use the subject line “Confidential – Data Protection Officer”.

movingimage processes personal data under its own responsibility where such processing serves the administration of customer contractual relationships, communication, billing, the provision and protection of its own product access, error analysis, abuse detection, the technical stability of the products or the fulfilment of its own legal obligations.

To the extent that customers process personal data through the products, by uploading, storing, streaming, publishing, analysing or deleting data or content containing data, movingimage generally acts as a processor on behalf of the respective customer. The respective customer is responsible for such processing. In this respect, processing by movingimage is carried out based on a data processing agreement pursuant to Art. 28 GDPR and in accordance with the documented instructions of the customer. The legal bases for such processing are determined by the respective customer.

This applies in particular to content data provided or generated by the customer, recorded videos, livestream content, subtitles, chat and Q&A content, participant lists, viewer reports, as well as other data whose type, scope, purpose, retention period or access options are configured or determined by the customer within the respective product.

2. Purposes and Legal Bases of Processing under Own Responsibility

Where movingimage processes personal data under its own responsibility, the purpose of processing personal data is the provision, operation, use, administration, as well as the technical and content-related development of the movingimage products, insofar as legally permissible:

• VideoManager Pro
• CorporateTube
• VideoCreator Pro
• LiveStream Pro
• OneComms Pro
• other product modules provided by movingimage or offered in the future.

In addition, personal data is processed under movingimage’s own responsibility for user management, authentication, ensuring system security, error analysis, the fulfilment of contractual and legal obligations, billing, and communication with users.

Personal data is regularly processed based on Art. 6(1)(b) GDPR where such processing is necessary for the performance of a contract with the data subject or for the implementation of pre-contractual measures. Where processing serves to ensure the secure, stable and economical operation of the products, it is carried out based on Art. 6(1)(f) GDPR. Where a legal obligation exists, commercial, tax or VAT-related retention and documentation obligations or statutory cooperation or disclosure obligations towards authorities or courts, processing is carried out on the basis of Art. 6(1)(c) GDPR.

To the extent that movingimage processes personal data on behalf of the respective customer, processing is carried out by movingimage as a processor based on a data processing agreement pursuant to Art. 28 GDPR (see Section 1).

3. Categories of Data

In connection with the use of the products, movingimage processes, depending on the product, user role, configuration and booked additional functions, personal data of users on the customer side, administrators, editors, contact persons and individuals whose data is processed in connection with the use of the products.

In particular, the following categories of personal data are processed:

• Identification and contact data (e.g. name, email address, company affiliation),
• Account and authentication data (e.g. username, roles, permissions),
• Contract, customer and billing data (e.g. information relating to customer accounts, services and invoices),
• Usage and log data (e.g. login timestamps, upload timestamps, technical usage parameters),
• Technical data (e.g. IP addresses in log files, device and browser information),
• Communication and support data (e.g. contents of support requests, error messages),
• Content and metadata, insofar as these are provided or generated by users within the product.

The categories of data processed in individual cases depend on the respective product, the role of the data subject, the customer’s settings and the activated functions. Product-specific details regarding the categories of data processed and the relevant functions are set out in Section 5 of this Privacy Policy.

To the extent that movingimage processes personal data under its own responsibility, this relates to identification and contact data, account and authentication data, contract, customer and billing data, usage and log data, technical data as well as communication and support data. To the extent that personal data is uploaded, generated or otherwise processed within the products by customers or users, in particular content and metadata, movingimage generally processes such data as a processor on behalf of the respective customer.

Personal data is not processed for advertising or marketing purposes in connection with the use of the products. movingimage has no influence on whether special categories of personal data within the meaning of Art. 9 GDPR are verbally disclosed, visually displayed or otherwise processed in connection with livestreams, videos or other customer content. The respective customer is generally responsible for the content design and lawfulness of such content.

4. Retention Period

Personal data processed by movingimage under its own responsibility is stored only for as long as necessary for the respective purposes described above. Thereafter, we will delete the data without undue delay unless we require the data until the expiry of statutory limitation periods for evidentiary purposes in relation to civil law claims, due to statutory retention obligations, or where another legal basis under data protection law exists in the specific case for the continued processing of your data.

Where commercial and tax law retention periods must be observed, certain data may be retained for up to 10 years.

To the extent that movingimage processes personal data on behalf of the respective customer, the retention period is generally determined by the instructions and settings of the respective customer as well as by the provisions of the applicable data processing agreement. Depending on the product and function, the customer may determine which content is stored, how long it is retained and when it is deleted. Product-specific information regarding retention and deletion is set out in Section 5 of this Privacy Policy.

5. Specific Processing of Personal Data When Using Products

Depending on the product and the features enabled by the customer, personal data may be processed. The following sections provide an overview of the processing of personal data within the respective products and their specific functionalities.

5.1. VideoManager Pro (VMPro)

VideoManager Pro (VMPro) is a video asset management platform that enables customers to upload, organize, manage, enrich, distribute, and control access to video content and related metadata throughout its lifecycle.

‍5.1.1 Authentication/Login:
‍To use VMPro as an administrator as well as to access the video asset management platform as a user, registration in the product or a login is required. The type and scope of user authentication can be controlled by the administrator. There are various configuration options regarding which data is requested from users during login. A simple single sign-on process via the customer’s corporate account can be configured and/or a login via email + password authentication (movingimage user account). Depending on the administrator’s settings, this user account data may include:

• First name
• Last name
• Email address
• Company name
• Phone number

This account data is stored in the movingimage platform until the individual user is deleted or for a maximum of 1 month after the end of the contract.

