Privacy Policy

Last Updated: December 1, 2025

Greenlogic Sp. z o.o. (“Greenlogic”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our mobile application Santa Cards: AI Video (“App”) and visit our website https://santacards.app/ (including subdomains), and tell you about your privacy rights and how the law protects you. By using the App, you agree to the collection and use of information in accordance with this policy.

1. Important Information and Who We Are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how Greenlogic collects and processes your personal data through your use of the App and our services, including any data you may provide when generating video content, making a purchase, or contacting support.

Controller

Greenlogic Sp. z o.o. is the controller and responsible for your personal data.

  • Full name of legal entity: Greenlogic Sp. z o.o.
  • Postal address: ul. Podwale 1/99, 50-043 Wrocław, Poland
  • VAT ID: PL8943073554
  • KRS: 0000602965
  • REGON: 363758260

Contact Details

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details below:

  • Email address: Form available at https://santacards.app/contact/
  • Privacy Support: via the contact form or strictly related correspondence to the postal address above.

2. The Personal Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data: Includes internal User IDs (randomly generated identifiers).
  • Input Data (User Content): Includes the specific information you provide to generate the AI video, such as:
    • The Name of the recipient (e.g., the child’s name).
    • The Age of the recipient.
    • The Custom Message/Script (the text you want the character in the video to speak).
  • Transaction Data: Includes details about payments to and from you (e.g., subscription status, purchase history, transaction IDs).

    Important: We do not store or process your full credit card or banking details. All financial transactions are handled securely by Apple (App Store).

  • Technical Data: Includes internet protocol (IP) address, your login data, device type and version, time zone setting, operating system (iOS version), and unique device identifiers (e.g., IDFA, IDFV).
  • Usage Data: Includes information about how you use the App, such as button clicks, time spent on screens, and crash logs (to help us fix bugs).

Aggregated Data

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

Special Note on Children’s Data (COPPA & GDPR)

While our App is themed around “Mikołaj” and holidays, the App is intended for use by parents and adults (18+). We do not knowingly collect personal data directly from children below the age of 13.

However, strictly for the purpose of generating the personalized video, the App allows the adult user to input a child’s name and age. This data is:

  • Provided voluntarily by the adult user.
  • Used solely to generate the requested video content.
  • Processed by our AI providers to render the output.

If you are a parent or guardian and you are aware that your child has provided us with personal data without your consent, please contact us.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Direct interactions: You may give us Input Data and feedback by filling in forms in the App. This includes personal data you provide when you:
    • Enter details to configure a video (name, age, wishes);
    • Request support or contact us;
    • Report a problem.
  • Automated technologies or interactions: As you interact with our App, we automatically collect Technical Data and Usage Data about your equipment and browsing actions. We collect this personal data by using server logs and third-party SDKs (Software Development Kits).
  • Third parties: We may receive Technical and Transaction Data from the following parties:
    • Apple (App Store): Confirmation of purchase and subscription status.
    • Google (Firebase): Analytics and crash reporting data.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

The following table:

Purpose/Activity Type of Data Lawful Basis for Processing
To provide the Service: Generating the personalized AI video based on your instructions. (a) Identity, (b) Input Data (Name, Age, Message) Performance of Contract: Necessary to deliver the service you requested/purchased.
To manage payments: Processing your In-App Purchase via Apple. (a) Identity, (b) Transaction Data Performance of Contract: Necessary to facilitate your purchase.
To improve the App: Fixing crashes, debugging, and understanding user preferences to develop new features. (a) Technical, (b) Usage Legitimate Interests: To keep our App updated, functional, and relevant.
To prevent abuse: Monitoring content to ensure generated videos do not violate our Terms or contain illegal/harmful content. (a) Identity, (b) Input Data, (c) Usage Legitimate Interests: To prevent fraud and misuse., Legal Obligation: To comply with applicable laws regarding content safety.
Customer Support: Responding to your inquiries. (a) Identity, (b) Contact (if provided) Legitimate Interests: To assist you with technical issues.

5. AI Video Generation

To provide the core functionality of the App (creating the video), the Input Data you provide (Recipient Name, Age, and Message) is processed using Artificial Intelligence models.

  • Service Provider: We use Replicate (replicate.com) as our AI inference provider.
  • Data Transfer: When you click "Generate," your Input Data is securely transmitted to Replicate's servers to create the video and audio files.
  • Data Usage by AI Provider: We have configured our services such that the provider processes data solely to return the generated video.
  • Accuracy Disclaimer: AI-generated content may occasionally contain errors or artifacts. The App is for entertainment purposes only.

6. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in Section 4.

  • AI Service Providers: Replicate, Inc. (USA) – for the generation of video and audio content.
  • Analytics & Infrastructure:
    • Google Firebase (Google LLC): For app analytics, database hosting, and crash reporting (Crashlytics).
  • Payment Processors: Apple Inc. – We do not see your credit card data; Apple processes the payment and tells us if it was successful.
  • Legal Authorities: If required by law, court order, or to protect the rights, property, or safety of Greenlogic, our users, or others.
  • Business Transfers: If we sell, transfer, or merge parts of our business or our assets, the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

7. International Transfers

Our company is based in Poland (European Economic Area - EEA). However, many of our external third parties (such as Replicate and Google) are based outside the EEA, specifically in the United States.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (e.g., under the EU-US Data Privacy Framework where applicable).
  • Where we use certain service providers, we may use specific Standard Contractual Clauses approved by the European Commission which give personal data the same protection it has in Europe.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. All data transmission between the App and our servers (and third parties) is encrypted using SSL/TLS (HTTPS). Access to your personal data is limited to those employees, agents, contractors, and other third parties who have a business need to know.

9. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

  • Account Data: Retained as long as you use the App.
  • Generated Videos: We may retain the generated video files on our secure servers for a limited period to allow you to download or share them.
  • Input Data: Retained only as long as necessary to generate the content and strictly for abuse monitoring.

You can request the deletion of your data at any time (see Section 10).

10. Your Legal Rights

Depending on your location, you have rights under data protection laws in relation to your personal data.

For Users in the EEA/UK (GDPR)

You have the right to:

  • Request access to your personal data.
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data ("Right to be forgotten").
  • Object to processing of your personal data.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent in any time where we are relying on consent to process your personal data.

For Users in the USA (California and others)

Although we are not strictly bound by CCPA/CPRA thresholds due to our size, we value your privacy and voluntarily offer similar rights:

  • Right to Know: You may request information about the categories of personal information we have collected.
  • Right to Delete: You may request that we delete personal information we have collected from you.
  • Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

How to exercise these rights:

To exercise any of the rights set out above, please contact us via the form at https://santacards.app/contact/. We aim to respond to all legitimate requests within one month.

11. Third-Party Links

The App may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the privacy policy of every website you visit.

12. Changes to the Privacy Policy

We keep our privacy policy under regular review. This version was last updated on the date listed at the top of this policy. We may update this privacy policy from time to time. If we make material changes, we will notify you through the App or via other communication channels. Continued use of the App after such changes constitutes your acceptance of the new Privacy Policy.

13. Contact

For legal notices or support: