Pombu · Privacy

Privacy Policy

Pombu is a film library of independent creators. You watch without an account, without ads and without tracking tools. We collect only what the app really needs, and we never sell your data.

Effective 26 October 2026 · version 1.1

1. Who processes your data

The controller of the Pombu app and the pombu.com website is 2-morrow s.r.o., Kravany 113, 059 18 Kravany, Slovakia, company ID (IČO) 36 839 523 (“we”).

For questions about personal data, requests to exercise your rights and notices under the Digital Services Act, write to support@pombu.tv. We reply in English or Slovak.

2. Watching without an account

When you open the app for the first time, it creates an anonymous guest session: a random identifier stored on your device and on our side. It has no e-mail, name or phone number. Linked to it we store:

• the app language,
• films you liked or saved and creators you follow,
• where you stopped in a film, so you can continue,
• view events (which film, when, for how long, whether you finished it, language and approximate country), which we turn into aggregated statistics.

Why and on what basis: so you can watch, continue where you left off and keep your saved films. This is providing the service you ask for (performance of a contract, Art. 6(1)(b) GDPR). Aggregated statistics are based on our legitimate interest (Art. 6(1)(f)), see section 7.

If you delete the app, you will usually no longer be able to reach the guest session data. We delete guest sessions that have not been used for 12 months. When you sign in to an account, the likes, saved films, films in progress, and followed and blocked creators from the guest session move to the account and the guest session ends.

3. Account and sign-in

You need an account only to create. We store in it:

• your e-mail address,
• display name, username (@handle) and avatar, if you set one,
• language,
• when the account was created, when you last signed in and when you accepted the Terms of Use.

We have no password. You sign in with a code or link we send to your e-mail; the code is valid for a few minutes and can be used once. We use your e-mail only for sign-in, important account notices and replies to your messages. We do not send you marketing e-mails without your consent.

Your display name, @handle and avatar are shown with your films and on your creator profile. We never publish your e-mail. You cannot create an account without an e-mail address; you can watch without one.

Basis: performance of a contract (Art. 6(1)(b)).

4. Creating in Pombu Studio

Pombu Studio generates characters, places, frames, voices and video from your instructions. You can also upload a film you shot yourself. We store:

• projects: titles, stories, scripts, text instructions, reference images you upload and everything generated from them,
• films you upload or publish, with title, description, category and age rating,
• voice instructions: when you dictate an instruction, we transcribe the recording. We keep the audio only until the transcript is ready, at most 24 hours; only the text of the instruction stays in the project,
• generation records: what was generated, when, how many credits it cost and whether it succeeded.

If you upload photos, video or voice of real people, you need their consent (see the Terms of Use). We use such material only for your project; we do not use it to recognise or identify people.

An unpublished project is visible only to you. When you publish a film, it is public and anyone on Pombu can watch it. Every generated film is labelled as synthetic content (Art. 50 of the EU AI Act) and exports carry the Pombu logo and pombu.com.

Generation runs through our own gateway: when you start a step, our server sends your instructions and material to the processor that performs it (list in section 13). Nothing is sent to processors without your instruction. The processor does not receive your e-mail, name or profile. Instructions and results pass automated safety checks (ours and the processors’) so that prohibited content is not produced.

Basis: performance of a contract (Art. 6(1)(b)); safety checks and moderation are based on our legitimate interest (Art. 6(1)(f)) and our obligations under the Digital Services Act (Art. 6(1)(c)).

5. Linking ChatGPT

Connecting. If you wish, you can connect your Pombu account to your own ChatGPT account through the Pombu app in ChatGPT. You sign in on the Pombu page (OAuth, by confirming in the Pombu app or with a code from your e-mail) and allow projects:read (read your projects) and projects:write (create and edit your projects). We do not receive your ChatGPT password or access to your ChatGPT account. We store a connection record (date, the connected application, granted permissions, last use) and the connection's access tokens only as one-way hashes, so we can never read them. An access token is valid for 1 hour, a refresh token for 90 days, and it changes on every use.

What Pombu gives ChatGPT about your account. The profile tool and the /oauth/userinfo endpoint return the permanent Pombu account identifier, your display name, your handle and your account e-mail, so ChatGPT knows which Pombu account it is working with.