‍5.1.2. Video on demand
‍The customer has the option to add metadata to videos stored in VideoManager Pro. If the customer decides to add metadata, the personal data contained in the video metadata is collected, processed, and stored in our web storage by movingimage for the purpose of fulfilling the contract. The type of personal data in the videos themselves or its metadata depends on the content of the video asset and are not determined by movingimage. All data related to a video are stored until the video is deleted permanently or for a maximum of 1 month after the end of the contract.

‍5.1.3. Subtitles & Transcripts
‍Personal data is collected during the use of the Subtitles and Transcripts Feature, if the Video contains personal data that is being transcribed by the tool (subservice provider: Azure). Which personal data is being transcribed thereby lays within the control and responsibility of the customer and cannot be controlled by movingimage. The transcribed personal data is stored for the same retention period as the video itself and can be manually deleted by the customer at any time.

‍5.1.4. Notifications
‍The customer has the option to configure email notifications to inform specific users about events within the platform, such as uploaded videos, monthly reports, expiring releases or scheduled deletions of assets. When such notifications are active, the email addresses of the specified recipients are used to deliver these notifications. Recipients email addresses are stored until the notification is deleted or for a maximum of 1 month after the end of the contract.

‍5.1.5. Smart upload (Upload forms)
‍The customer has the option to configure and use custom upload forms to let (external) users upload video and audio assets to VideoManager Pro. The customer can determine which inputs from uploaders are possible and who has access to these inputs. The type of personal data depends on the content of the web form; however, at a minimum, the email address used for authentication via Pin-registration is required to use these functions to ensure that only authorized users can access the web form. Uploaders email addresses are stored until the video is deleted or for a maximum of 1 month after the end of the contract.

Optionally, an approval process can be added to an upload form. If an upload process is configured to require approval, either the uploader or the platform administrator can define one or multiple approvers, depending on the configuration. In that case, the email addresses of the approvers are stored until the upload form and the video assets uploaded through this web form are deleted or for a maximum of 1 month after the end of the contract.

‍5.1.6. Deletion of personal data
‍The retention period and deletion of users, videos and video metadata are generally determined and administered by the respective customer. movingimage processes and stores personal data exclusively within the framework of the contractually agreed provision of the product and in accordance with the customer’s instructions. If a user account or content is deleted by the customer or the contractual relationship ends, personal data is deleted or returned in accordance with the contractual agreements and the data processing agreement, unless statutory retention obligations prevent this.

5.2. CorporateTube

CorporateTube enables customers to provide users with access to video content through a branded video portal. CorporateTube can be used as a private or public video portal depending on the customer configuration.

‍5.2.1. Authentication / Login
‍For a private CorporateTube portal, users must authenticate before they can access the portal and its video content. Depending on the customer setup, authentication may be handled through the customer’s corporate single sign-on and/or through a movingimage user account. During login, movingimage may process authentication and account-related data such as user ID, names, email address, company information, roles, permissions, access groups, session tokens, and refresh tokens. The exact data processed depends on the customer’s authentication configuration. Account and authentication data is stored until the user account is deleted or for a maximum of 1 month after the end of the contract.

‍5.2.2. Video Portal and Video Playback
Depending on the customer configuration, users may browse, search, filter, and play videos made available in CorporateTube. During portal usage and video playback, movingimage may process data that can contain personal data, such as:

• user ID,
• access permissions,
• video metadata,
• video title,
• description,
• channel assignment,
• playback information,
• technical player settings,
• and usage events.

The type of personal data contained in the videos themselves, in video metadata or in the titles/subtitles/descriptions depends on the content provided by the customer and therefore falls under the customer's responsibility. movingimage processes this data for the purpose of providing the contracted CorporateTube service. Video content and metadata are generally managed through VideoManager Pro and are stored until the video or metadata is deleted by the customer or for a maximum of 1 month after the end of the contract.

‍5.2.3. Permissions, Groups, Channels, and Access Control
‍CorporateTube can use permissions, groups, channels, and access rules to determine which users may access specific CorporateTubes, channels, or videos. The customer controls the configuration of these permissions. During access control checks, movingimage may process personal data such as user IDs, email addresses, roles, group assignments, permissions, access tokens, channel assignments, and video access rules. This data is processed to ensure that users can only access the content made available to them by the customer. Access control data is stored until the relevant user, group, permission, channel, or video is deleted, or for a maximum of 1 month after the end of the contract.

‍5.2.4. Search, Metadata, and Content Discovery
‍CorporateTube may allow users to search and discover videos using video titles, descriptions, metadata, labels, channels, languages, transcripts, or other configured search criteria. When search and discovery features are used, movingimage may process usage information that can contain personal data, such as:

• search queries,
• video metadata,
• user ID,
• access permissions,
• language settings,
• and technical information.

If video metadata or transcripts contain personal data, such personal data may also be processed as part of the search and discovery functionality.

The customer determines which metadata is added to videos and which content is made available in CorporateTube. Search and metadata-related data is stored for as long as the related video, metadata, or transcript exists, or for a maximum of 1 month after the end of the contract.

