Privacy Policy

RHEI Global Privacy Policy

Last Updated On: July 25, 2025

A. ABOUT THIS POLICY

This Privacy Policy explains how RHEI Creations Corp. and its affiliates ("RHEI", "we", "us", or "our") collect, use, disclose, and protect personal data through our platforms, including the Made platform (www.getmade.ai), Data Pro, Rights Pro, Audience Pro, and other products or services we offer.

This policy is designed to reflect key privacy principles and legal requirements in jurisdictions where RHEI operates, including the United States, United Kingdom, European Economic Area, and Canada. While we implement measures intended to meet applicable obligations, the scope and applicability of specific legal requirements may vary by user location and product use.

1. Scope And Application

This Privacy Policy applies to individuals whose personal data RHEI collects, uses, or otherwise processes in the course of its operations. This includes users, creators, clients, job applicants, event participants, and website visitors—where RHEI holds or processes their personal data. It covers personal data collected through:

• Our current and future products and services, including Made, Data Pro, Rights Pro, Reach Pro, Audience Pro and any related tools, features, or service offerings we develop
• Websites and mobile applications operated by RHEI
• Support channels and customer service interactions
• Referrals, affiliate or invitation programs
• Webinar registration and attendance, or event sign-ups and participation (virtual or in person)
• Submissions to talent or partnership intake forms and creator portals
• Product feedback and testing programs (including beta or early access pilots)
• Social media interactions, such as mentions, messages, or comment engagement
• Recorded demos, onboarding sessions, or support calls
• Recruitment and application processes for employment or contractor roles

For the purposes of this Privacy Policy:

"Personal data" or "personal information" means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to a particular individual. This includes, but is not limited to, contact details, account credentials, user-generated content, device and usage data, payment and transaction information, online identifiers, and any inferences drawn from such data.

The precise definition of personal data or personal information may vary depending on your jurisdiction. For example, it includes "personal data" as defined under the GDPR and UK GDPR, and "personal information" as defined under the California Consumer Privacy Act (CCPA/CPRA).

Inclusion in this Policy does not imply a contractual relationship with RHEI, but reflects that RHEI may process your personal data based on your interactions with our services or content.

This Policy also applies to personal data collected indirectly from publicly available sources or through automated or technical means, such as:

• Metadata or content publicly posted on digital platforms (e.g., YouTube)
• Analytics and usage logs
• Cookies, IP addresses, and online identifiers
• Inferred data and engagement metrics

This Policy does not apply to websites, applications, services, or platforms that are not owned or controlled by RHEI, even if we provide links to them or integrate with them. These may include, for example, platforms such as YouTube, Google, Meta, Instagram, LinkedIn, third-party payment providers, or ad technology services.

We are not responsible for the privacy practices of such third parties, and we encourage you to review their privacy policies before interacting with their services.

2. Personal Data We Collect

We collect the following categories of personal data (this list may expand as our platform evolves and may include additional information required for identity verification or legal compliance):

• Identity and Contact Data (e.g., name, email address, phone number, mailing address, social handles)
• Authentication Data (e.g., account credentials, session ID, OAuth login tokens, and platform usernames from third-party login providers such as Apple or Google)
• User-Generated Content (e.g., prompts, uploaded personal photos, audio, video, comments, replies, playlists, and channel-related assets used in or for AI output generation)
• Usage and Device Data (e.g., features accessed, frequency and duration of use, user behavior during app interaction, and technical logs such as IP address, browser type, and device identifiers)
• Audience and Community Interaction Data (e.g., tipping activity, likes, replies, follows, direct messages, or other user-to-creator engagement through RHEI-operated features)
• Public Platform Information (e.g., publicly available YouTube comments, playlists, or channel metadata retrieved via APIs or visible through user interactions)
• Identity Verification Data (e.g., government-issued ID, date of birth, IP-based location, or other documentation requested to verify your identity, age, or jurisdictional eligibility for features such as monetization, tipping, or legal compliance)
• Payment and Transaction Data (e.g., billing address, transaction history, preferred payment method, and last four digits of payment card)
• Performance and Revenue Data (e.g., viewership, monetization performance, payout history, and content metrics drawn from YouTube channels and other integrated services)
• Inferred or Derived Data (e.g., user engagement patterns, feature usage, behavioral profiles, or content suitability ratings generated from system analytics)
• Communications and Support Data (e.g., emails, help tickets, chat transcripts, call recordings, or other correspondence, including email open rates, browser type, and approximate IP-based location for performance analysis)
• Optional Biographical or Demographic Information (e.g., country, preferred language, education history, interests, or age range)
• Professional Information (e.g., company, title, talent bios, or materials submitted via partnership intake or outreach forms)
• Audio/Visual Recordings (e.g., recordings of demos, onboarding sessions, webinars, or support calls, where applicable and with notice)
• Generated Creative Assets (e.g., AI-generated images, video clips, captions, and other creator tools based on your prompts or preferences)

