Version of [DATE]
In short
- Webcam and microphone are processed on your computer, in real time. Images and sound are never sent and never stored. Only the calibrations, if you make them, keep a few measurements: an average profile of the vowels for the microphone, the extremes of your expressions for the face (section 2).
- Our software sends no image, no sound, no usage statistics and no crash reports, and contains no advertising and no cookies.
- The software connects to the Internet only to activate, check or release your licence key, with Polar, our reseller, and with our licence server, which keeps neither your key nor your details (section 3 a). Links open in your browser or your e-mail program.
- Payment is handled by Polar: we never see your card details.
- Everything the software keeps stays on your computer: in %APPDATA%\Ugokami, and the activation confirmation file in Documents\Ugokami. The licence file there is encrypted for your Windows account alone, and no identifier of your hardware is read or sent for the licence.
1. Data controller
[NOM ET PRÉNOM] EI, SIRET [SIRET], [ADRESSE]. Contact for any question about your data: contact@ugokami.com.
2. What stays on your computer
- Webcam images. The face tracking module, a program installed with the software, reads the camera and turns it into measurements (head orientation, eye and mouth opening, expressions) that animate your model. Images are processed in memory and discarded as they go: none is stored or sent. When you open the camera preview, a reduced image goes from the tracking module to the application through a connection internal to your computer, for display only.
- Microphone sound. Only the loudness and the vowel being spoken are computed, in real time, to animate the mouth. The sound is neither recorded nor sent.
- Microphone calibration. If you calibrate the microphone on your voice, the software keeps an average sound profile of each of the five vowels (a, i, u, e, o): twenty numbers per vowel, not a recording; nothing you said can be heard again from it. It keeps it in its settings. The voice calibration is saved in the model (.vtm), on your computer, with the microphone's gain setting: it goes with that file if you share it. "Test in Ugokami Studio" copies it into Ugokami Studio's library on the same computer; nothing is sent. A pack written with "Export file" contains it only if you tick "Include my voice calibration" for that export: the box is unticked at every export, and no choice is remembered. To clear it: "Forget all", in the "Voice calibration" window, then save the model; Ugokami Studio's copies go with the %APPDATA%\Ugokami folder (below).
- Tracking from a source other than the webcam (another tracking program or device, chosen in Ugokami Studio; some of these sources are still experimental). If you choose one, face measurements arrive from that source, from your computer or over your local network; for some, the application sends a request to the device address you entered (or to your whole Wi-Fi network). These measurements do not leave your network and are not stored.
- Graphics card. Like any program that displays images, the software reads your graphics card's model and its driver version, for display and the technical logs. This information is not sent.
- Your files (artwork, rigs, exported models) stay where you save them. We have no access to them.
- Settings and logs. The software keeps its preferences (language, chosen camera, tracking settings, face calibration, the tracking device's address and the authorisation given by a third-party tracking program if you use one, microphone and its calibration, window), the licence file (below) and technical logs. The face calibration, if you make one, keeps the extremes of your expressions, measured in ten seconds: a few numbers per measurement, no image. Everything is in %APPDATA%\Ugokami, shared by both programs. None of it is sent. Uninstalling leaves that folder in place; delete it to erase everything (if a key is activated, use "Forget this key" first: deleting the folder does not give its seat back). If you used a pre-release older than 0.9.0, its data is also in %APPDATA%\Redot\app_userdata\VTuber Engine: delete that folder too.
- Licence file. The first time it needs one, Ugokami Rig draws at random a pair of encryption keys of this installation's own; the installation identifier is the fingerprint of its public half. It comes neither from your hardware nor from your account. If you activate a key, Ugokami Rig keeps in %APPDATA%\Ugokami the key, that key pair (it never sends the private half), the activation identifier given by Polar, the certificate signed by our licence server (section 3 a), the plan (monthly or pass), the end date if there is one, the key's state, the version of the waiver text you ticked and the check dates. This file is encrypted by Windows for your Windows account alone (Windows's data protection, "DPAPI") and sealed against changes: it can only be read from your Windows session, and a copy shows your key to nobody else. To tie it to your account, Ugokami Rig reads no identifier of your hardware (serial number, network address, machine identifier): Windows does the encryption, with a key of your account's own. This file does not leave your computer.
