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1# Privacy Policy for GUID.AI
Last Updated: August 18, 2026
Element colors Electronic Entertainment Limited ("we," "us," "our," or the "Company") is committed to protecting and respecting your privacy. This Privacy Policy ("Policy") explains how we collect, use, disclose, and safeguard your information when you access or use our website GUID.AI (the "Platform"), including our web application, mobile applications, APIs, and all related services (collectively, the "Services").
Please read this Policy carefully. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the practices described in this Policy. If you do not agree with this Policy, please do not use the Platform.
This Policy is designed to comply with the United Kingdom General Data Protection Regulation ("UK GDPR"), the UK Data Protection Act 2018 ("DPA 2018"), and applicable data protection laws in other jurisdictions where we operate.
Company Information:
| Field | Details |
|---|---|
| Company Name | Element colors Electronic Entertainment Limited |
| Registration Number | 13067695 |
| Registered Address | 19H MAXGRAND PLAZA NO. 3 TAI YAU STREET SAN PO KONG KL, Hong Kong |
| Platform | GUID.AI |
For the purposes of the UK GDPR and DPA 2018, the Company is the data controller of your personal data.
II. Scope of Application
This Policy applies to all personal data processed by Element colors Electronic Entertainment Limited in connection with the Platform and Services, including but not limited to:
- Accessing and browsing the GUID.AI website and web application;
- Using our mobile applications (iOS, Android, or other platforms);
- Registering and maintaining a user account;
- Using AI features, including AI chat, image generation, text-to-video, voice cloning, video studio, and Apps tools;
- Browsing the Inspiration Square;
- Topping up your Wallet, making purchases, or earning revenue through our Creator Program;
- Using our API services and developer integrations, including Skills and Model Context Protocol ("MCP") integrations;
- Participating in referral and reward programs; and
- Any other interactions with the Platform, our communications, or customer support.
This Policy does not apply to third-party websites, services, or applications that you may access through links on the Platform, except as described in Section XIV.
III. Information We May Collect and Process
We may collect and process the following categories of personal data:
3.1 Account Registration and Login
When you register an account or log in, we may collect:
- Identity Information: Your name, username, display name, email address, and password (stored in encrypted/hashed form). If you register or authenticate via third-party social login providers (e.g., Google, Apple, Facebook, WeChat), we receive your name, email address, and unique user identifier from that provider.
- Contact Information: Email address, and optionally your phone number.
- Profile Information: Profile picture, bio, and other optional information you choose to provide.
3.2 Identity Verification
In certain circumstances, we may require identity verification, including:
- Government-issued identification documents (passport, national ID card, driver's licence);
- Proof of address (utility bill, bank statement);
- Selfie or live photo verification;
- Business registration documents (for enterprise/API accounts); and
- Know Your Customer ("KYC") information required for regulatory compliance, particularly for Wallet top-ups,Creator Program participation, or large-value transactions.
Identity verification data is processed to comply with anti-money laundering ("AML"), counter-terrorism financing ("CTF"), and other applicable regulations. This data is retained securely and used only for verification and compliance purposes.
3.3 Content Data
As a generative AI platform, the nature of content data on GUID.AI is distinct from conventional platforms:
(a) User Inputs (Prompts and Instructions): When you interact with AI features, we collect the text prompts, instructions, parameters, and any files (images, audio, video, documents) you submit as inputs to our AI models.
(b) AI-Generated Content: Content generated by the Platform's AI services (text, images, video, audio, code, or other outputs) is created based on your inputs. All AI-generated content produced on the Platform is identified and disclosed as AI-generated in accordance with applicable regulations and our Acceptable Use Policy. This disclosure may include:
- Visible watermarks or labels on AI-generated images and videos;
- Metadata tags (e.g., C2PA, EXIF, or other provenance standards) embedded in AI-generated files;
- Clear UI indicators in the content display interface; and
- Exported content headers or footers where technically feasible.