What the tools read and write. All tools work only with the content of your connected account:

• projects and their content: idea, title, story, episodes, characters (look, personality), locations, scenes, emotion curve, shots with camera and dialogue. ChatGPT writes them as you create with it and gets them back when it reads a project;
• images: when ChatGPT sends an image (a file or a public https address), Pombu downloads it and stores it in your Studio; ChatGPT receives temporary signed links (24 hours) to the images of your shots and characters;
• image generation, prices and jobs: the price of an action in credits, your balance and the status of started jobs;
• your films: the list of your films with their status, and taking a film you published off the catalogue;
• trash: the items in your trash and the date they will be permanently deleted;
• statistics: only aggregate numbers of your films (views, watch time, likes, saves, shares, completion, followers), never data about individual viewers;
• credits: balance, recent changes and the price list.

ChatGPT never receives passwords, codes, access tokens or internal identifiers of other people from Pombu. We do not see your other ChatGPT conversations.

Director's notes. Before each stage Pombu prepares short notes for your project. When extended processing is enabled, your project content (without your e-mail and name) is processed to generate the text by our processor OpenAI through the Pombu gateway (section 13).

What ChatGPT sends us. Besides the content ChatGPT writes, it may send the interface language (used only for the language of answers) and an anonymised session identifier that we do not store. What you enter in ChatGPT itself is governed by OpenAI's privacy policy; OpenAI is responsible for ChatGPT and your conversations there.

No selling, no ads. We do not sell data from the ChatGPT link, we do not share it for advertising and we do not use it to build advertising profiles.

Retention. Access tokens 1 hour (refresh tokens 90 days), deleted within 7 days after they expire; connection requests 10 minutes (deleted within 1 day); the connection record until the connection is revoked or you delete your account; project content like any other Pombu content; trash items 30 days, then permanently deleted; security and audit records of connecting, disconnecting and misuse attempts for the periods in section 14.

Your control. You can disconnect at any time in ChatGPT settings; Pombu tokens that are no longer used expire (access tokens after 1 hour, refresh tokens after 90 days). Write to support@pombu.tv and we will revoke the connection at once. Deleting your Pombu account deletes all connections and tokens. Paid actions never start before you have seen and confirmed the price. Basis: performance of a contract at your request (Art. 6(1)(b)).

6. Credits and purchases

You buy generation credits through the App Store. Apple processes the payment; we never see your card number or other payment details. Apple sends us a purchase confirmation: transaction ID, the pack bought, the date and the App Store country. We store credit movements on your account (added, reserved, used, returned).

Apple also processes purchase data as an independent controller under its own privacy policy.

Basis: performance of a contract (Art. 6(1)(b)); keeping accounting records is a legal obligation (Art. 6(1)(c)).

7. Likes, follows and statistics

We store likes, saved films, creators you follow and films in progress on your account or guest session. Only you can see your saved films and films in progress.

We turn view events into aggregated statistics. A creator sees totals (for example the number of views, likes and followers), not a list of individual viewers. We also use the totals to show new and popular films in the app. We do not build advertising profiles from them and we do not sell them. Individual view events are deleted after 90 days; after that only totals remain, with no link to you.

Basis: performance of a contract (saved films, continue watching); legitimate interest (statistics for creators, running and improving the catalogue).

8. Reports, blocking and moderation

When you report a film, profile or creator, we store who reported what, the reason, your note and the time. For a notice of illegal content under the Digital Services Act, also the name and e-mail you provide. We do not reveal your identity to the reported creator unless this is necessary to handle the notice (for example a claim that your copyright was infringed) or required by law.

We store the list of creators you blocked so that their content is not shown to you. We also store moderation decisions: what we removed or restricted, why, and the statement of reasons we sent to the creator concerned.

Basis: legitimate interest in a safe community (Art. 6(1)(f)) and obligations under the Digital Services Act (Art. 6(1)(c)).

9. Notifications

Notifications are optional. If you allow them on your iPhone, we store the device token from Apple and your notification preferences (for example a new film from a creator you follow, or a finished generation). Notifications are delivered by the Apple Push Notification service. You can turn them off in iPhone or app settings; we delete invalid tokens.

