Privacy Policy for AI Portraits

Effective Date: October 7, 2025

Last Updated: October 7, 2025

1. Information We Collect

1.1 Photos and Facial Images

What We Collect:

• Photos containing facial images that you voluntarily upload from your device photo library or capture using your device camera
• These photos are used exclusively for AI portrait generation

What We DO NOT Collect:

• We do NOT collect, extract, or store biometric facial recognition data
• We do NOT extract facial measurements, facial feature vectors, or facial landmarks
• We do NOT create facial templates or facial signatures
• We do NOT perform facial identification, authentication, or recognition
• We only process the complete photo image as provided by you

1.2 Other Personal Information

We may also collect:

• Device information (iOS version, device model, device identifier)
• App usage analytics (features used, session duration)
• Purchase history for in-app coin purchases
• Crash reports and performance data

1.3 Automatically Collected Information

We automatically collect:

• App performance metrics
• Error logs and crash reports
• Feature usage statistics
• Advertising identifier (IDFA) only if you provide consent through App Tracking Transparency

2. How We Use Your Information

2.1 Face Data and Photo Usage

Primary Purpose: Photos containing facial images are used EXCLUSIVELY for:

• AI Portrait Generation: Transforming your photos into professional AI-generated portraits
• Real-time Processing: Photos are transmitted to Google Gemini AI API for immediate processing
• Display and Preview: Original and generated portraits are temporarily displayed in the app for your review
• Optional Saving: You can choose to save generated portraits to your device photo library

What We DO NOT Do with Face Data:

• We do NOT use photos for facial recognition or identification
• We do NOT use photos for user authentication or verification
• We do NOT use photos to train AI models
• We do NOT use photos for advertising or marketing purposes
• We do NOT analyze facial features for demographic profiling
• We do NOT share photos with any parties other than Google Gemini AI API

2.2 Other Data Usage

We use other collected information to:

• Provide and improve our services
• Process in-app coin purchases through Apple App Store
• Analyze app performance and fix bugs
• Comply with legal obligations
• Provide customer support

3. Information Sharing and Third-Party Services

3.1 Face Data Sharing

Google Gemini AI API (Third-Party AI Service):

• Purpose: Your photos are transmitted to Google’s Gemini AI API solely for AI portrait generation
• Transmission: Photos are sent via secure HTTPS encrypted connection
• Processing: Google processes your photos in real-time to generate AI-enhanced portraits
• Retention by Google: According to Google’s API terms and policies:
  • Your photos are NOT used to train Google’s AI models
  • Your photos are NOT retained by Google after processing is complete
  • Photos are processed and immediately discarded
• Google’s Privacy Policy: https://policies.google.com/privacy
• Google’s Terms of Service: https://policies.google.com/terms

No Other Third-Party Sharing of Face Data:

• We do NOT share your photos or face data with any other third parties
• We do NOT sell your photos or facial data to anyone
• We do NOT use your photos for advertising purposes

3.2 Other Third-Party Services

We share non-photo data with:

• Apple App Store: For payment processing and app distribution
• Firebase (Google): For remote configuration and analytics (no photo data)
• Legal Authorities: When required by law or to protect our rights

4. Data Storage and Retention

4.1 Face Data and Photo Storage

Critical Information:

• NO Server-Side Storage: We do NOT store or retain your photos on our servers or any cloud storage
• Device-Only Storage: Photos remain on your device only
• Temporary Memory: Photos are held temporarily in device memory only during active use
• Automatic Clearing: Photos are automatically cleared from memory when you:
  • Close the app
  • Navigate away from the photo processing screen
  • Complete the portrait generation session
  • Force quit the app
• Generated Portraits: AI-generated portraits are only saved to your device photo library if YOU explicitly choose to save them
• No Cloud Backup: We do not maintain any cloud storage, backup, or archive of your photos

4.2 Photo Retention Duration

Retention Timeline:

• During Processing: Photos are held in device memory for 30-120 seconds during AI processing
• During Preview: Photos are held in memory while you preview the generated portrait
• After Session: Photos are immediately cleared from memory when session ends
• Total Maximum Retention: Less than 5 minutes in device memory
• By AIPortrait: Zero retention on any servers or cloud storage
• By Google Gemini API: Zero retention after processing (per Google’s API terms)

4.3 Other Data Retention

• Coin Balance: Stored securely on your device in iOS Keychain until you delete the app
• Purchase History: Retained as required by Apple and tax regulations (typically 7 years)
• Analytics Data: Aggregated and anonymized data retained for 24 months
• Crash Reports: Retained for 12 months for debugging purposes

5. Data Security

We implement comprehensive security measures to protect your data:

5.1 Photo and Face Data Security

• Encryption in Transit: All photos are transmitted to Google Gemini API via HTTPS with TLS 1.3 encryption
• Secure API Communication: API keys are securely managed through Firebase Remote Config
• No Persistent Storage: Photos are never written to disk or persistent storage
• Memory Protection: Photos are held in secure memory and cleared immediately after use
• No Screenshot Protection: System screenshots may capture photos while in use (standard iOS behavior)