‍5.2.5. Analytics and Performance Measurement
‍CorporateTube may use analytics and performance tools to measure video usage, playback quality, and user interaction with the portal and player.

Depending on the configuration, CorporateTube may use third-party service providers such as NPAW or Youbora to process analytics and performance data. This may include:

• product usage information,
• device identifiers,
• session information,
• playback events,
• performance data,
• and technical player information.

CorporateTube may store analytics-related local storage items such as Youbora device UUID, account code, session data, host information, offline views, and session expiry information. These items are used to support analytics and performance measurement.

Analytics and performance data is processed for the purpose of contractual performance which can include:

• measuring usage,
• improving playback reliability,
• and providing reporting or quality insights.

5.2.6. Deletion of Personal Data
‍The retention period and deletion of users, access rights, video content, video metadata, analytics data, and CorporateTube configuration are generally determined and administered by the respective customer. movingimage processes and stores personal data within the framework of the contractually agreed provision of CorporateTube and in accordance with the customer’s instructions. If a user account, access permission, channel, video, metadata, or related content is deleted by the customer, or if the contractual relationship ends, personal data is deleted or returned in accordance with the contractual agreements and data processing agreement, unless statutory retention obligations prevent this.

5.3. Video Creator Pro (VCPro)

VC Pro is a video creation platform that enables customers to create, edit, organize, and manage video projects.

‍5.3.1. Authentication / Login
‍To use VCPro as an administrator or user of the video creation platform, registration or login is required. Depending on the customer's configuration, users may authenticate via the customer’s corporate single sign-on or via email and password using a movingimage user account. Depending on the configuration, the following personal data may be processed:

• user ID,
• names,
• email address,
• company information,
• account status,
• MFA configuration,
• login/session identifiers,
• OAuth tokens,
• and terms acceptance records.

VCPro uses technically necessary cookies, local storage, and session storage to support authentication, session continuity, token rotation, access control, and cross-context authentication between the dashboard and editor. Authentication-related data is processed by movingimage services such as user-service and access-service.

Account data is stored until the user is deleted or for a maximum of 1 month after the end of the contract. Session-related data is stored according to the applicable session or token lifetime. When a user account is deleted, the email address is replaced with a random @deleted.vcpro.movingimage.com address and the account is flagged for deletion.

5.3.2. Project Creation and Editing
‍Users can create video projects from scratch or from templates and add media, text, scenes, animations, fonts and other project elements. During project creation and editing, movingimage may process personal data within project titles, descriptions, metadata, uploaded assets, text content, images, videos, audio files, fonts, scene and object data, creator information, permissions, and project events. The type of personal data processed within a project depends on the input added by the customer or user. This may include personal data contained in uploaded videos, images, audio, text, or other assets. The customer remains responsible for the personal data contained in the project content. Project data is stored until the project is deleted by the customer or for a maximum of 1 month after the end of the contract.

‍5.3.3. Templates, Assets, and Workspace Settings
‍VCPro allows users to create projects from templates and to manage workspace-specific settings such as branding, fonts, preferences, roles, and permissions. Templates may include predefined layouts, scenes, placeholders, text fields, images, videos, fonts, colours, and other design elements. If personal data is entered into template placeholders or included in template assets, such data is processed for the purpose of creating and editing projects. Users may also upload and manage assets such as images, videos, audio files, and fonts. The personal data contained in uploaded assets depends on the input uploaded by the customer or user and are not determined by movingimage. Workspace, template, and asset data are processed by movingimage for the purpose of providing the VCPro service and are stored until deleted by the customer or for a maximum of 1 month after the end of the contract.

‍5.3.4. Rendering and Exporting
‍VCPro allows users to render and export video projects. During rendering, project content is processed to generate a final video output.

The following data may be processed:

• project content,
• uploaded media assets,
• text and scene content,
• render job metadata,
• user/account information,
• render status,
• error information,
• generated video output,
• and output file metadata.

Rendering is processed by movingimage backend services and selected subprocessors, including cloud infrastructure used for storage, rendering, logging, and security.

Rendered outputs are stored until deleted by the customer, until the related project is deleted, or for a maximum of 1 month after the end of the contract.

‍5.3.5. Third-Party Integrations and Publishing
‍VCPro may allow users to connect third-party platforms for importing assets, accessing stock media, or publishing/exporting generated video content. These integrations are initiated by the user or customer. Supported integrations may include cloud storage, DAM systems, stock providers, and publishing destinations such as YouTube, Facebook Pages, Instagram Business, Vimeo, LinkedIn, TikTok, Google Drive, OneDrive, Box, Bynder, HubSpot, Shopify, and similar services, depending on configuration. When such integrations are used, movingimage may process:

• OAuth tokens,
• asset metadata,
• file names,
• asset IDs,
• publishing destination metadata,
• video titles/descriptions,
• thumbnails,
• video files or URLs
• and platform-specific publishing settings.

Third-party integration tokens are stored until the user disconnects the integration, the token expires, the user account is deleted, or the contract ends. Data processed by the third-party platform is subject to the terms and privacy policy of the respective provider.