Basis: your consent (Art. 6(1)(a)), which you withdraw by turning notifications off.

10. Support

When you write to support@pombu.tv, we process your e-mail address, the message and any attachments to help you. Messages are read and handled by people.

Basis: performance of a contract and our legitimate interest in answering you (Art. 6(1)(b) and (f)).

11. Security logs

Our server records technical data with requests: IP address, time, requested address, app and system version, and result. These logs protect against attacks, abuse and fraud (for example limiting sign-in attempts). We delete them after 30 days unless we need them to investigate a specific security incident.

For the guest session and for every signed-in device we store sign-in data: the device identifier within the app, platform, app version, app identification (user agent) and a fingerprint (hash) of the IP address, not the address itself. We store the same IP fingerprint with requests for a sign-in code and in an audit record of important account actions (for example sign-in, e-mail change, purchase, account deletion, moderation decision), so that we can detect and investigate abuse.

Basis: legitimate interest in the security of the service (Art. 6(1)(f)).

12. Legal bases at a glance

• Performance of a contract (Art. 6(1)(b) GDPR): watching, guest session, account, creating and generating, ChatGPT link, credits, support.
• Legitimate interest (Art. 6(1)(f)): security, abuse prevention, moderation, aggregated statistics, defence of legal claims. You can object to processing on this basis at any time.
• Legal obligation (Art. 6(1)(c)): accounting and tax records, Digital Services Act obligations, replies to public authorities.
• Consent (Art. 6(1)(a)): notifications. You can withdraw consent at any time; this does not affect the lawfulness of earlier processing.

We do not make decisions with legal or similarly significant effects based solely on automated processing (Art. 22 GDPR). Automated filters may stop the generation of clearly prohibited content; a person decides on removing a published film or blocking an account.

13. Processors and transfers outside the EU

Pombu runs on our own servers rented in the EU. These processors help us; each receives only what it needs for its task and processes it under a contract with us:

• Contabo GmbH (Germany): rental of the servers Pombu runs on. Data and media (films, images, audio) are stored in the EU.
• Cloudflare, Inc. (USA, global network): delivers and protects connections to the app and website; processes IP addresses and technical request data.
• BytePlus (ByteDance group, based in Singapore, servers in South-East Asia), Seedream and Seedance models: image and video generation. Receives frame instructions, reference images and the project material needed for that frame.
• OpenAI (USA): help with story and frame text, image and audio generation, transcription of voice instructions and automated safety checks of texts and images. Receives instructions, texts and reference images or the recording needed for that step.
• Google (Gemini, USA): text and image processing and generation. Receives instructions, texts and reference images needed for that step.
• Anthropic (USA): text processing, for example stories, scripts and frame descriptions. Receives the project texts needed for that step.
• ElevenLabs (USA): character voices and speech. Receives the line of dialogue and voice settings, or a recording to transcribe.
• Apple (Ireland and USA): App Store purchases and notification delivery. For purchases Apple is an independent controller.

Our server sends requests to the generation processors; they do not receive your e-mail, name or profile. Under their own terms they may keep inputs and outputs for a limited time for abuse monitoring. Where a service allows it, we choose settings under which content is not used to train models.

Transfers outside the EU. Some processors are based in or process data outside the EU (USA, South-East Asia). We protect such transfers with an adequacy decision of the European Commission (for the USA the EU–US Data Privacy Framework, where the company is certified) or with standard contractual clauses approved by the European Commission, together with supplementary measures such as encryption in transit and sending only the data that is necessary. We will send you a copy of the safeguards on request.

OpenAI (ChatGPT, USA) as a recipient: when you link ChatGPT, the data the Pombu tools return (section 5) goes to your ChatGPT account at your request. For ChatGPT, OpenAI is an independent controller under its own privacy policy.

We do not share your data with anyone else, except where the law requires it (for example at the request of a court or the police) or where there is a serious threat to people’s life or safety.

