Privacy Policy

Effective Date: November 9, 2026

1. INTRODUCTION. This Privacy Policy (the “Policy”) explains how OnVibe, Inc. (“OnVibe”, “we”, “us”, “our”) collects, uses, and discloses personal information through its marketing website (onvibe.co), its web application (app.onvibe.co), its interactive preview environment (demo.onvibe.co), our transactional and marketing email communications, and our Concierge service (collectively, the “Services”). Any capitalized terms that are not defined in this Policy are defined in our Terms of Service.

2. INFORMATION COLLECTED AND HOW WE USE IT. As explained further in this section, you will have the opportunity to provide us with certain personal information, and certain personal information is also provided to us by third parties (such as Meta Platforms, Inc., when you connect your Instagram account) at your direction. In addition, we may collect certain personal information automatically through your use of the Services. The rest of this section provides a more detailed explanation of the personal information we collect, how we use that personal information, and our lawful bases for processing that personal information.

2.1. Voluntarily Disclosed and User-Authorized Information. The following table identifies the specific purposes for which you may disclose personal information to us (directly, or by authorizing a third party such as Meta Platforms, Inc. or LinkedIn Corporation to share your information with us), along with our lawful bases for processing that personal information.

2.2. Automatically Collected Information. Whenever you interact with the Services, we and our service providers automatically receive and record certain information, including your IP address, browser and device type, operating system, session identifiers, and page and click events. We use a limited number of functional cookies (described in our Cookie Policy below) and, separately, use Google Analytics through Google Tag Manager (onvibe.co only) and Mixpanel for analytics and Sentry for error monitoring. Neither Mixpanel nor Sentry sets cookies on our Services, and Mixpanel's browser identifier is stored in your browser's local storage rather than in a cookie. Where required by applicable law, including for users in the European Economic Area, Switzerland, and the United Kingdom, we obtain your consent before setting non-essential cookies, such as our Google Analytics cookies, through the cookie consent banner described in our Cookie Policy below. We use this data to operate, secure, and improve the Services, to debug issues, and to prevent abuse. We collect this information to perform our contract with you and for our legitimate interest of providing a smooth, secure, and reliable user experience on the Services.

2.3. Use of Artificial Intelligence.

OnVibe uses artificial intelligence technology to analyze the content you connect or upload (such as your posts, captions, images, and audience engagement data) in order to identify demographic and usage trends and generate personalized social media content on your behalf. When you interact with our conversational chat interface, including through text or voice input, the content of your inputs is transmitted to third-party artificial intelligence providers in order to generate and refine content for you.

We do not use your individually identifiable account content to train or fine-tune our underlying AI models, and personalization for your account is not shared with other users. Separately, we may use aggregated, deidentified usage data and performance trends, which do not identify you or any individual, to improve the Services across all users.

Our AI service providers process this information as our service providers and, per their standard API terms, do not use it to train their own general-purpose models. We rely on our AI providers' standard business or commercial API terms for this purpose.

3. DISCLOSURE OF PERSONAL INFORMATION. We may disclose your personal information as detailed in this section.

3.1. Personnel and Third-Party Service Providers. We employ personnel and engage other companies and people to perform tasks on our behalf and need to share your personal information with them to provide products or services to you. All data we receive is stored on servers hosted by Google Cloud Platform. We also engage service providers for product analytics (Mixpanel), error monitoring (Sentry), AI prompt and output logging (Langfuse), email delivery (Resend), application logging (Axiom), and artificial intelligence processing (our AI technology providers), and, once payment processing launches, a third-party payment processor. We maintain a current list of our subprocessors, which you can request by contacting us as set out below.

3.2. Workspace Administrators. We are introducing team and workspace functionality. Once available, if you are invited to a workspace by an administrator, that administrator will be able to view your connected accounts, generated content, and published posts within the shared workspace. This is administrator visibility into a member's account, not a public forum or user-to-user communication, and continues to apply even if you leave the workspace and retain your own individual account.