We may also collect personal data about third parties that you include in content, submissions, or referrals (e.g., names, voices, or images). If you provide such information, you are responsible for ensuring you have obtained any necessary consents or lawful basis to share it with us. In such cases, you are responsible for ensuring you have the legal right to share such information with us.

3. APPLICANT AND RECRUITMENT DATA

If you apply for a job or internship with RHEI, we may collect and process personal data for recruitment and hiring purposes. This includes:

Application and Recruitment Data (e.g., resume/CV, education history, employment history, work authorization status, skills, certifications, references, salary expectations, location preferences, and other information submitted through our Careers portal, by mail, delivery or electronic transmission, or during interviews)

We use this information to:

• Evaluate your application and assess qualifications
• Contact you regarding your application
• Manage interview logistics and perform background checks (where permitted)
• Maintain a record of your application for future roles (unless you request deletion)
• Comply with legal and regulatory employment obligations

We may share this data with RHEI personnel involved in the hiring process or with third-party service providers who support recruiting, background checks, and applicant tracking systems. We retain this data only as long as necessary for the hiring process, as required by our internal policies, or as required by law.

HOW WE COLLECT AND USE PERSONAL DATA

4. HOW WE COLLECT PERSONAL DATA

We collect personal data through multiple sources and methods, including:

• Contractual relationships – Information you provide or that is generated in connection with agreements or legal relationships you enter into with RHEI, including Content Provider Agreements, licensing arrangements, onboarding forms, or collaborations with partners and sponsors to promote or represent you
• Direct interactions – When you provide data directly to us via forms, registration, electronic communications, telephone, uploads, surveys, support requests, or product usage.
• Automated technologies – Through cookies, pixels, device logs, and usage analytics.
• Third-party integrations – Including platforms such as YouTube, Google, OpenAI, and other tools that support platform features or personalization.
• RHEI-operated support sessions – We may record support, onboarding, or diagnostic sessions (with notice) for internal use.
• Publicly available or licensed sources – Such as social platforms, channel metadata, or industry directories.

We may also enhance our user records with professional or contact information collected or licensed from reputable third-party providers. This may include details such as names, email addresses, company affiliations, roles or titles, or social media profiles. We use this information to support outreach, business development, market analysis, or to better personalize services or recommendations. Where we collect or use personal data for outreach purposes, we will provide notice of processing at the time of first contact or as soon as reasonably practicable, as required by applicable law.

You are solely responsible for ensuring that any information or content you provide or make accessible to RHEI—whether through a RHEI platform, via a contractual relationship, or by authorizing access from a third-party service—complies with applicable laws, does not infringe third-party rights, and includes any necessary permissions or consents (e.g., for biometric or personal data)

5. PLATFORM-LINKED ACCOUNT DATA

If you connect your YouTube account or another supported third-party platform (e.g., TikTok, Meta, Spotify) to a RHEI service, we may access data via APIs, platform permissions, or authorized partner tools. This may include your channel name, performance metrics, playlists, subscribers, comments, audience insights, and other public or authenticated data.

This data is used to:

• Verify account identity and eligibility for services
• Access and display performance data
• Generate insights and platform-specific recommendations
• Match creators with branded opportunities and sponsorships
• Fulfill obligations under partnership, content licensing, rights or channel management, or other agreements with us.

We access this data only with your authorization or where otherwise permitted under a written agreement with you. You may revoke access at any time, subject to the platform's tools and permissions (e.g., via your Google account permissions settings) and any obligations you may have to us under an agreement.