(c) User-Uploaded Content: Any content you upload to the Platform, including to the Inspiration Square, Apps, or your personal workspace, is stored and processed as described in this Policy.
(d) Voice and Biometric Data: If you use voice cloning or voice synthesis features, we collect and process your voice recordings and vocal biometric characteristics. This data is used solely to generate the requested voice outputs. Voice cloning data is treated as special-category biometric data and is processed only with your explicit consent.
(e) Image Data: If you use image processing features, we process images you upload. Such data is used only for the requested transformation and is not retained beyond the processing session unless you explicitly save the result to your account.
3.4 Wallet, Top-Ups, Orders, and Transactions
When you use Wallet, top-up, purchase, or transaction features, we may collect:
- Payment instrument details (credit/debit card numbers, bank account information, or third-party payment provider tokens — note: we do not store full card numbers; these are handled by our PCI-DSS-compliant payment processors);
- Transaction records (amounts, dates, descriptions, transaction IDs);
- Billing address and invoicing information;
- Cryptocurrency wallet addresses (where applicable);
- Refund and dispute records; and
- Creator Program earnings, referral rewards, and withdrawal records.
3.5 API and Developer Usage
For users accessing our Services via API or developer integrations (including Skills and MCP integrations), we may collect:
- API keys, access tokens, and authentication credentials;
- Developer workspace configurations;
- API request and response logs (excluding the content of user prompts and AI outputs, unless you opt in to enhanced logging);
- Integration endpoints, callback URLs, and webhook configurations; and
- Usage metrics, rate limits, and error logs.
3.6 Device, Log, and Runtime Information
We automatically collect certain information when you access the Platform, including:
- Device Information: Hardware model, operating system and version, browser type and version, screen resolution, and device identifiers (e.g., advertising ID, device fingerprint);
- Log Data: IP address, access times, pages viewed, referral URLs, and navigation paths;
- Runtime Data: Performance metrics, error logs, crash reports, and feature usage statistics; and
- Location Data: General location inferred from IP address (country, region, city level). We do not collect precise GPS location unless you explicitly grant such permission.
3.7 Third-Party Services and Upstream AI Model Providers
The Platform integrates with multiple upstream AI model providers to deliver its services. When you submit a prompt or input to the Platform, your input data may be transmitted to and processed by these third-party providers. This has important privacy implications:
(a) Text/Chat Model Providers:
Upstream providers for text and chat capabilities include U.S.-based providers (OpenAI, Google, Anthropic) and leading Chinese AI providers including DeepSeek, Alibaba Cloud (Qwen series), MiniMax, Moonshot AI (Kimi series), and others. Representative models include the OpenAI GPT series, Google Gemini series, Anthropic Claude series, and models from the aforementioned Chinese providers.
The specific models available on the Platform are subject to change as we continuously expand and update our model offerings. Please refer to the model selection interface on the Platform for the most current list of available models.
(b) Image Model Providers:
Upstream providers for image generation capabilities include Black Forest Labs (United States/Germany), Stability AI (United Kingdom), ByteDance/Volcano Engine (Seedream), OpenAI (United States), Ideogram AI (Canada), and others. Representative models include Flux, Stable Diffusion, Seedream, DALL-E, and Ideogram.
The specific models available on the Platform are subject to change as we continuously expand and update our model offerings. Please refer to the model selection interface on the Platform for the most current list of available models.
(c) Video Model Providers:
Upstream providers for video generation capabilities include Google (United States), Runway AI (United States), Stability AI (United Kingdom), and leading Chinese AI providers including Kuaishou Technology (Kling series) and others. Representative models include Veo, Runway Gen-3, Stable Video Diffusion, and Kling.
The specific models available on the Platform are subject to change as we continuously expand and update our model offerings. Please refer to the model selection interface on the Platform for the most current list of available models.
(d) Audio/Voice Model Providers:
Upstream providers for audio and voice capabilities include Microsoft (United States), Google (United States), ElevenLabs (United States/Poland), and proprietary voice cloning models (see Section 3.3(d)).
