Legal · Privacy

Privacy Policy

Last updated April 8, 2026


Privacy Policy

Last updated: April 7, 2026

Victoria AI LLC ("Victoria AI," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your information when you use the Adaptive Content System ("ACS," "the Service").

By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Service.


1. Who We Are

Victoria AI LLC is the company behind the Adaptive Content System — an AI-powered content engine that helps users automate content strategy, generation, publishing, and analytics across multiple platforms.

For privacy questions, contact us at: privacy@adaptivecontentsystem.com


2. Information We Collect

2.1 Account Information

When you register, we collect your email address, name, and brand or business name. If you subscribe to a paid plan, payment is processed by Stripe — Victoria AI LLC does not store your full credit card number or billing details.

2.2 Content and Strategy Data

We store the content you create and manage through ACS, including:

  • Strategy documents and brand guidelines you configure
  • Ideas and content briefs stored in your Idea Bank
  • Drafted and published content pieces (articles, newsletters, social posts, threads)
  • Campaign records and weekly publishing plans
  • In-progress drafts and revision history from your compose sessions
  • Notes and feedback you attach to content

2.3 Platform Credentials and Tokens

When you connect third-party platforms, we store the credentials necessary to act on your behalf:

  • OAuth access tokens for LinkedIn, Twitter/X, and Google Search Console
  • API keys and credentials for Beehiiv, Kit (ConvertKit), Mailchimp, WordPress, and Ghost
  • Webhook tokens and HMAC secrets for webhook-based integrations (Substack, Webflow, Zapier, and custom destinations)

All credentials are stored encrypted and are used exclusively to operate the Service on your behalf. We do not share them with any party beyond the infrastructure required to provide the Service.

2.4 Analytics and Performance Data

We collect and store performance metrics from your connected platforms, including:

  • Impressions, clicks, opens, engagement rates, and conversion data
  • Analytics data received via inbound webhooks from your publishing platforms
  • Analytics pulled automatically via OAuth-connected platform APIs (e.g., Google Search Console weekly data, LinkedIn and Twitter/X engagement metrics)
  • Analytics data from manual file uploads you provide

2.5 Usage and Technical Data

We automatically collect certain technical information when you use the Service:

  • Log data (IP address, browser type, device type, pages visited, timestamps)
  • Authentication and session data
  • Feature usage patterns, used in aggregate for product improvement

2.6 Communications

If you contact our support team, we retain records of that correspondence.


3. How We Use Your Information

We use the information we collect to:

  • Provide the Service — Store your content, execute campaigns, publish to your connected platforms, and display analytics dashboards
  • Generate Content — Pass your strategy, ideas, and instructions to AI language model providers to produce content drafts on your behalf
  • Operate Integrations — Use your stored credentials to authenticate with connected platforms, publish content, and retrieve analytics
  • Deliver Notifications — Send transactional emails including campaign status updates, publishing confirmations, and billing receipts
  • Improve the Service — Analyze aggregated, de-identified usage patterns to improve features and performance
  • Billing and Fraud Prevention — Process payments, manage subscription status, and detect fraudulent activity
  • Legal Compliance — Comply with applicable laws, regulations, and lawful requests from authorities

We do not sell your personal data to third parties. We do not use your content to train AI models without your explicit consent.


4. How We Share Your Information

4.1 Connected Platforms (At Your Direction)

When you instruct ACS to publish content or retrieve analytics, we share the necessary data with the third-party platforms you have connected (e.g., posting to LinkedIn, sending a newsletter via Beehiiv). All such sharing occurs at your explicit direction.

4.2 Infrastructure Sub-Processors

We rely on the following third-party providers to operate the Service:

Provider Purpose
Supabase Database hosting, authentication, and serverless Edge Function execution
Railway Application hosting and deployment
Stripe Payment processing and subscription management
Third-Party AI Providers AI language model APIs used to generate content on your behalf

These providers process your data only as necessary to perform their services and are bound by appropriate data protection agreements.

4.3 Webhook Proxy

Outbound webhook deliveries are routed through our webhook proxy service, which forwards your content to the destination URLs you configure. The proxy does not retain payload content beyond the delivery attempt.

4.4 Legal Requirements

We may disclose your information if required by law, subpoena, court order, or other legal process, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Victoria AI LLC, our users, or the public.

4.5 Business Transfers

If Victoria AI LLC is involved in a merger, acquisition, or sale of all or substantially all of its assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a materially different privacy policy.