‍5.3.6. AI-Assisted Features
‍VCPro may provide AI-assisted video creation features, such as:

• script generation,
• text-to-video,
• webpage-to-video,
• automated scene or storyboard creation,
• voiceover,
• dubbing,
• transcription
• and platform-specific publishing settings.

depending on customer configuration and product availability. When users initiate AI-assisted features, movingimage may process user-provided prompts, text input, project content, uploaded assets selected by the user, generated scripts, generated scene/storyboard data, generated voiceover/audio/transcript data, user ID and project context. The personal data processed through AI-assisted features depends on the information entered or selected by the user. Where AI features rely on third-party subprocessors, the relevant content may be transmitted to such subprocessors for the purpose of generating the requested output.

Generated AI output is stored as part of the project or related project metadata until deleted by the customer, until the related project is deleted, or for a maximum of 1 month after the end of the contract.

‍5.3.7. Cookies, Client Storage, Monitoring, and Deletion
‍VCPro uses cookies, local storage, and session storage to provide essential platform functionality and improve the user experience.

Strictly necessary storage is used for:

• authentication
• session continuity,
• OAuth login,
• API authentication,
• token rotation,
• access control,
• and browser capability detection.

Functional storage may be used for cached profile information, workspace settings, branding preferences, font preferences, UI preferences, onboarding flags, and warning visibility settings. VCPro may also use analytics, error monitoring, and support tools to ensure product reliability, troubleshoot issues, and improve the user experience. Depending on the configuration, such tools may process personal data contained within:

• user IDs,
• browser metadata,
• stack traces,
• page views,
• events,
• IP address,
• page URL,
• email address,
• or other information submitted by the user.

The retention period and deletion of users, projects, assets, renders, and project metadata are generally determined and administered by the customer. movingimage processes and stores personal data exclusively within the framework of the contractually agreed provision of VCPro and in accordance with the customer’s instructions. If a user account, project, asset, integration, or workspace is deleted by the customer, or if the contractual relationship ends, personal data is deleted or returned in accordance with the contractual agreements and data processing agreement, unless statutory retention obligations prevent this.

5.4. LiveStreamPro (LSPro)

LiveStreamPro is a web-based live streaming and virtual event platform that enables customers to broadcast live events, record and provide on-demand content, enable live captions and facilitate audience interaction.

‍5.4.1. Authentication and Registration
‍Use of LSPro, both by administrators and by viewers accessing an event, requires registration within the product and/or user authentication via log-in. The type and scope of user authentication can be configured by the administrator.

Various authentication options are available, including a Single Sign-On (SSO) process using the customer's corporate account and/or a registration form within the product requiring users to provide information for log-in purposes. What personal data will be collected during the authentication process depends on the configuration selected by the administrator. Among others, the following personal data may be collected:

• Email address
• Name
• User ID
• Company name
• Department name
• Country
• Telephone number
• or other information submitted by the user.

As part of the authentication process, the customer may also choose to generate participant lists (containing email addresses or user IDs) for individual viewer events.

Alternatively, the customer may make an event accessible via a publicly available link. Where participants access an event through such public link, only pseudonymised usage data that does not directly identify individual participants will be collected.

‍5.4.2. Video Recording
‍The customer may choose to record a live stream and make the recording available as video-on-demand content to a group of recipients determined by the customer.

Where the customer elects to record the live stream, the personal data contained in the video content will be processed by movingimage on behalf of the customer for the purpose of providing the contracted services and stored within our web storage infrastructure. The categories of personal data contained in such recordings depend on the content of the live stream and are therefore outside the control and responsibility of movingimage. In connection with a live stream, viewer reports may optionally be generated and made available to the administrator. The customer (administrator) determines who is authorised to access such viewer reports. Viewer reports contain pseudonymised usage data that does not permit the direct identification of individual participants. If the customer decides not to record the live stream, movingimage will not collect or process any additional personal data relating to the live stream beyond the data processed for the authentication and registration of administrators and viewers.

‍5.4.3. Live Captions
‍LSPro offers customers the option to add a live captioning feature. Where enabled, captions are generated in real time during the live stream and displayed to viewers.

For the provision of this functionality, movingimage engages DeepVA as a sub-processor. DeepVA processes personal data on behalf of movingimage under a data processing agreement pursuant to Article 28 GDPR.

DeepVA generates the live captions and, following the event, creates a file containing the generated captions. This file is made available to movingimage and is deleted by DeepVA no later than 30 days after the event.

The temporary storage of the caption file is necessary to enable movingimage to provide the stream subsequently as a captioned video where the customer has chosen to record the event and make it available as video-on-demand content. DeepVA does not receive information regarding whether a recording of the live stream is planned. Consequently, the caption file is generated irrespective of whether the live event is recorded.

By enabling the live captioning feature, the customer acknowledges that personal data communicated verbally during the live stream may be transcribed into captions and processed and stored by movingimage through its sub-processor DeepVA. The categories of personal data contained in such captions depend entirely on the content of the live stream and are therefore outside the control and responsibility of movingimage.

movingimage has no influence over whether special categories of personal data within the meaning of Article 9 GDPR are disclosed verbally during the live stream.

‍5.4.4. Chat and Q&A Functions
‍The customer may enable and use chat and Q&A functionalities before, during, or after a live stream. The customer may determine which inputs viewers are permitted to submit and which persons are authorised to access such inputs.

The categories of personal data processed depend on the content submitted by viewers. However, the viewer's registered email address is required as a minimum for the use of these functionalities. Chat and Q&A content is processed by movingimage on behalf of the customer for the purpose of providing the requested event functionality.

The customer remains solely responsible for the content, lawfulness, and compliance of any information submitted by viewers through the chat and Q&A functionalities.
‍
‍5.4.5. Retention and Deletion of Personal Data
‍The retention periods and deletion of viewer reports, participant lists, and recorded video content are determined and administered by the respective customer.

movingimage processes and stores personal data exclusively for the purpose of providing the contracted services and in accordance with the customer's documented instructions.

Upon deletion of an event or related content by the customer, or upon termination of the contractual relationship, personal data will be deleted or returned in accordance with the applicable contractual arrangements and the data processing agreement, unless statutory retention obligations require continued storage.

5.5. OneComms Pro (OCP)

OneComms Pro is a cloud-based, AI-powered solution (Agentic AI) for corporate communications that orchestrates the entire communication workflow, from planning and content creation to asset review.

‍5.5.1. Authentication/Login:
‍The customer opens OneComms Pro in the browser, signs in via single sign-on or a user account (email and password).

To use OCP, authentication via the movingimage identity service is required. Authentication is handled through movingimage's central identity provider using the OpenID Connect (OIDC) standard (single sign-on). Single sign-on via the customer's own corporate account (an external identity provider) can be configured, so that users authenticate with their existing company credentials; alternatively, users authenticate against a user account in movingimage's identity provider. Login credentials (e.g. passwords) are managed exclusively by the identity provider (either movingimage or external) and are not stored within OCP.

At login, the following account data is processed to identify the user and control access:

• First name
• Last name
• Email address
• A unique user identifier
• The user's role within the customer account (e.g. member or administrator)
• Profile picture

5.5.2. Campaign Creation and Provision of Context Information
‍The customer may create communication campaigns and provide the information on which the functions of OCP operate.

The following information may be provided:

• Campaign title
• Description
• Communication type
• Target audience
• Communication objective
• Sensitivity level
• Optional start and end date

In addition, the customer may upload reference documents (e.g. DOCX, PDF, TXT, XLS or XLSX files) and provide additional context information in free-text fields. The information entered into free-text fields and the uploaded documents may contain personal data. The type and scope of any personal data contained therein are determined solely by the customer and the content provided. The uploaded documents are stored by movingimage in a storage infrastructure within the European Union (Microsoft Azure Blob Storage, West Europe region). For the provided content to be processed by the AI and used as context, the text of the uploaded documents is extracted and stored together with vector representations (embeddings) derived from it in the product’s processing database. The storage and deletion of campaigns, context documents and additional context information are managed by the customer. Deletion requests may be submitted through movingimage support and will be carried out in accordance with the customer’s documented instructions.

‍5.5.3. AI-Assisted Generation of Core Messages and Communication Content
‍OCP uses generative AI to create drafts of core messages, key facts and additional communication content. After the customer has provided the campaign context, the customer may initiate the creation of a core message, refine it using various editing functions and generate communication content from it, such as email drafts or intranet articles.

For this functionality, movingimage works with the provider Microsoft (Microsoft Azure OpenAI Service). The service is operated within movingimage’s Microsoft Azure tenant in the European Union (West Europe region). The following information may be processed for the generation and further development of content:

• Campaign settings
• Additional context information
• Extracted content of uploaded documents
• Generated core messages
• Key facts
• Existing communication content
• User chat messages and inputs

Whether and which personal data is contained in such content is determined solely by the customer. Generated content is retained in accordance with the retention period of the respective campaign.

‍5.5.4. Review by AI Agents
‍OCP enables the review of core messages and communication content by predefined AI agents.

These agents may, for example, simulate perspectives from Legal, Human Resources or Brand Communications and provide suggestions for revision. The user may accept, edit or reject such suggestions. For these reviews, the campaign context, the relevant content and the associated key facts are transmitted to, and processed by, the AI service described in Section 5.5.3. The AI agents used represent virtual role models and are likewise provided through Microsoft Azure OpenAI Service. The product is designed in such a way that additional agents and data sources may be integrated in the future, for example from the customer’s organisation or from external service providers. Such integrations are currently not active. At present, no customer data is transmitted to external agent systems or external communications agencies.

‍5.5.5. Communication Content and Version History
‍Various communication content may be created from an approved core message, for example email announcements or FAQ documents.

Such content may be edited, further developed and managed through a version history. Every modification to a core message or communication content is stored as a separate version, allowing previous versions to be restored. Communication content may contain personal data depending on the content of the respective campaign.

Version data is stored in the product database of movingimage within the European Union (Microsoft Azure, West Europe region) and retained for the duration of the respective campaign or communication content. Communication content may be deleted through the user interface. For technical and operational reasons, deleted content may temporarily remain stored until final deletion is carried out in accordance with the customer’s instructions and the applicable deletion processes.

‍5.5.6. Deletion of Personal Data
‍The retention period and deletion of campaigns, context documents, generated core messages, communication content and the associated versions are generally determined and managed by the respective customer. Personal data is retained for the period specified by the customer and is deleted or returned to the customer upon the customer’s instruction, upon termination of the contractual relationship, or in accordance with the applicable contractual arrangements and the Data Processing Agreement.

6. Disclosure of Data to Third Parties

movingimage does not disclose personal data to third parties unless such disclosure is necessary for the performance of a customer’s request (Art. 6(1)(b) GDPR), the customer has previously given their explicit consent (Art. 6(1)(a) GDPR), or there is a legal obligation to disclose the data (Art. 6(1)(c) GDPR). To the extent that movingimage engages service providers for the execution and handling of processing activities, such engagement shall take place in compliance with the applicable data protection laws, in particular the GDPR and the German Federal Data Protection Act (Bundesdatenschutzgesetz).

6.1 Disclosure to Third-Party Service Providers

Personal data will only be disclosed to third-party service providers to the extent necessary for the provision, administration, protection or operation of the products, where a data subject has given consent, or where the customer has activated a corresponding function or integration. To the extent that service providers process personal data on behalf of movingimage, they are engaged based on a data processing agreement pursuant to Art. 28 GDPR. To the extent that recipients process personal data under their own responsibility, their respective privacy policies shall apply in addition.

Recipients may include:

• IT and hosting service providers, data centres, content delivery networks and cloud providers,
• providers of support, monitoring, analytics and security services,
• providers of integrations activated by the customer or user,
• payment, billing and communication service providers as well as financial institutions, insofar as required for contract administration,
• attorneys, tax advisors, auditors and other advisors,
• User chat messages and inputs

Where we disclose data to our service providers, they may use such data solely for the performance of their respective tasks. The service providers have been carefully selected and engaged by us. They are contractually bound by our instructions. Appropriate agreements are entered into with external advisors and auditors to ensure the confidentiality of the data.

The specific service providers used may vary depending on the product, the selected functions and the activated integrations. Customers can obtain further information about the respective subprocessors from the contractual documentation, in particular the applicable data processing agreement and the current list of subprocessors.

6.2 Disclosure of Data to movingimage Partners

If a customer places an order through a partner of movingimage, the data required for the execution of the order will be transferred to that partner. In addition, the data required for the execution of the order will be displayed to the partner within the partner’s personal/restricted area. Such personal data will not be made accessible to any other persons at any time. The partner may use the personal data of the end customer transmitted by movingimage in this context solely for the performance, administration and execution of the respective contractual relationship.

6.3 Disclosure of Data to Public Authorities

Where a legal obligation exists or an administrative or judicial order has been issued, movingimage may be required to disclose personal data to authorities, courts or other public bodies. In individual cases, this may also include the provision of information concerning subscriber data and/or usage data, insofar as such disclosure is legally permissible and necessary.

6.4 Use of Google API Services in VideoCreator Pro

VideoCreator Pro offers the possibility of integrating certain Google services. Such integration is only used if a user actively decides to connect or use the respective Google service.

We access Google user data solely to provide the specific functionality requested by the user. We do not use Google user data for advertising purposes.

‍6.4.1 Google Sign-In
‍If a user chooses to sign in with Google, we access basic profile information from the user’s Google account, including the email address and name. We use this information solely to authenticate the user and to create, manage or maintain the user account for our service. Google Sign-In is optional.

‍6.4.2 YouTube API Services
‍If a user chooses to connect a YouTube account, we use the YouTube API solely to enable the user to publish or manage videos on the user’s own YouTube channel through our service. Depending on the action initiated by the user, this may include channel information, permissions required for uploading and publishing videos, playlist-related data, thumbnails and information regarding video processing status. These actions are initiated by the user. Our service itself is used to create and edit videos internally.

‍6.4.3 Google Drive API
‍If a user chooses to connect Google Drive, we use the Google Drive API to export files from our service to the user’s own Google Drive account. This may include rendered video files, project files, media assets and related file metadata. Access is limited to what is required to create and upload such files. We do not browse, read or monitor unrelated content stored in the user’s Google Drive account.

‍6.4.4 Google Sheets API
‍If a user chooses to connect Google Sheets, we use the Google Sheets API to import data from spreadsheets expressly selected by the user, for example for template automation or other data-driven content functions. In this context, we may access spreadsheet content, spreadsheet metadata, cell values and formatting information relevant to the imported content. Access is limited to the read access required for the requested functionality.

‍6.4.5 Google Cloud Translation API and Google Cloud Text-to-Speech API
‍We may use the Google Cloud Translation API and the Google Cloud Text-to-Speech API to provide translation and speech generation functionalities within our service. For these functionalities, we do not access Google user account data via user OAuth. Instead, these services process only the text content that the user expressly submits for translation or speech generation.

‍6.4.6 How We Use Google User Data
‍Google user data is used exclusively:

• to authenticate users who choose Google Sign-In,
• to upload or manage videos on a user’s own YouTube channel where linked by that user,
• to export files to a user’s own Google Drive account where linked by that user,
• to import user-selected data from Google Sheets,
• to provide translation or text-to-speech functionalities for text expressly submitted by the user.

We do not use Google user data to sell data to third parties, deliver advertising, create advertising profiles or access unrelated content within a user’s Google account beyond what is required for the respective functionality.

‍6.4.7 Retention and Disclosure
‍Google user data is retained only for as long as necessary to provide the respective functionality, maintain the user account, comply with legal obligations, resolve disputes, enforce agreements or ensure the security and integrity of our service. Google user data may only be disclosed where necessary to provide the requested integration, operate and secure the service, or where required under applicable law. We do not sell Google user data to third parties.

‍6.4.8 International Data Transfers
‍Depending on how the respective Google services are provided, Google user data may be processed in countries outside the user’s country of residence. Where required, appropriate safeguards will be implemented in accordance with applicable data protection law.