Use of these services is also subject to applicable third-party terms, including:

• YouTube Terms of Service
• Google Privacy Policy
• Other applicable third-party platform terms

6. USE OF PERSONAL DATA

We use personal data for the following purposes:

• To deliver and operate our services, including diagnostic support, onboarding, and personalized system responses
• To send marketing communications, newsletters, or event invitations where consent has been provided or permitted by law
• To generate deidentified insights or analytics derived from your content, activity, or use of a platform
• To personalize your experience and surface relevant opportunities (e.g., sponsorships, integrations, partner campaigns)
• To improve and evaluate our AI models
• For analytics and performance tracking
• To manage payments and contracts
• To fulfill our rights or obligations under content licensing agreements, including distributing authorized content to third-party partners or platforms
• To send communications, alerts, product updates, or marketing materials, where consented or permitted by law
• To detect and prevent fraud or security threats
• To verify your identity, geographic eligibility, or legal status where required for certain features (e.g., monetization, financial disbursements, age-sensitive tools)
• To comply with legal obligations, including financial reporting, content licensing, or intellectual property enforcement
• To measure the effectiveness of advertising or promotional campaigns displayed on or through RHEI-licensed or operated content using standard tracking tools (e.g., pixels, web beacons, or ad performance frameworks)

7. LEGAL BASIS FOR PROCESSING PERSONAL DATA

Some jurisdictions require organizations to identify a legal basis for processing personal data. Depending on the nature of the data, the relationship between RHEI and the individual, and the applicable legal framework (e.g., GDPR, CPRA, PIPEDA), more than one legal basis may apply. We rely on the following bases to process personal data:

These include:

• Consent – Where required by law, we will seek clear and informed consent before processing personal data. This may apply, for example, when placing cookies, sending marketing communications, or collecting optional demographic information. In some jurisdictions, consent may be implied based on your use of our services, your relationship with RHEI, or where the purpose is obvious and the individual has voluntarily provided the data. In other cases, we may rely on consents obtained by a third party (such as a licensor, partner, or platform) who is legally authorized to share that data with us. Where required, we rely on your consent to send marketing emails or newsletters. You may withdraw this consent at any time by clicking the unsubscribe link or contacting us.
• Contractual necessity – We process personal data when it's needed to fulfill a contract with you, or to take steps at your request before entering into a contract (e.g., to provide services, manage your account, or issue payments). In some cases, we may also process personal data under contracts we have with another party (e.g., a creator or content licensor), where doing so is necessary to fulfill our obligations or exercise rights under that agreement.
• Legal obligations – We may process personal data to comply with laws, regulations, or other legal requirements. This includes obligations related to fraud prevention, tax reporting, financial disclosures, identity verification (e.g., Know Your Customer or KYC checks), child safety and protection, intellectual property enforcement, or transparency disclosures required under AI or privacy laws, as well as contractual reporting requirements tied to our licensing or partnership agreements.
• Legitimate interests – In some cases, we process personal data because it supports a legitimate interest of RHEI or our partners, provided your privacy rights are not overridden. This may include operating and improving our services; protecting against fraud, abuse, or legal risk; analyzing platform use and user engagement; matching creators with relevant brands or sponsorship opportunities; developing new features; enriching records from public or third-party sources for outreach or personalization purposes; or collecting publicly available data from reputable or open sources, in accordance with applicable law and platform terms.

AI AND AUTOMATION

8. AI PRACTICES AND AUTOMATED PROCESSING

Our Made platform and other services use AI to assist creators with a wide range of content development and optimization tasks. These may include:

• Generating visual assets, written text, and audio from user-submitted prompts
• Personalizing interactions with AI agents based on usage context and preferences
• Translating, summarizing, or reformatting content
• Suggesting audience engagement strategies or publishing workflows

Prompts and generated outputs may be stored and reviewed to refine your user experience and improve system performance. In some cases, RHEI may use internal fine-tuning techniques such as LoRA (Low-Rank Adaptation) to optimize specific features—such as generating thumbnails or refining AI outputs—without modifying the underlying model. These models are trained exclusively on RHEI-controlled systems. We use third-party tools to support these AI-powered features, including orchestration platforms, search integrations, translation engines, and large language models. These may include OpenAI, Google Gemini, LangChain, and other providers.

Our AI features may involve automated processing or decision-making (e.g., recommending a thumbnail, drafting commentary, conducting polls and surveys or identifying content tags), but ultimate control over publishing or content use remains with the user.

If you interact with our agentic tools, those interactions are logged for consistency, safety, and product improvement.

You may not currently opt out of reuse of your prompts or outputs.

AI Law and Transparency

We are committed to meeting applicable legal obligations related to transparency, fairness, and responsible AI use. We use AI strictly to support user-facing functionality (e.g., content generation, metadata suggestions, platform recommendations), and not to make automated decisions that have legal or similarly significant effects on individuals. Where required by law we will provide additional disclosures or notices regarding AI system capabilities, limitations, and data usage.