5. Cookies and Tracking

We use essential cookies and browser storage for:

  • Authentication and session management — Keeping you securely logged in across page loads
  • Security — CSRF protection and PKCE state tokens for OAuth authorization flows

We do not use advertising cookies, third-party tracking pixels, or behavioral analytics tools that track you across other websites. We do not participate in cross-site data sharing for advertising purposes.


6. Data Security

We implement industry-standard security measures to protect your information:

  • Row-Level Security (RLS) enforced at the database level — your data is logically isolated from all other users
  • Encryption in transit — All data is transmitted over TLS (HTTPS)
  • Encryption at rest — Data stored in our database is encrypted at rest
  • Credential protection — OAuth tokens, API keys, and HMAC secrets are stored in encrypted form
  • Webhook integrity — Outbound webhook payloads are signed with HMAC-SHA256 so recipients can verify authenticity

No security system is perfect. We cannot guarantee absolute security against all possible threats. If you become aware of a security concern relating to the Service, please notify us immediately at security@adaptivecontentsystem.com.


7. Data Retention

  • Active accounts — We retain your data for the duration of your account relationship with Victoria AI LLC.
  • Cancelled or terminated accounts — Your data is retained for 30 days following account closure, then permanently deleted. Please export any data you wish to keep before cancelling.
  • Encrypted backups — Deleted data may persist in encrypted database backups for up to 90 days before being purged from all systems.
  • Legal holds — We may retain certain data longer if required by applicable law or ongoing legal proceedings.

8. International Data Transfers

Our infrastructure is hosted in the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States. For users in the European Economic Area (EEA) or United Kingdom, such transfers are conducted in compliance with applicable data protection laws, including through appropriate safeguards such as Standard Contractual Clauses where required.


9. Your Privacy Rights

Depending on your location, you may have the following rights with respect to your personal data:

9.1 Right to Access and Portability You may request a copy of the personal data we hold about you, including in a portable format.

9.2 Right to Correction You may request that we correct inaccurate or incomplete information. Many profile fields can be updated directly in your account settings.

9.3 Right to Deletion You may request deletion of your account and all associated personal data. Submit a request to privacy@adaptivecontentsystem.com or delete your account from within the Service. Deletion will be completed within 30 days, subject to any legal retention obligations.

9.4 Right to Restriction You may request that we restrict processing of your data in certain circumstances (e.g., while you contest accuracy).

9.5 Right to Object You may object to certain processing activities, such as processing based on our legitimate interests.

9.6 Right to Withdraw Consent Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of these rights, contact us at privacy@adaptivecontentsystem.com. We will respond within 30 days (or within any shorter period required by applicable law). We may need to verify your identity before fulfilling a request.


10. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

  • Right to Know — Request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months, along with the purposes for collection and any third parties with whom it was shared
  • Right to Delete — Request deletion of personal information we have collected from you (subject to certain legal exceptions)
  • Right to Correct — Request correction of inaccurate personal information
  • Right to Opt-Out of Sale or Sharing — We do not sell your personal information or share it for cross-context behavioral advertising
  • Right to Limit Use of Sensitive Personal Information — We do not use sensitive personal information beyond what is necessary to provide the Service
  • Right to Non-Discrimination — We will not deny, charge different prices for, or provide a different level of service based on your exercise of CCPA rights

Categories of personal information collected in the past 12 months:

Category Examples
Identifiers Name, email address, IP address
Commercial information Subscription plan, billing history
Internet / network activity Usage logs, pages visited, session data
Professional information Brand name, content strategy, publishing platforms
Content Articles, newsletters, social posts, ideas
Inferences Content performance insights, strategy patterns

To submit a California privacy request, contact: privacy@adaptivecontentsystem.com


11. Children's Privacy

The Service is not directed at individuals under the age of 16. We do not knowingly collect personal information from anyone under 16. If we learn that a child under 16 has created an account or provided us with personal data, we will delete that information promptly. If you believe a child has submitted information to us, please contact us at privacy@adaptivecontentsystem.com.


12. Third-Party Platforms and Links

ACS connects to third-party platforms at your direction. This Privacy Policy does not apply to those platforms. Each connected platform has its own privacy policy governing how it collects and uses your data. We encourage you to review the privacy policies of any third-party service you choose to connect to ACS.


13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. If we make material changes, we will notify you via email or in-app notice at least 14 days before the changes take effect. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the Service after an updated Privacy Policy takes effect constitutes your acceptance of the changes.


14. Contact

Victoria AI LLC

For privacy inquiries and data rights requests: privacy@adaptivecontentsystem.com For security concerns: security@adaptivecontentsystem.com For general support: support@adaptivecontentsystem.com