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Privacy Policy

Last updated: March 11, 2026

1. Introduction

Second Enlightenment Global Private Limited (UEN 202530874K) (“Sunra,” “we,” “us,” or “our”), a company registered in Singapore, respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI media generation platform (“the Service”).

For users in the UK and EU, Sunra is the data controller for the personal data described here, and we process it in line with the UK GDPR and EU GDPR. For a plain-language overview of how we protect your data and the AI providers we use, see our Trust & Security page.

2. Information We Collect

2.1 Information You Provide

  • Account data: email address, name, and profile information when you register
  • Payment data: billing information processed securely through our third-party payment processor
  • User content: prompts, text inputs, and uploaded images you provide to generate content
  • Communications: messages you send to our support team

2.2 Information Collected Automatically

  • Usage data: pages visited, features used, generation history, and interaction patterns
  • Device data: browser type, operating system, device identifiers, and screen resolution
  • Log data: IP address, access times, and referring URLs
  • Cookies: session cookies and analytics cookies to improve your experience

3. How We Use Your Information

We use the information we collect to:

  • Provide, operate, and maintain the Service
  • Process your AI content generation requests
  • Manage your account and provide customer support
  • Process transactions and send billing notifications
  • Improve and personalize your experience through analytics
  • Send service-related communications (updates, security alerts)
  • Detect, prevent, and address fraud or abuse
  • Comply with legal obligations

3.1 Legal Basis (UK/EU Users)

Where the UK or EU GDPR applies, we rely on the following legal bases: performance of a contract (to provide the Service you request), legitimate interests (to secure, maintain, and improve the Service and prevent abuse, and to send account holders occasional email updates about the Service and its features — you can opt out at any time via the unsubscribe link in any such email or in your account settings), consent (for optional analytics cookies and third-party marketing, which you can withdraw at any time), and legal obligation (to comply with applicable law).

4. How We Share Your Information

We do not sell your personal information. We may share your information with:

  • Service providers: third-party vendors (sub-processors) that help us operate the Service — hosting, analytics, payment processing, and AI model providers. We publish the current list, including what each receives and where it operates, on our sub-processor page.
  • Legal compliance: when required by law, regulation, legal process, or governmental request
  • Business transfers: in connection with a merger, acquisition, or sale of assets
  • With your consent: when you have given explicit permission for a specific sharing purpose

5. AI-Generated Content

Because Sunra aggregates many AI models, the prompts and media you submit for a generation are sent to the third-party provider behind the model you choose (for example OpenAI, Google, ByteDance, or Kuaishou). We list every provider openly — including the data each receives and its region — on our sub-processor page. We do not use your prompts or generated content to train our own AI models, and we are securing written no-training / no-retention commitments from these providers.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. Generated content is stored for your convenience and may be deleted upon account termination. We may retain certain data as required by law or for legitimate business purposes (e.g., fraud prevention).

7. Data Security

We implement industry-standard security measures to protect your information, including encryption in transit (TLS/SSL) and at rest. However, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security but are committed to promptly addressing any breaches.

8. Your Rights & Choices

Depending on your location, you may have the following rights:

  • Access: request a copy of the personal data we hold about you
  • Correction: request correction of inaccurate or incomplete data
  • Deletion: request deletion of your personal data, subject to legal requirements
  • Portability: request your data in a machine-readable format
  • Opt-out: unsubscribe from marketing emails at any time
  • Object / restrict: object to or restrict processing based on our legitimate interests
  • Complaint: lodge a complaint with your data protection authority. In the UK this is the Information Commissioner's Office (ICO)

To exercise these rights, contact us at privacy@ponpon.ai.

9. Cookies

We use essential cookies to keep you signed in and maintain session state. We also use analytics cookies to understand how the Service is used. You can control cookie preferences through your browser settings, though disabling cookies may limit certain features.

10. Children's Privacy

The Service is not directed to children under the age of 13. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 13, we will take steps to delete it promptly.

11. International Transfers

Your information may be transferred to and processed in countries other than your own, including the United States. We ensure appropriate safeguards are in place to protect your data in accordance with applicable data protection laws.

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by updating the “Last updated” date and, where appropriate, providing additional notice (such as an email or in-app notification). Your continued use of the Service after changes constitutes acceptance.

13. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at privacy@ponpon.ai.