The specific models available on the Platform are subject to change as we continuously expand and update our model offerings. Please refer to the model selection interface on the Platform for the most current list of available models.
(e) Code Model Providers:
Code generation capabilities are powered by leading text and chat models, including providers such as Anthropic (United States), OpenAI (United States), and leading Chinese AI providers including DeepSeek and Alibaba Cloud (Qwen Coder series), among others.
The specific models available on the Platform are subject to change as we continuously expand and update our model offerings. Please refer to the model selection interface on the Platform for the most current list of available models.
Important Privacy Implications:
- Data Transmission: Your prompts and inputs are transmitted to the servers of these upstream providers for processing. Each provider is subject to its own privacy policy and data handling practices.
- No Training on User Data: We configure our integrations with upstream providers such that user prompts and generated outputs are not used to train or fine-tune the underlying AI models, to the extent permitted by the provider's terms and our technical controls. However, certain providers may retain inputs temporarily for abuse monitoring or regulatory compliance.
- Provider Privacy Policies: We encourage you to review the privacy policies of the upstream providers whose models you use. Key links are available upon request or in our documentation.
- Model Availability: The specific models available on the Platform may change over time. We reserve the right to add, remove, or replace models. Material changes to the model provider landscape will be reflected in updated versions of this Policy.
IV. How We Use This Information
We use the information collected under Section III for the following purposes:
- Service Delivery: To provide, maintain, and improve the Platform and Services, including AI model inference, content generation, and user experience optimization.
- Account Management: To create, administer, and secure your account, authenticate your identity, and provide customer support.
- Transaction Processing: To process Wallet top-ups, purchases, refunds, Creator Program payments, and referral rewards.
- Content Moderation: To detect and prevent violations of our Terms of Service, Acceptable Use Policy, and applicable laws, including but not limited to prohibited content such as CSAM (child sexual abuse material), hate speech, violence, and illegal content. Content moderation may involve automated scanning, human review, and reporting to law enforcement where required.
- AI Output Quality: To monitor and improve the quality, safety, and reliability of AI outputs, including bias detection, hallucination reduction, and safety alignment.
- Security and Fraud Prevention: To detect, investigate, and prevent fraud, abuse, unauthorized access, and security threats.
- Communication: To send you service-related notices, updates, marketing communications (with your consent where required), and respond to your inquiries.
- Analytics and Improvement: To analyze usage patterns, develop new features, and improve Platform performance and user experience. Analytics data is aggregated and anonymized where possible.
- Legal Compliance: To comply with applicable laws, regulations, legal processes, and regulatory requirements, including AML/CTF obligations.
- Creator Program: To administer the Creator Program, calculate revenue shares, and facilitate payments to creators.
- Referral Program: To track and administer referral rewards and incentive programs.
V. Special Notice Regarding AI Services and Upstream Models
Given that GUID.AI is an AI aggregation, creation, and access platform, the following special disclosures apply:
5.1 AI Content Generation and Disclosure
All content generated through the Platform's AI services is machine-generated and may not accurately reflect reality. We implement the following disclosure measures:
- Visual Content: AI-generated images and videos are labeled with visible watermarks and/or metadata markers indicating AI origin, in compliance with applicable regulations and industry standards.
- Text Content: AI-generated text outputs are presented within clearly marked AI interaction interfaces.
- Audio Content: AI-generated voice and audio outputs are identified as synthetic/synthesized within the Platform interface.
- Provenance Standards: Where technically feasible, we embed C2PA (Coalition for Content Provenance and Authenticity) or equivalent provenance metadata in AI-generated content files.
Users are responsible for appropriately disclosing the AI-generated nature of content they share or distribute outside the Platform.
5.2 Upstream Model Provider Data Processing
As described in Section 3.7, your inputs to AI services are processed by upstream model providers located in various jurisdictions. Each provider:
- Is a separate and independent data controller or processor;
- Is subject to the data protection laws of its own jurisdiction;
- Has its own privacy policy governing the processing of data it receives;
- May be located outside the UK/EEA, triggering cross-border data transfer mechanisms (see Section XIII); and
- May be required by applicable law to process, retain, or disclose data for law enforcement, national security, or regulatory purposes.