5.2 General Security Measures

• Industry-standard encryption for all data transmission
• Secure keychain storage for sensitive app data (coin balance)
• Regular security audits and updates
• Limited employee access to systems (no access to user photos)
• Compliance with Apple App Store security requirements

6. Your Rights and Choices

6.1 Control Over Your Photos

You have complete control over your photos:

• Voluntary Upload: You choose which photos to upload or capture
• No Automatic Access: We never access your photo library without your explicit permission
• Immediate Deletion: Simply close the app to clear all photos from memory
• No Retention: We cannot provide copies of your photos because we don’t store them
• Device Storage Only: Generated portraits are only on your device if you save them

6.2 General Privacy Rights

You have the right to:

• Access: Request information about what personal data we have (excluding photos which we don’t store)
• Deletion: Request deletion of your data by deleting the app
• Opt-Out: Disable App Tracking Transparency in iOS Settings
• Data Portability: Request a copy of your purchase history
• Withdraw Consent: Stop using the app at any time
• Complaint: File a complaint with your local data protection authority

6.3 iOS Privacy Controls

Control AIPortrait’s access through iOS Settings:

• Camera Access: Settings > AIPortrait > Camera
• Photo Library Access: Settings > AIPortrait > Photos
• Tracking: Settings > Privacy & Security > Tracking

7. Children’s Privacy

Age Restriction: AIPortrait is rated 4+ but is not intended for independent use by children under 13.

• We do NOT knowingly collect personal information, including photos, from children under 13
• Parents/guardians should supervise children’s use of the app
• If we become aware that we have collected information from a child under 13, we will delete it immediately
• Parents can contact us to request deletion of their child’s data

Parental Consent: If you are under 13, please ask your parent or guardian to review this Privacy Policy and provide consent before using AIPortrait.

8. International Data Transfers

Your data, including photos during processing, may be transferred to and processed in countries other than your own:

• Google Gemini AI: Photos are processed on Google’s servers, which may be located in various countries
• Safeguards: We ensure appropriate safeguards including:
  • Encryption during transmission
  • Data processing agreements with Google
  • Compliance with GDPR, CCPA, and other privacy regulations
• European Union: Data transfers comply with GDPR requirements
• United States: Some data may be processed in the United States

9. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), our legal basis for processing your data:

• Consent: You provide explicit consent by uploading photos for AI portrait generation
• Contract Performance: Processing is necessary to provide the service you requested
• Legitimate Interests: We have legitimate interests in improving our app and preventing fraud
• Legal Obligation: We may process data to comply with legal requirements

10. Cookies and Tracking Technologies

App Tracking Transparency (ATT):

• We request your consent before tracking you across apps and websites owned by other companies
• You can change tracking preferences: iOS Settings > Privacy & Security > Tracking
• Denying tracking does NOT affect core app functionality (AI portrait generation)

What We Track (with consent):

• App usage patterns and feature engagement
• Advertising attribution (to measure ad effectiveness)
• Aggregated analytics data

What We Don’t Track:

• Your specific photos or portrait content
• Facial recognition or biometric data

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements:

• Notification: We will notify you of material changes through:
  • In-app notification
  • Updated “Effective Date” at the top of this policy
  • Email (if we have your email address)
• Your Consent: Continued use of the app after changes constitutes acceptance of the updated policy
• Version History: Previous versions available upon request

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices:

Email: privacy@dgndevs.online

Support: support@dgndevs.online

Website: https://dgndevs.online/aiportrait/

Response Time: We aim to respond to all privacy inquiries within 30 days.

13. Regional Privacy Rights

13.1 European Union – GDPR Rights

If you are in the EU, you have additional rights under the General Data Protection Regulation (GDPR):

• Right to Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Request limitation of data processing
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time
• Right to Lodge a Complaint: File a complaint with your supervisory authority

EU Data Protection Authority: You can find your local authority at https://edpb.europa.eu/

13.2 California – CCPA/CPRA Rights

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

• Right to Know: Request disclosure of personal information collected, used, and shared
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt-out of sale/sharing of personal information (we don’t sell data)
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit: Limit use and disclosure of sensitive personal information
• Right to Non-Discrimination: We will not discriminate for exercising your rights

Do Not Sell My Personal Information: We do NOT sell your personal information.

13.3 Other Regions

Depending on your location, you may have additional privacy rights under local laws. Contact us to learn more about rights available in your jurisdiction.

14. Data Breach Notification

In the unlikely event of a data breach affecting your personal information:

• We will notify affected users within 72 hours of discovering the breach
• We will notify relevant regulatory authorities as required by law
• We will provide information about the nature of the breach and remedial actions

Note: Since we do NOT store photos on our servers, there is no risk of a photo data breach from our systems.

15. Summary – Key Points