14. How long we keep data

• Account and profile: until you delete the account.
• Guest session: 12 months after the last activity.
• Sign-in codes and links: valid for a few minutes; records are deleted one day after they expire.
• Device sign-in data: while the sign-in is valid (at most 12 months) and for 30 more days after sign-out or expiry.
• Projects, material and unpublished results: until you delete them or your account.
• Published films: until you take them down, delete your account, or we remove them in moderation.
• Audio of voice instructions: at most 24 hours; the text of the instruction stays in the project.
• Individual view events: 90 days, then only totals with no link to you.
• Purchases and credit movements: for the life of the account. Records required by accounting and tax law are kept for the statutory period (at most 10 years), also after account deletion, without the profile.
• Reports and moderation decisions: 12 months after resolution; if a dispute or proceedings are ongoing, until they end.
• Account terminated for a serious violation: we may keep a one-way fingerprint (hash) of the e-mail for at most 2 years so that a banned person cannot return right away.
• Blocked creators: until you unblock them or delete your account.
• Notification token: until you turn notifications off, sign out or the token expires.
• Support e-mails: 12 months after the last message in the conversation.
• Security logs with IP address: 30 days.
• ChatGPT link: the connection record until the connection is revoked or you delete your account; access tokens 1 hour and refresh tokens 90 days, deleted within 7 days after they expire; connection requests 10 minutes, deleted within 1 day.
• Trash: 30 days, then permanently deleted.
• Audit record of important account actions (with IP fingerprint): 12 months.
• Backups: used only to recover from failures and kept for at most 6 months. Data we have already deleted may therefore remain in them for up to that time.

15. Children

Children can watch fairy tales (Rozprávky) and films rated “For everyone” without an account. Only people aged 16 or over may create a creator account. If we learn that an account belongs to someone younger, we delete it.

We do not knowingly collect personal data from children beyond the anonymous guest session. We have no ads, we do not profile children, and we use their viewing only to continue films, keep saved films and produce aggregated statistics. If a parent learns that a child under 16 has given us personal data, they can write to us and we will delete it.

16. Your rights

Under the GDPR you have the right:

• of access to your data and to a copy,
• to rectification of inaccurate data,
• to erasure,
• to restriction of processing,
• to data portability: we will send the data you gave us (profile, projects, uploaded files) in a common machine-readable format,
• to object to processing based on legitimate interest,
• to withdraw consent at any time.

Write to support@pombu.tv from the e-mail of your account. We will reply without undue delay and at the latest within one month; for complex requests we may extend this by two further months and will tell you. We may ask you to verify your identity.

If you believe we handle your data unlawfully, you can lodge a complaint with the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov SR), Hraničná 12, 820 07 Bratislava 27, dataprotection.gov.sk, or with the supervisory authority in the EU country where you live or work.

17. Security

Connections to the app and website are encrypted (HTTPS). Only a small circle of authorised people can access servers and data. We do not use passwords, so no password of yours can leak from us; sign-in codes are short-lived and single-use, and we store codes and sign-ins only as fingerprints (hashes), not in readable form. We update and back up our systems regularly. If a personal data breach occurs, we will notify the supervisory authority within 72 hours and, where there is a high risk to you, you as well.

18. Deleting your account

You can delete your account right in the app: Library → Profile and settings → Delete account. This deletes the account and your personal data: profile, projects, material, likes, saved films, follows, the ChatGPT link and the notification token. Your published films are removed from Pombu. Unused credits are forfeited.

We keep only what the law requires us to keep (accounting records) and moderation records needed to defend legal claims, for the periods in section 14. Data disappears from backups within 6 months at the latest. We cannot delete copies of films you exported and shared outside Pombu.

If you cannot sign in, write to us from the e-mail you use on Pombu and we will delete the account for you.

19. Cookies and tracking

The app uses no advertising or analytics tools and does not track you across other apps or websites. On your device it stores only what it needs to work (guest identifier, sign-in, settings). These information pages set no cookies. The only exception would be a strictly necessary technical cookie from the Cloudflare network if, when it suspects an attack, it has to check that you are not a robot.

20. Changes to this policy

If we change this policy, we will update this page and the effective date. We will tell you about material changes in advance in the app or by e-mail.

Related: Terms of Use · Community Rules · Support