- Signature of exports. Every exported pack ("Export file" or "Test in Ugokami Studio") carries your installation's certificate (a fingerprint of your key, the installation identifier, the plan, the period covered and our store's identifier), the public half of the installation's key pair, the date and time of the export, and a signature made with the private half. Ugokami Studio checks them on the computer that opens the pack, with no connection. The pack contains neither your name, nor your e-mail address, nor your key, nor any identifier of your hardware: to whoever receives it, these numbers do not say who you are; they only show that two packs come from the same installation. We do not receive your packs; with Polar's records, we could link these numbers to a purchase. They go with the pack if you share it.
- Activation confirmation file. When you activate a key, Ugokami Rig writes once a dated text file, Documents\Ugokami\Confirmation-activation-YYYY-MM-DD.txt ("-2" is added to the name for a second confirmation on the same day): the text you ticked, the date and time, the last 4 characters of the key, the activation's name, the seller, the publisher and the address of our refund policy. It is sent nowhere: it is your proof, keep it.
- OBS. Your avatar's image is shared with OBS (Spout) on your computer only.
3. What goes over the Internet
a) The licence (only if you enter a key)
It goes to two recipients: Polar, our reseller, which manages your key, and our licence server, which checks the key with Polar and signs the certificate that opens export on this installation.
On activation, Ugokami Rig sends Polar:
- your licence key;
- a name for this activation, "ugokami-…-rw1": the software's name, the beginning of the installation identifier (in place of "…") and the version of the waiver text you ticked ("rw1"). It says nothing about you or your computer: no computer name, no user name, no hardware number.
On activation, then at every check, Ugokami Rig sends our licence server:
- your licence key;
- the activation identifier Polar assigned;
- the public half of the installation's key pair (section 2), which says nothing about you;
- the version of the waiver text you ticked.
The server then asks Polar, with the key, the activation identifier and our store's identifier, whether the key is active and whether that activation is indeed this installation's. If so, it sends Ugokami Rig a signed certificate: a fingerprint of your key (from which the key cannot be recovered), the installation identifier, the plan, and the period covered (until the end of the pass; for the monthly plan, 30 days, extended at every check). Ugokami Rig keeps it in the licence file and copies it into every exported pack (section 2).
Checks take place at least once a week at start-up, at every start-up while the key is not confirmed, and every 10 minutes while export is locked during a session. If Polar no longer finds this computer's activation, Ugokami Rig activates the same key again with Polar, under the same name.
To free this computer's seat, Ugokami Rig sends Polar directly the key and the activation identifier: when you forget the key ("Forget this key"), when an activation is refused, and when a new key replaces the old one on this computer. "Forget this key" removes the key from the computer only once Polar has confirmed the seat is given back.
Polar answers with the key's state and, in the same answer, the details you gave it at purchase (name, e-mail address, billing name and address, and VAT number if you gave one). Neither Ugokami Rig nor our server stores that answer. Ugokami Rig keeps only the key's state, its plan (monthly or pass), its end date if it has one and the date of the check, in the encrypted licence file (section 2); the server uses it to decide, then forgets it, and sends Ugokami Rig nothing but the certificate.
Our licence server is hosted in a data centre in France by Hostinger International Ltd., established in the European Union, which acts on our behalf, as processor. The server has no database and keeps neither your key, nor your activation, nor your details. Your IP address, which any connection shows it, is never written: to limit the number of requests, the server keeps only a scrambled fingerprint of it in memory, for one hour at most. Its technical logs (start-ups, errors, and for each request the answer's code and how long it took) contain neither your key, nor your IP address, nor Polar's answer; a connection that fails before reaching the server may leave an IP address in the logs of its HTTPS front end. All these logs are erased after 14 days.
All these exchanges go over an encrypted connection (HTTPS), whose certificate Windows checks. Like any Internet connection, they reveal your IP address and a technical identification of the software, which says nothing about you (for example its name, its version and "Windows").
Purpose: checking that the subscription is active, limiting each key to one installation at a time, giving back the seat of an installation you no longer use, and signing the certificate that opens export on this installation. Legal basis: performance of the contract (GDPR article 6(1)(b)); for the limit on requests and the server's logs, our legitimate interest in protecting the server against abuse (GDPR article 6(1)(f)). The key, the activation identifier and the installation's public key are needed to unlock export; without them, everything else works (import, rigging, saving, Ugokami Studio). Ugokami Studio checks no licence at all and connects to nothing for it: it checks the packs' signature on your computer.