3.3. Third-Party Integrations. If we introduce integrations with third-party applications or services within the Services (the “Third-Party Apps”), we will allow the providers of those Third-Party Apps (the “Third-Party Providers”) to access or use your personal information and User Content as required for the interoperation of the Third-Party Apps and the Services. Any Third-Party Provider’s use of your personal information and User Content is subject to the applicable agreement between you and the Third-Party Provider. We are not responsible for any access to or use of your personal information or User Content by Third-Party Providers. You are solely responsible for the decision to permit any Third-Party Provider to use your personal information or User Content.

3.4. Meta Platforms and LinkedIn. When you connect your Instagram account, Meta Platforms, Inc. independently controls its own processing of your Instagram account under its terms with you, separate from our processing of the data you authorize us to receive. Similarly, if you use LinkedIn's publishing API to authorize us to publish on your behalf, LinkedIn Corporation independently controls its own processing under its terms with you.

3.5. No Sale of Information. We do not sell your personal information, and we do not share your personal information with third parties for the purpose of cross-context behavioral or targeted advertising.

3.6. Aggregated and Anonymous Information. We may de-identify your personal information so that you are not identified as an individual, and use or share that information, including aggregated engagement and content-performance trends derived across our user base, to improve the Services for all users. This aggregated data does not include your handle or any individual user or post identifier. Where this aggregated data is derived from Instagram content obtained through the Instagram Graph API, we handle it consistent with Meta's Platform Terms and Developer Policies governing the aggregation, retention, and transfer of platform data.

3.7. Business Transfers. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.

3.8. Legal Compliance. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with governmental requests, law enforcement or court orders, or enforce or apply our Terms of Service and other agreements.

3.9. California Residents Under 16 Years of Age. Because we require all users of the Services to be at least 18 years of age, and because we do not sell or share personal information, we do not sell or share the personal information of users under 16 years of age.

4. INTERNATIONAL TRANSFERS. Our Services are available to users in the United States, the European Economic Area, Switzerland, the United Kingdom, Canada, and elsewhere, and all personal information we collect is stored on servers located in the United States. When we transfer the personal information of users from the European Economic Area, Switzerland, or United Kingdom to the United States, we rely on adequacy decisions, data transfer agreements, or other legally compliant mechanisms for such transfers, including standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below.

5. SECURITY. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. In addition, we rely on the technical safeguards provided by the third party service providers we use to host, store, and process your personal information. We cannot, however, ensure or warrant that your personal information on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6. YOUR RIGHTS.

6.1. Who To Exercise Your Rights With. You may have rights under data protection laws in relation to your personal information. You can learn more about your rights further down in this section. If we have collected your personal information as a result of our contractual relationship with you, we are a “controller” of that personal information and you can exercise your rights with respect to your personal information by following the instructions below. However, if we have collected your personal information as a result of agreements we have in place with our clients, we are a “processor” of your personal information and those clients control our use of your personal information and determine how and for what purpose we process your personal information.

If we are a processor of your personal information, and you have any questions or concerns about how your personal information is handled or would like to exercise your rights as a data subject, you should contact the client who has contracted with us to use the Services to process your personal information. That client’s privacy policy governs their use (and our processing) of your personal information. We will provide assistance to the client to address any concerns you may have, in accordance with the terms of our contract with them and applicable law.

6.2. Rights of Users in the EEA, Switzerland, and UK. If you reside in the EEA, Switzerland, or the UK and we are a controller of your personal information, you have the following rights:

6.2.1. Request access to your personal information. You may request a copy of the personal information we hold about you and to check that we are lawfully processing it. Where we have good reason, and where applicable law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.

6.2.2. Request correction of your personal information. You may request that we correct any incomplete or inaccurate data we hold about you.

6.2.3. Request erasure of your personal information. You may request that we delete or remove personal information where there is no good reason for us continuing to process it. You may also ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

6.2.4. Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests). You may also restrict our processing of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that personal information.

6.2.5. Request the transfer of your personal information to you or to a third party. In certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organization on your behalf. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organization’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.