We have conducted due diligence on our upstream providers and maintain data processing agreements where required. However, we cannot guarantee that upstream providers will not change their data practices. We monitor provider terms and will update this Policy as warranted.
5.3 Content Moderation and Privacy
To maintain a safe and compliant Platform, we implement content moderation measures, which may include:
- Automated Scanning: AI-based content filters that scan user inputs and AI outputs for prohibited content categories (e.g., CSAM, extreme violence, illegal content, hate speech). These scanners process content in real-time and may store flagged content for review.
- Human Review: Content flagged by automated systems or reported by users may be reviewed by trained moderators.
- Hash-Based Detection: We may use perceptual hashing and other fingerprinting technologies to detect known prohibited content.
Content moderation data (including scanned content, flags, and review outcomes) is processed on the basis of our legitimate interests in maintaining platform safety and legal compliance. Content that is not flagged is not retained beyond the processing session.
5.4 AI Model Categories
The Platform organizes its AI capabilities into the following categories:
- Text & Chat: Multi-model conversational AI supporting diverse text generation, analysis, and reasoning tasks.
- Image Generation: Text-to-image and image-to-image generation using multiple models.
- Video Generation: Text-to-video and image-to-video generation.
- Audio & Voice: Text-to-speech, voice synthesis, and voice cloning.
- Code Generation: AI-assisted coding and software development.
Representative models for each category are described in Section 3.7. The specific models available on the Platform are subject to change as we continuously expand and update our model offerings. Please refer to the model selection interface on the Platform for the most current list of available models.
VI. How We Share Your Information
6.1 With Upstream AI Model Providers
As described in Section 3.7 and Section V, we share your prompts, inputs, and generation parameters with upstream AI model providers to deliver AI services. These providers process your data as independent data controllers or processors.
6.2 With Payment Processors
We share transaction-related information with our authorized payment processor, Waffo Pancake, to facilitate Wallet top-ups, purchases, and refunds.
6.3 With Cloud and Infrastructure Providers
We may share data with cloud infrastructure providers (e.g., AWS, Google Cloud) for hosting, storage, and computing services.
6.4 With Content Moderation and Safety Partners
We may share content with third-party content moderation, safety, and compliance partners to detect and prevent prohibited content and fraudulent activity.
6.5 With Law Enforcement and Regulatory Authorities
We may disclose your personal data to law enforcement, regulatory authorities, or other government entities when:
- Required by applicable law, regulation, or legal process;
- Necessary to protect the rights, property, or safety of the Company, our users, or the public;
- To detect, prevent, or address fraud, security issues, or technical problems;
- To comply with AML/CTF obligations; or
- To report suspected illegal activity, including CSAM, to relevant authorities.
6.6 Business Transfers
In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice on the Platform of any change in ownership or uses of your personal data.
6.7 With Your Consent
We may share your information with third parties when you have given us explicit consent to do so.
6.8 Aggregated and Anonymized Data
We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you for analytical, research, or marketing purposes.
VII. Data Retention and Deletion
7.1 General Retention Principles
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
- As long as your account is active;
- To provide the Services;
- To comply with legal, regulatory, accounting, or reporting obligations;
- To resolve disputes and enforce our agreements; and
- As otherwise described in this Section.
7.2 Specific Retention Periods
| Data Category | Retention Period | Notes |
|---|---|---|
| Account Data | Duration of account + 30 days after deletion request | May be retained longer for legal compliance |
| Transaction Records | 7 years from transaction date | Required for financial regulatory compliance |
| Identity Verification Data | 5 years from last transaction or account closure | Required for AML/CTF compliance |
| API Logs (non-content) | 90 days | Extended to 1 year for troubleshooting if needed |
| Device/Log Data | 90 days | Aggregated/anonymized data may be retained longer |
| Support Tickets | 3 years after resolution | For quality assurance and dispute resolution |
7.3 AI-Generated Content Retention
(a) User Prompts and Inputs:
- Prompts and inputs submitted to AI models are transmitted to upstream providers as described in Section 3.7. We do not permanently store your prompts in our own systems beyond what is necessary for real-time processing, session management, and content moderation.