‍6.4.9 User Choice and Revocation
‍The use of Google integrations is optional. Users may stop using a Google integration at any time by disconnecting the respective Google account or ceasing to use the relevant integration functionality. In addition, users may, where applicable, manage or revoke permissions granted to their Google account through their Google account settings.

Further information on how Google processes personal data can be found in Google’s Privacy Policy: https://policies.google.com/privacy?hl=en.

6.5. Services of Meta Platforms (Facebook & Instagram) in VCPro

Our VideoCreator Pro application uses interfaces (“APIs”) and authentication services of Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”), in particular Facebook Login and Instagram APIs, to provide certain functions of our platform.

‍6.5.1 Collection of Data via Facebook and Instagram
If users voluntarily connect their account to our application via Facebook or Instagram or sign in using Facebook, we may, depending on the respective use case and granted permissions, access the following data:

• Name
• Email address (when using Facebook Login)
• Public profile information
• Instagram account information (when connecting an Instagram Business or Creator account via APIs)

Access is granted solely within the scope of the permissions approved by Meta.

‍6.5.2 Data Processing
The processing of personal data by Meta is carried out in accordance with Meta’s respective privacy policies, over which we have no influence.

Further information regarding Meta’s processing of personal data can be found at: https://www.facebook.com/privacy/policy.

The data provided via Meta is processed by movingimage based on the user’s voluntary consent solely for the following purposes:

• Authentication and user login via Facebook Login
• Connection, administration and use of Facebook and Instagram accounts within our application
• Provision of platform-specific functionalities, such as analytics, content usage or publishing workflows (where activated)

No processing for any other purposes takes place.

‍6.5.3 Storage and Security
The data obtained from Meta is stored within our systems and protected by appropriate technical and organisational measures. Access is restricted to authorised persons and is granted solely for the respective defined purpose.

‍6.5.4 Disclosure of Data and Third Parties
Data collected through Facebook or Instagram is used exclusively within our platform. Such data is not disclosed to unauthorised third parties and is not sold. Where necessary, data may be processed by carefully selected service providers that are contractually required to comply with applicable data protection requirements. Meta processes personal data under its own responsibility in accordance with its own privacy policies.

‍6.5.5 User Rights and Data Deletion
Users have the right at any time:

• to request access to their personal data,
• to request the rectification of inaccurate data,
• to request the deletion of their personal data,
• to withdraw any consent granted with effect for the future.

Requests relating to the exercise of these rights and the deletion of data provided via Facebook or Instagram may be sent to the following contact address:
‍datarequests@support.facebook.com

‍Alternatively, users may disconnect their connection with Meta at any time through the account settings of their respective user account.

7. Transfer of Data to Third Countries

We may use services whose providers are located, in part, in so-called third countries (outside the European Union or the European Economic Area) or which transfer personal data to such countries, i.e. countries whose level of data protection does not correspond to that of the European Union.

Where an adequacy decision of the European Commission pursuant to Art. 45 GDPR exists for a third country, we rely on such adequacy decision for the transfer. In the case of transfers to the United States, this applies only where the respective recipient is certified under the EU-U.S. Data Privacy Framework.

Where no adequacy decision has been issued for the relevant country, we have implemented appropriate safeguards to ensure an adequate level of protection for any data transfers. These safeguards include, among others, the Standard Contractual Clauses of the European Union or binding corporate rules (Art. 46 GDPR).

Where this is not possible, we rely on the derogations set out in Art. 49 GDPR, your explicit consent or the necessity of the transfer for the performance of a contract or the implementation of pre-contractual measures.

Where a transfer to a third country is envisaged and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyse it, and that the enforceability of your data subject rights may not be guaranteed. Where your explicit consent is obtained, you will also be informed of these risks.

8. Cookies and Technical Measures in the Products

When using movingimage products, cookies, local storage, session storage or comparable technologies may be used depending on the product, configuration and activated functions. These technologies may be required to provide basic product functionalities, including authentication, session management, access control, security, content playback, technical stability and error analysis.

8.1 Cookies

Cookies are small text files that are either stored temporarily in memory (so-called session cookies) or permanently on the hard drive (so-called permanent cookies). Session cookies stored only in memory are automatically deleted when the internet browser is closed. The use of such technologies may involve the storage of pseudonymised identifiers or technical identifiers, but under no circumstances are programs executed on the user’s computer or computer viruses transmitted. Technically necessary session cookies are generally deleted at the end of the session unless a different retention period is specified.

8.2 Legal Bases and Withdrawal of Consent

Access to information stored on an end user’s device or the storage of information on such device by means of strictly necessary technologies takes place based on Section 25 (2) TDDDG. Where personal data is processed in this context, such processing is carried out, depending on the specific processing activity, based on Art. 6(1)(b) or Art. 6(1)(f) GDPR to provide the core functionalities of our products. Access to and storage of information on the end user’s device is strictly necessary in these cases and is carried out based on the national laws implementing the ePrivacy Directive of the EU Member States, in Germany pursuant to Section 25 (2) TDDDG.

Where personal data is transferred to third countries, we refer, including with regard to any associated risks, to Section 7 “Transfer of Data to Third Countries” (see above).

All other non-essential (optional) tools that provide additional functionalities are used based on your consent pursuant to Art. 6(1)(a) GDPR. Access to and storage of information on the end user’s device is then carried out based on the national laws implementing the ePrivacy Directive of the EU Member States, in Germany pursuant to Section 25 (1) TDDDG. Personal data will only be processed through such tools where we have obtained your prior consent. Any consent granted may be withdrawn at any time with effect for the future.