Disclaimer on AI Output Accuracy

AI-generated content may occasionally contain errors, inaccuracies, or "hallucinations" (outputs that appear plausible but are factually incorrect or fabricated). These outputs are generated by probabilistic systems and are not reviewed in real time. While we strive to improve quality and reliability, you should not rely solely on AI-generated outputs for decisions that may have legal, financial, reputational, or personal consequences. We encourage users to review and evaluate AI-generated outputs carefully and to apply human judgment before relying on such outputs for consequential decisions.

SHARING, TRANSFERS, AND RETENTION

9. DISCLOSURE AND SHARING

We may share personal data in the following circumstances:

• With your consent – Where legally required, we will seek your opt-in consent before sharing any sensitive personal data (e.g., medical, biometric, financial, or self-identified demographic data).
• With service providers – We share data with vendors who support our business operations (e.g., hosting, analytics, customer support, payment processing, translations). These providers are bound to use data only as needed to deliver their services.
• With joint operators, brand partners, or advertisers – For co-managed programs, monetization support, sponsorship matching, or advertising or branded entertainment campaigns.
• With partners verifying your affiliation – For example, to confirm your participation in a network, advertising or brand campaign, or third-party service powered by RHEI.
• For brand safety or compliance purposes – We may share channel or video data and related trust and safety signals with advertisers, brands or platforms to assess eligibility for campaigns or partnerships.
• To facilitate user-authorized transactions or programs – Including data-sharing initiated by your direct participation in RHEI features, integrations, or external opportunities.
• To resolve disputes or act on your behalf – Including when a representative or agent is authorized to communicate with us on your behalf.
• To comply with legal obligations – Including lawful requests from courts, regulators, or enforcement authorities.
• For fraud prevention and security protection – To prevent abuse, unauthorized use, or threats to our systems, services, or community.
• In the context of a business transaction – If RHEI is involved in a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred in accordance with the terms of the business transaction or applicable law.

We also share aggregated, non-identifiable data (which cannot reasonably be linked back to an individual) for analytics, marketing, and performance improvement purposes.

Additionally, RHEI may sublicense licensed audiovisual content to third-party AI developers under a Data Pro Agreement or similar arrangement. While this licensing is limited to content authorized by the licensor, it may include elements that qualify as personal data under applicable law (e.g., facial images, voice recordings, or biometric or descriptive metadata). These arrangements are subject to contractual safeguards, including transparency requirements, usage limitations, and compliance with data protection laws. RHEI requires licensors to obtain all necessary rights and consents before submitting content for these purposes.

Note: If your personal data is included in content submitted to RHEI by another party (e.g., a licensor or brand partner), you may not be able to limit certain forms of sharing or reuse that are contractually permitted or legally authorized.

10. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to or stored in jurisdictions outside your province, state, or country of residence, including the United States and Canada. These transfers may be necessary for us to operate our services, engage vendors, or fulfill contractual obligations.

Where required by law we implement appropriate safeguards before making such transfers. These may include:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• UK International Data Transfer Agreements (IDTA)
• Transfers to countries deemed to provide adequate protection by regulatory authorities.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to operate and improve our websites, apps, and services. These may include:

• Essential cookies – Required for basic site functionality such as login sessions, navigation, or storing user preferences.
• Performance and analytics cookies – Used to understand how visitors use our services, which helps us improve performance, troubleshoot issues, and develop new features.
• Functional cookies – Help remember choices you make, such as language settings or region.
• Advertising and measurement technologies – May be used to understand the effectiveness of campaigns, including the use of tags, pixels, or cookies. These may also be used by RHEI or our partners to understand how you interact with content and advertisements across platforms.

We may use cookies, web beacons, JavaScript, and similar technologies to analyze trends, administer our services, monitor engagement, and gather broad demographic information. You can manage your cookie preferences through your browser settings. You may also opt out of certain types of tracking used for interest-based advertising by visiting opt-out tools provided by industry groups, such as:

• Network Advertising Initiative
• Digital Advertising Alliance
• Your Online Choices (EU users)

Please note that these opt-outs are device- and browser-specific. Disabling or clearing cookies may impact the functionality of certain features or your user experience.

12. DATA RETENTION

We retain personal data as long as reasonably necessary to fulfill the purposes described in this policy, including for business operations, legal compliance, dispute resolution, or security and fraud prevention. Our retention periods may vary depending on the nature of the data, our relationship with you, and the legal or regulatory context.