- Prompt history may be stored in your personal chat/workspace history for up to 90 days, after which it is automatically deleted unless you explicitly save it.
- You may manually delete your prompt/chat history at any time through your account settings.
(b) AI-Generated Outputs:
- AI-generated content saved to your account (workspace, gallery, downloads) is retained until you delete it or close your account.
- AI-generated content published to the Inspiration Square is retained for as long as the publication is active.
- AI-generated content that is flagged for content moderation may be retained for up to 180 days for review and compliance purposes.
- Temporary/unsaved AI outputs are deleted from our servers within 24 hours of generation, unless content moderation flags require extended retention.
(c) Voice Cloning Data:
- Voice recordings and vocal biometric data used for voice cloning are retained for the duration of your active use of the voice cloning feature.
- You may request deletion of your voice cloning data at any time through account settings or by contacting us. Upon deletion, all voice models derived from your voice data will be permanently removed.
(d) Image Processing Data:
- Images uploaded for processing are not retained beyond the processing session unless you explicitly save the output. Cached data is purged within 24 hours.
7.4 Deletion
You may request deletion of your personal data by:
- Using account settings (where available);
- Contacting us at the address in Section XVI; or
- Exercising your right to erasure under UK GDPR (see Section IX).
Upon receiving a valid deletion request, we will delete your data within 30 days, subject to legal retention requirements. We will confirm deletion upon completion. Note that some data may be retained in backup systems for up to an additional 90 days before permanent deletion, and some data (e.g., transaction records) may be retained as required by law.
VIII. Cookies and Similar Technologies
We use cookies, web beacons, pixels, and similar tracking technologies ("Cookies") to collect information about your browsing activities and preferences. Cookies we use include:
8.1 Essential Cookies
Required for the Platform to function properly, including session authentication, security features, and preference settings. These cannot be disabled.
8.2 Functional Cookies
Remember your preferences, settings, and customizations to enhance your experience.
8.3 Analytics Cookies
Help us understand how users interact with the Platform, allowing us to improve performance and content. We use tools such as Google Analytics.
8.4 Marketing Cookies
Used to deliver relevant advertisements and track campaign effectiveness. These are set with your consent.
8.5 Managing Cookies
You can manage or disable Cookies through your browser settings. Note that disabling certain Cookies may affect Platform functionality. For more information, please refer to our Cookie Policy (if available) or contact us.
IX. Your Rights
Under the UK GDPR and DPA 2018, you have the following rights regarding your personal data. We are committed to facilitating these rights and will respond to valid requests within 30 days.
9.1 Right of Access (Subject Access Request)
You have the right to obtain confirmation of whether we process your personal data and, if so, access to that data along with supplementary information.
9.2 Right of Rectification
You have the right to request correction of inaccurate or incomplete personal data. You may update most of your account information directly through your account settings.
9.3 Right of Erasure ("Right to Be Forgotten")
You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent, or where you object to processing. This right is subject to exceptions, including legal retention obligations, establishment/exercise/defense of legal claims, and regulatory requirements.
9.4 Right to Restrict Processing
You have the right to request restriction of processing in certain circumstances, such as when you contest the accuracy of data, processing is unlawful but you prefer restriction over erasure, or we no longer need the data but you do for legal claims.
9.5 Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller.
9.6 Right to Object
You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.
9.7 Rights Related to Automated Decision-Making and Profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, except in limited circumstances permitted by law. If our AI services involve automated decision-making that significantly affects you, we will provide appropriate safeguards, including the right to human intervention.