Withdrawal of Your Consent or Change of Your Selection

You may withdraw your consent for optional tools, including their storage of and access to information on your device, the processing of your personal data and the transfer of your data to third countries, at any time with effect for the future. To do so, when using the product, either navigate to your account settings and select "Manage my cookie settings" from the dropdown menu or click the cookie settings link at the bottom of the page to revoke existing consent. There you may also change your selection regarding the tools for which you wish to provide consent and obtain additional information about the tools used. Alternatively, for certain tools you may exercise your withdrawal directly with the respective provider.

9. Data Security

movingimage implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access. Such measures are designed and continuously reviewed considering the state of the art, implementation costs, the nature, scope, circumstances and purposes of the processing, as well as the respective risks. Absolute protection of personal data against unauthorised access by third parties (e.g. hackers) cannot be guaranteed according to the current state of the art. movingimage shall therefore not be liable for any unauthorised access to personal data by third parties who unlawfully obtain access to stored data through the deliberate circumvention of firewalls or other security measures implemented to prevent unauthorised access.

10. Server Log Files (Logs)

For technical reasons, server log files and comparable protocol data may be processed when using the products. This may include IP addresses, date and time of access, accessed resources, volume of data transferred, referrer URLs, browser and operating system information, as well as technical event and error data. The processing is carried out for the provision, security, stability, error analysis and abuse detection of the products. The legal basis is Art. 6(1)(f) GDPR to the extent that movingimage processes such data under its own responsibility. Our legitimate interest lies in the secure and stable provision of the products.

To the extent that log data is processed on behalf of a customer, such processing is carried out based on the applicable data processing agreement and in accordance with the customer’s instructions. Log data is stored only for as long as necessary for the purposes described above. Unless a longer retention period is required due to specific security incidents, error analyses, legal obligations or for the establishment, exercise or defence of legal claims, log data is regularly deleted or anonymised after 30 days.

11. Data Subject Rights

In this section, we provide information about the applicable data protection rights available to data subjects.

11.1 Overview of Your Rights

Subject to the applicable statutory requirements, you are entitled at any time to exercise the data subject rights set out in Art. 7(3) and Arts. 15–22 GDPR, including:

• the right to withdraw any consent you have granted (Art. 7(3) GDPR);
• the right to object to the processing of your personal data (Art. 21 GDPR);
• the right to obtain access to your personal data processed by us (Art. 15 GDPR);
• the right to obtain rectification of inaccurate personal data stored by us (Art. 16 GDPR);
• the right to obtain erasure of your personal data (Art. 17 GDPR);
• the right to obtain restriction of processing of your personal data (Art. 18 GDPR);
• the right to data portability of your personal data (Art. 20 GDPR);
• the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you, including, where applicable, the right to obtain human intervention by the controller, to express your point of view and to contest the decision (Art. 22 GDPR).

To exercise the rights described above, you may contact us at any time using the contact details provided above. This also applies if you wish to obtain copies of safeguards demonstrating an adequate level of data protection. Where the respective legal requirements are met, we will comply with your request.

To the extent that a request relates to personal data that movingimage processes exclusively on behalf of a customer, we will forward the request to the respective customer or coordinate its handling with the customer where required under the applicable data processing agreement.

Requests relating to the exercise of data protection rights and our responses thereto may be retained for documentation purposes to the extent necessary to comply with statutory accountability obligations or for the establishment, exercise or defence of legal claims.

The legal basis for such processing is Art. 6(1)(f) GDPR, based on our interest in defending against potential civil law claims pursuant to Art. 82 GDPR, avoiding administrative fines pursuant to Art. 83 GDPR, and fulfilling our accountability obligations under Art. 5(2) GDPR.

movingimage points out that, due to caching systems and the use of proxy servers, deleted data may in certain circumstances remain accessible for a limited period of time.

11.2 Right to Withdraw Consent and Right to Object

11.3 Right to Lodge a Complaint

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). You may exercise this right, for example, before a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement. In Berlin, where we are based, the competent supervisory authority is:

‍Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59-61
10555 Berlin
Germany

12. Use of Artificial Intelligence

Where Artificial Intelligence is used within movingimage products, the separately established terms and conditions set out in the “Artificial Intelligence Addendum” shall apply in addition. The Artificial Intelligence Addendum is available at https://www.movingimage.com/gtc/ai-addendum.

13. Enforcement and Compliance with this Privacy Policy

movingimage shall continuously maintain the standards set out in this Privacy Policy and will continue to work on the ongoing improvement of data protection practices in the future.

14. Amendments to this Privacy Policy

As movingimage’s offerings are subject to continuous change, it may become necessary to introduce new provisions and/or amendments to this Privacy Policy. The same applies in the event of new or amended applicable legal requirements which may necessitate a corresponding update.

Berlin, July 2026

General Terms and Conditions of Business

• ‍Terms and Conditions of Use and Licensing of the VideoManager‍
  
• General Terms and Conditions of movingimage EVP GmbH
• Addendum on Artificial Intelligence of movingimage EVP GmbH
• ‍Contractual conditions for the production of videos or other multimedia products
• ‍Privacy Policy of movingimage EVP GmbH