6.2.6. Withdraw consent. You may withdraw your consent for our processing of your personal information where we are relying on consent to process that personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

6.3. Rights of Users in Certain US States. Certain states within the United States (the “Applicable States”) have comprehensive data privacy laws that provide you with certain rights with respect to your personal information (collectively, the “U.S. Privacy Laws”). Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:

6.3.1. Right to Know: The right to request that we disclose to you the personal information we collect, use, disclose, and sell, as well as information about our data practices.

6.3.2. Right to Request Correction: The right to request that we correct inaccurate personal information that we maintain about you.

6.3.3. Right to Request Deletion: The right to request that we delete your personal information that we have collected from or about you. We may reject your request if it is reasonably necessary to maintain your personal information in order to complete the transaction for which we collected the personal information, comply with law, or other applicable reasons that are permitted under the US Privacy Laws and that will be communicated to you upon receipt of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

6.3.4. Right to Portability: The right to request that we provide you with your personal information in a common file format.

6.3.5. Right to Opt Out of Sales and Targeted Advertising: The right to opt out of our sale of your personal information and the processing of your personal information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising. If you do choose to opt out, your preference will apply specifically to the device and browser you are using. If you visit the Services using a different browser or device, you will need to indicate your preferences for that browser/device.

6.3.6. Right to Opt In for Sensitive Data Processing: The right to opt in before we can process your sensitive data for certain purposes.

6.3.7. Right to Opt Out of Automated Decision Making: The right to opt out of our use of your personal information for certain types of automated decision making.

6.3.8. Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

6.4. Rights of All Other Users. Regardless of where you reside, through your account settings, you may access and edit your profile information. You may request deletion of your account at any time, which will disconnect your connected Instagram account and schedule your personal information for deletion as described in Section 7. Please understand, however, that it may be impossible to delete this information completely, due to backups and records of deletions. In addition, we may deny a deletion request if the denial is necessary for us to comply with applicable law. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

6.5. How to Exercise Your Rights. If you wish to exercise any of the rights set out above, please contact us at privacy@onvibe.co. If you have authorized an agent to exercise your rights on your behalf, the agent may contact us at privacy@onvibe.co. Please note that to protect your personal information and the integrity of our Services, we may need to collect additional information to verify your identity (and, if applicable, the authority of your agent) before processing your request. We intend to respond to verified requests within 30 days. If you are not satisfied with any decision we make with respect to your request, you can let us know the reasons for your concern, and we will review your appeal.

6.6. Supervisory Authorities. We welcome and appreciate the chance to address any concerns you may have about the Policy and our collection and use of your personal information. To the extent you feel like we have not addressed your concerns, and depending on your jurisdiction, you may have the right to make a complaint at any time to your data protection supervisory authority. For end users in the EEA, you can find contact information for each country’s supervisory authority here. For end users in the UK, you can find contact information for the Information Commissioner’s Office (ICO) on the ICO’s website here.

7. RETENTION OF INFORMATION. Subject to your right to request deletion of your personal information in accordance with Section 6, we retain your personal information for as long as needed for your use of the Services, our compliance with legal obligations, and to protect our or others' interests, as further described in the table in Section 2. When you delete your account, we schedule your personal information for deletion from our own systems, and a daily process permanently purges that information within 90 days. This deletion process covers our own systems; copies of your information already transmitted to our service providers (such as our analytics, error-monitoring, AI-logging, and email-delivery providers) are governed by each provider's own retention practices and are not reached by our deletion process. Aggregated, de-identified data derived from your information, and feedback signals retained in aggregate, may be retained indefinitely because they are not tied to you as an individual.

8. HOW WE RESPOND TO DO NOT TRACK AND GLOBAL PRIVACY CONTROL SIGNALS. We will honor your exercise of your rights with respect to your personal information in accordance with Section 6. We honor the Global Privacy Control (GPC) as a valid opt-out preference signal. Apart from GPC and those rights, we do not otherwise respond to “Do Not Track” signals.

