Captivately

Effective Date: October 27th, 2025
App Name: Captivate.ly
Data Controller: ANIPSIA

1. Introduction

At ANIPSIA, we are committed to protecting your personal data and your privacy. This Privacy Policy explains how we collect, use, and protect personal information when you use Captivate.ly, our mobile application for AI-powered social media caption generation and publishing.

This policy is compliant with the General Data Protection Regulation (GDPR) (EU) and the Swiss Federal Act on Data Protection (FADP/DSG).

2. Who We Are

ANIPSIA sagl is the legal entity responsible for the collection and processing of your personal data via Captivate.ly.
Registered Address: Via Emilio Bossi 35, 6830 Chiasso, Switzerland
Contact Email: privacy@anipsia.com

3. What Personal Data We Collect

When you use Captivate.ly, we may collect the following types of personal data:

• Authentication Data

  • Email account used to sign in

• Uploaded Content

  • Images you select for caption generation and posting

  • Short prompts you enter to guide the AI-generated captions

• Usage Data

  • Caption drafts, edits, and publishing activity

  • Device type and technical diagnostics (for debugging and quality assurance)

• Metadata

  • Timestamps, file type, anonymized filename, and IP logs (for hosting and security)

4. How We Use Your Data

We process your data for the following purposes:

• To allow you to sign in and access your account

• To generate caption drafts using Google Gemini based on your images and text prompts

• To enable you to post to Instagram and LinkedIn via their APIs

• To temporarily host images in an anonymized and unlisted cloud bucket for up to 24 hours for API compatibility

• To improve the performance and reliability of the app

• To comply with legal obligations if misuse or illegal content is detected

We do not use your data for advertising, profiling, or third-party marketing.

5. Legal Basis for Processing

We rely on the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR) – to provide the services you request

• Consent (Art. 6(1)(a) GDPR) – where required, such as API posting or LLM-based caption generation

• Legitimate interests (Art. 6(1)(f) GDPR) – for debugging, quality control, and improving service

• Legal obligation (Art. 6(1)(c) GDPR) – in cases of suspected illegal content

6. Data Retention

We retain personal data as follows:

• Uploaded images are stored in a secure, anonymized, public-but-unlisted bucket for up to 24 hours and then automatically deleted.

• User activity logs and caption drafts are retained for up to 90 days, unless you request deletion sooner.

• Authentication logs and diagnostic data are retained for up to 180 days for audit and error resolution.

A full data retention schedule is provided in our [Personal Data Policy].

7. Third-Party Services

We work with the following third-party providers:

• Google Gemini – used for processing your uploaded images and prompts to generate caption suggestions.

• Instagram Graph API – used to publish posts to your linked Instagram account, only with your action.

• LinkedIn API – used to publish posts to your LinkedIn account, only with your action.

• Cloud Hosting Provider – used to host image files temporarily to comply with social media API requirements.

These providers process data on our behalf and are bound by appropriate data processing agreements (DPAs).

8. Data Transfers

Where data is transferred outside of Switzerland or the EU (e.g. to U.S.-based services like Google), we ensure adequate protection through:

• Standard Contractual Clauses (SCCs)

• Approved third-party certifications

• Data minimization and encryption

9. Your Rights

As a user in Switzerland or the EU, you have the following rights:

• Right to Access – Obtain a copy of your data

• Right to Rectification – Correct inaccurate or incomplete data

• Right to Deletion – Request erasure of your personal data

• Right to Data Portability – Receive your data in a portable format

• Right to Restrict Processing – Temporarily stop processing under certain conditions

• Right to Lodge a Complaint – With your national data protection authority

10. Export / Deletion Requests

You may request a copy of your personal data or ask for deletion at any time by contacting us at:

Email: privacy@anipsia.com

We will respond to verified requests within 30 days, as required by applicable law.

11. Data Security

We implement technical and organizational safeguards including:

• Encrypted transmission (HTTPS, secure storage)

• Access controls and logging

• Limited access to hosted data

• Auto-expiry mechanisms for image storage

12. Children’s Privacy

Captivate.ly is not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be announced via the app or email.

14. Version History

• v1.0 – October 27th, 2025 – Initial version

15. Contact

If you have any questions about this policy or our data practices, please contact:

ANIPSIA sagl
Via Emilio Bossi 35, 6830 Chiasso, Switzerland
Email: privacy@anipsia.com