If you are an active customer or user, we generally retain your data for the duration of your engagement with RHEI. We do not delete personal data while your account or contractual relationship remains active, unless required by law or unless explicitly agreed otherwise. Once the relationship ends, we retain personal data in accordance with internal retention policies and legal obligations, and may delete or anonymize it after those periods expire.

Where RHEI acts on behalf of a partner (such as a brand or licensor), we may retain and manage data in accordance with the retention requirements or instructions of that partner. In such cases, requests regarding data deletion should be directed to the relevant data owner where appropriate.

13. DATA SECURITY

We use a combination of physical, technical, and organizational safeguards to help protect personal data from unauthorized access, use, or disclosure. These safeguards may include encryption in transit, access controls, logging, multi-factor authentication, and secure server environments. Personal data is stored on infrastructure that is monitored and access-controlled to protect against misuse.

We also maintain internal policies and employee training programs designed to ensure personal data is handled responsibly and in accordance with applicable law. While no system can guarantee complete security, we take commercially reasonable steps to protect the data we hold.

Users are responsible for maintaining the confidentiality of their login credentials and should use secure authentication methods.

YOUR RIGHTS AND SPECIAL POPULATIONS

14. YOUR RIGHTS AND HOW TO EXERCISE THEM

Depending on your location and applicable laws, you may have certain rights over your personal data. These may include the right to:

• Access the personal data we hold about you
• Correct or update inaccurate or incomplete information
• Delete or request erasure of your personal data
• Object to or restrict certain types of processing (e.g., for marketing)
• Withdraw consent for processing where consent is the legal basis
• Request data portability, allowing you to receive your data in a usable format
• Opt out of sales or sharing of your data, as defined by applicable laws
• Designate an authorized agent to exercise your rights on your behalf
• Lodge a complaint with a supervisory authority in your jurisdiction

To exercise these rights, please contact us at privacy@rhei.com or at the contact details below. We may need to verify your identity before processing certain requests, and reserve the right to deny a request where we are unable to authenticate the request or where legally permitted to do so. If an authorized agent makes a request on your behalf, we may require additional information to verify their authority.

You may unsubscribe from marketing emails or newsletters by clicking the "unsubscribe" link at the bottom of our emails or by contacting us at privacy@rhei.com. You will continue to receive essential service-related emails related to your account or transactions.

We aim to respond to rights requests within the time period required by applicable law. In some cases, we may decline to fulfill a request if it would interfere with legal obligations, impact the rights of others, or where we are otherwise permitted by law to deny the request.

Please note that in some cases, access may be restricted as permitted or required by applicable law, including where responding would reveal legal privilege, compromise the rights of others, or violate confidentiality obligations. If applicable, we will inform you of the reasons for denying or limiting access, subject to any legal or regulatory requirements.

15. CHILDREN'S DATA

We do not knowingly collect or process personal data from children who do not have the legal capacity to consent under applicable law (e.g., under age 13 in the U.S., or under the age of digital consent or majority in other jurisdictions). If we become aware that personal data has been collected from a child without verified parental or legal guardian consent, we will take steps to delete that data or obtain proper authorization.

Where minors are permitted to use our services or enter into agreements with RHEI, such use is only allowed with the consent and signature of a parent or legal guardian or pursuant to a court order, and only the minimum data necessary is collected.

Parents or legal guardians may request that we disclose, correct, delete, or restrict processing of their child's personal data by contacting privacy@rhei.com.

16. JURISDICTION-SPECIFIC RIGHTS AND DISCLOSURES

Some jurisdictions grant additional privacy rights or require specific disclosures. These apply in addition to the rights and practices described in this Policy.

If you reside in a jurisdiction with additional legal rights not addressed above, you may contact us at privacy@rhei.com.

17. UPDATES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time. We will post any changes to this Privacy Policy on this web page, and if the changes are significant, we will post a more prominent notice on this page or we will directly send you a notification. You agree that your continued use of our products or services after notice of such change shall constitute your acceptance of the Privacy Policy. You agree to review this Privacy Policy regularly in order to inform yourself of the terms and conditions of this Privacy Policy and any modifications to the Privacy Policy.

18. CONTACT INFORMATION

If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise your rights over control and usage of your data, please contact us at privacy@rhei.com, or using the contact details below:

Our Privacy Officer/Data Protection Officer is responsible for ensuring our compliance with this Privacy Policy and all relevant privacy laws.