9.8 Right to Withdraw Consent
Where processing is based on your consent (e.g., marketing communications, voice cloning, optional cookies), you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
9.9 Exercising Your Rights
To exercise any of these rights, please contact us using the information in Section XVI. We may need to verify your identity before processing your request. We will respond within 30 days. If we are unable to fulfill your request, we will explain why.
X. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:
- Encryption: Data in transit is protected using TLS 1.2+ encryption. Data at rest is encrypted using AES-256 or equivalent encryption standards. Passwords are stored using bcrypt or equivalent cryptographic hashing.
- Access Controls: Role-based access controls limit access to personal data to authorized personnel on a need-to-know basis.
- Infrastructure Security: Our cloud infrastructure is hosted with reputable providers that maintain SOC 2 Type II, ISO 27001, or equivalent security certifications.
- Monitoring and Incident Response: We maintain logging, monitoring, and alerting systems to detect and respond to security incidents promptly.
- Payment Security: Payment processing is handled by PCI-DSS-compliant payment processors. We do not store full payment card numbers on our systems.
- Regular Assessments: We conduct periodic security assessments, vulnerability scans, and penetration tests.
No system is completely secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours as required by UK GDPR.
XI. Changes to This Privacy Policy
We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or the services we offer. Material changes will be communicated by:
- Posting the updated Policy on the Platform with a revised "Last Updated" date;
- Sending an email notification to registered users (for significant changes); and/or
- Displaying a prominent notice on the Platform.
Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.
XII. Protection of Minors
The Platform is not intended for use by individuals under the age of 16. If you are under 16 (or the minimum age required in your jurisdiction), you may not use the Platform.
12.1 Age Verification
We implement reasonable measures to verify the age of users, particularly for accounts that involve Wallet transactions, Creator Program participation, or access to mature content. We reserve the right to request proof of age at any time.
12.2 Collection of Minors' Data
We do not knowingly collect personal data from individuals under 16. If we discover that we have inadvertently collected personal data from a minor under 16, we will take immediate steps to delete that data from our systems.
12.3 CSAM Zero Tolerance
In accordance with our Acceptable Use Policy and applicable laws, we have a zero-tolerance policy toward Child Sexual Abuse Material (CSAM). Specifically:
- Any attempt to generate, upload, share, or access CSAM through the Platform is strictly prohibited and will result in immediate account termination and reporting to law enforcement.
- We implement automated detection systems to identify and block CSAM and related content.
- All reports of suspected CSAM are referred to the relevant law enforcement agencies and child protection organizations, including the National Crime Agency (NCA) in the UK and the National Center for Missing & Exploited Children (NCMEC) in the US, as applicable.
- User data associated with CSAM-related activity will be disclosed to authorities as required by law, without prior notice to the user.
12.4 Parental Controls
We do not currently offer specific parental control features. Parents and guardians are responsible for monitoring their children's online activities.
XIII. Cross-Border Data Transfers
13.1 Overview
Given the global distribution of our upstream AI model providers and cloud infrastructure, your personal data may be transferred to, stored, and processed in jurisdictions outside the United Kingdom and the European Economic Area ("EEA"). This is inherent to the nature of an AI aggregation platform that relies on models developed and hosted by providers worldwide.
13.2 Recipient Jurisdictions
Based on our current model provider and infrastructure arrangements, your data may be transferred to the following jurisdictions:
| Jurisdiction | Purpose | Relevant Providers |
|---|---|---|
| United States | AI model inference, cloud infrastructure | U.S.-based AI model providers (e.g., OpenAI, Google, Anthropic, Runway), cloud providers (e.g., AWS, Google Cloud) |
| China | AI model inference | Selected Chinese AI model providers (see Section 3.7) |
| United Kingdom | AI model inference, cloud infrastructure | UK-based AI model providers and cloud infrastructure |
| European Union / Germany | AI model inference | EU-based AI model providers and cloud infrastructure |
| Canada | AI model inference | Canadian AI model providers |
13.3 Transfer Mechanisms
To lawfully transfer your data outside the UK/EEA, we rely on the following mechanisms as applicable:
- UK Adequacy Regulations: Transfers to jurisdictions recognized as providing adequate data protection by the UK government (e.g., the EU, certain other territories).