9. AGE OF USERS. The Services are intended for users who are at least 18 years of age. Individuals under the age of 18 are not permitted to use, access, or register for the Services in any way. We do not knowingly collect or solicit information from anyone under the age of 18. If we learn that we have collected personal information from someone under the age of 18, we will delete that information as quickly as possible.

10. CHANGES TO POLICY. We’re constantly trying to improve the Services, so we may need to change this Policy from time to time as well. The date of the last modification will be posted at the beginning of this Policy. It is your responsibility to check from time to time for updates. By continuing to access or use the Services, you are indicating that you agree to be bound by the modified Policy.

11. CONTACT US. If you have any questions or concerns regarding this Policy, please send us a detailed message at privacy@onvibe.co, and we will try to resolve your concerns. In addition, please contact info@onvibe.co for all other inquiries.

OnVibe Cookie Policy

This Cookie Policy provides information about cookies, how we and third parties use them on the Services, and how you can manage our use of cookies with respect to your experience on the Services.

What is a Cookie?

A cookie is a small text file that can be stored on and accessed from your device when you visit and use our Services. Cookies enable us to “personalize” the Services for users by remembering information about our users. The Services use cookies to administer the Services, store your preferences, display content to personalize your visit, analyze trends on the Services, and track your movements around the Services.

How to Manage Cookies

If you are located in the European Economic Area, Switzerland, or the United Kingdom, when you first visit onvibe.co you will see a cookie consent banner that allows you to accept or reject non-essential cookies, including our analytics cookies, before they are set. You can change your cookie preferences at any time by adjusting your settings via the cookie preference link in the website footer. For all users, cookies are also managed through web browsers, so please review your web browser settings to modify your cookie settings, to disable the use of cookies, or to delete cookies. The National Advertising Initiative provides a helpful overview for disabling cookies. Please note that if you delete, or choose not to accept, cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

Types of Cookies

Cookies can be categorized in different ways:

• First-Party vs. Third-Party Cookies: If we use first-party cookies, we put them on your device. Third party cookies are placed on your device by a third party. You can learn more about the third-party cookies used on the Services below.
• Duration:
  • Session Cookies: Temporary cookies that expire once your session on the Services ends or your web browser is closed.
  • Persistent Cookies: Cookies that remain on your device for a longer period until you manually erase them or until their expiration date.
• Purpose:
  • Necessary Cookies - These cookies are necessary for us to operate the Services and their core features (e.g., account login).
  • Functionality Cookies – These cookies enable us to operate the Services in accordance with the choices you make. These cookies permit us to “remember” you in between visits. For instance, we will recognize your username and remember how you customized the Services (e.g., language preference, location), and these cookies allow us to provide you with the same customizations during future visits.
  • Analytical - These cookies analyze how the Services are used (e.g., browsing habits) and how the Services are performing.

First-Party Cookies That We Use

We do not use first-party cookies for analytics, advertising, or automatic collection of information about users. We use a small number of strictly functional cookies for authentication and security: a session cookie that keeps you logged in (valid for up to 30 days, sliding, and invalidated on sign-out), a CSRF-protection cookie and a callback-URL cookie used during login (both session-scoped, containing no personal information), and a short-lived (10-minute), single-use cookie used to secure the Instagram connection flow, which is deleted immediately after use.

We do not use third-party cookies on the Services, other than Google Analytics through Google Tag Manager (onvibe.co only), which we only set with your consent as described above if you are located in the European Economic Area, Switzerland, or the United Kingdom. We use Mixpanel for product analytics and Sentry for error monitoring and session replay, but both are configured not to use cookies: Mixpanel stores its identifier in your browser's local storage rather than in a cookie, and Sentry does not set cookies. We do not use HubSpot tracking, Meta or Facebook pixels, or any other third-party advertising cookies.

Web Beacons.

We do not currently use web beacons or tracking pixels in the Services or in our marketing and transactional emails. Our email delivery provider has the technical ability to enable email open and click tracking at the account level; if we enable this feature, we will update this Policy accordingly.