For the licence check, Polar acts on our behalf, as processor, whether Ugokami Rig or our server asks it. Polar is based in the United States. For the licence check, made on our behalf, the transfer is covered by the European Commission's standard contractual clauses provided for in its data processing agreement: https://polar.sh/legal/data-processing-addendum.
If the online check is no longer possible, you may ask us for a rescue code by writing to us with the installation identifier shown in the Subscription window and the e-mail address of the purchase (or the order number); do not send us your key. That code is a certificate we sign ourselves, offline: it holds a fingerprint of your key, that installation identifier and the end date of your paid period; it is valid only for that key and that installation, and Ugokami Rig checks it on your computer, with no connection.
b) Links
Links (checkout page, customer area, withdrawal form, Ugokami Studio's download page, the support e-mail address) open in your browser or your e-mail program.
c) Nothing else
No telemetry, no statistics, no automatic crash reports, no automatic update check, no advertising. The tracking module uses ONNX Runtime (Microsoft) with its diagnostic events turned off; Windows's own diagnostic settings remain those of your system.
4. Purchase, subscription and support: Polar and us
The subscription is sold by Polar (Polar Software, Inc., 3500 South DuPont Highway, Dover, DE 19901, US), as reseller ("merchant of record"). The roles:
- The purchase. Polar collects and processes the purchase data (name, e-mail address, country, billing address, payment method) as data controller, under its own privacy policy: https://polar.sh/legal/privacy. The safeguards covering the transfer of this data outside the European Union are described there. We never receive your card details.
- The licence check. Polar acts on our behalf, as processor (section 3 a).
- Subscription, refunds, support and security alerts. We are the data controller, and this data comes to us from Polar: in our seller area, we see your name, e-mail address, country and billing address (and your VAT number if you gave one), orders and subscription, and your licence key and its activations. We use them only to manage your subscription, refunds and support, and to warn you of a security problem. Legal basis: performance of the contract and, for security alerts, our legal obligation to inform users (Regulation (EU) 2024/2847, the Cyber Resilience Act).
5. Support, withdrawal and security by e-mail
- If you write to us, we keep your message and your address for as long as it takes to handle your request (legal basis: performance of the contract or, outside a contract, our legitimate interest in answering you).
- If you use "Withdraw from the contract here", we receive your first and last name, the e-mail address of the purchase or the order number, and the address to send the acknowledgement to (legal basis: our legal obligation, French Consumer Code, article L221-21).
- If you report a vulnerability to us, we keep your message to fix it and, where needed, to report it to the authorities.
6. Recipients
Your data is sold to no one. It is passed only to those who help us supply the software: Polar (purchase, subscription, licence); our licence server's host, Hostinger International Ltd. (section 3 a); our e-mail provider (support, acknowledgements, security alerts); our website's host, [HÉBERGEUR DU SITE]; the form tool that receives online withdrawals. We disclose it to an authority only where the law requires it.
7. The website
Our public page is hosted by [HÉBERGEUR DU SITE]. It sets no cookie or tracker and does not measure its audience. Like any web server, the host records visitors' IP addresses in its technical logs, for the site's security, and keeps them for one year at most. The checkout page and the customer area are Polar's, under its own policy.
8. How long
- Data at Polar: under its policy; we pass any erasure request on to it.
- Our licence server: nothing is kept; the IP address's fingerprint stays in memory for one hour at most, and the technical logs, without your key, 14 days.
- Our copies (seller-area statements, order notes): for the duration of the subscription, then 3 years so that we can answer a claim.
- Support and withdrawals: 3 years after the last exchange.
- Requests to exercise your rights: for as long as we need proof of our answer; any identity document asked for is deleted once checked.
- Accounting records: 10 years.
- Data on your computer: until you delete it.
9. Your rights
You may ask for access to your data, its correction, its erasure, the restriction of its processing, its portability, and object to its processing, by writing to contact@ugokami.com. We answer within one month. For purchase data, you may also contact Polar directly (privacy@polar.sh).
The only automated processing is the check of your key: depending on our reseller's answer, passed on by our licence server, export opens or closes. There is no profiling. If you believe a key is refused by mistake, write to us: we check it ourselves and restore access if the error does not come from you.
If you believe your rights are not respected, you may lodge a complaint with the CNIL, the French data protection authority: https://www.cnil.fr, or with the authority of the EU country where you live.
10. Changes
We will update this policy if the software changes what it sends; the date at the top gives the version in force.