- Standard Contractual Clauses ("SCCs"): For transfers to jurisdictions without an adequacy decision, we implement UK International Data Transfer Addendum to the EU Standard Contractual Clauses or equivalent safeguards, approved by the UK Information Commissioner's Office ("ICO").
- Data Processing Agreements: We maintain data processing agreements with all upstream AI model providers that specify the purposes, scope, and safeguards for data processing.
- Consent: Where required and where you have provided explicit informed consent for a specific cross-border transfer.
- Legitimate Interests: In certain circumstances, where the transfer is necessary for our legitimate interests and your rights and freedoms are not overridden.
13.4 Transfers to Non-Adequate Jurisdictions
Transfers of personal data to providers based in jurisdictions without a UK adequacy decision (including China) are subject to additional regulatory requirements under applicable data protection and data security laws. We:
- Limit the data transferred to the minimum necessary for AI model inference (typically, the prompt text and generation parameters, without including account identifiers, payment information, or other sensitive personal data where possible);
- Implement technical measures to pseudonymize or anonymize data before transmission where feasible;
- Maintain contractual safeguards with all providers in these jurisdictions; and
- Monitor regulatory developments and adjust our practices as required.
13.5 Your Rights Regarding Transfers
You have the right to be informed about cross-border transfers (as provided in this Section) and to request a copy of the safeguards used (e.g., SCCs). To exercise this right, contact us using the information in Section XVI.
XIV. Third-Party Links
The Platform may contain links to third-party websites, applications, or services that are not operated or controlled by us. This Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access through the Platform. We are not responsible for the privacy practices of third-party services.
XV. Updates
We will periodically review and update this Privacy Policy. The "Last Updated" date at the top of this page indicates when the Policy was last revised. We encourage you to review this page regularly for any changes.
XVI. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Element colors Electronic Entertainment Limited
Address: L220, Beaconside Business Village, Stafford Enterprise Park, Weston Road, Stafford, United Kingdom, ST18 0BF
Email: privacy@guid.ai
Data Protection Officer (DPO): If you wish to contact our Data Protection Officer, please email dpo@guid.ai or write to the address above marked "Data Protection Officer."
UK Supervisory Authority: If you are in the UK and remain unsatisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Website: https://ico.org.uk
- Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
XVII. Supplementary Notes
17.1 Definitions
- "Personal Data" means any information relating to an identified or identifiable natural person, as defined by UK GDPR.
- "Processing" means any operation or set of operations performed on personal data, whether or not by automated means.
- "Data Controller" means the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, Element colors Electronic Entertainment Limited is the data controller.
- "Data Processor" means an entity that processes personal data on behalf of the data controller.
- "AI-Generated Content" means any text, image, video, audio, code, or other output produced by artificial intelligence models accessible through the Platform.
- "Upstream Provider" means a third-party AI model provider whose models are integrated into and accessible through the Platform.
17.2 Relationship to Terms of Service
This Privacy Policy operates alongside our Terms of Service and Acceptable Use Policy. In the event of any conflict between this Policy and our Terms of Service regarding data protection matters, this Privacy Policy shall prevail to the extent of the conflict.
17.3 No Warranty
This Policy does not create any contractual rights beyond those set out in our Terms of Service. We may update this Policy at any time as described in Section XI.
17.4 Severability
If any provision of this Policy is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect.
17.5 Entire Agreement
This Privacy Policy, together with our Terms of Service and Acceptable Use Policy, constitutes the entire agreement between you and Element colors Electronic Entertainment Limited regarding the collection, processing, and protection of your personal data on the Platform.
17.6 Language
This Policy is provided in English. In the event of any discrepancy between the English version and any translated version, the English version shall prevail.
