Privacy Policy

Last Updated: December 26, 2024

Important Notice: AI Headshot Generator processes your photos to generate professional headshots. Your privacy is our top priority. We store your images securely and never sell or share them with third parties for marketing purposes.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy. You can find more details about any of these topics by clicking the links or using our table of contents below.

What personal information do we process?

When you use our Service, we process photos you upload, generated headshots, device information, usage statistics, and subscription data. We do NOT require account creation or collect contact information unless you contact support. Learn more →

Do we process any sensitive personal information?

We process facial images for headshot generation purposes only. These images are NOT used for biometric identification, authentication, or to create biometric templates. Images are processed temporarily and not used for AI model training without your consent. Learn more →

Do we collect any information from third parties?

We do not collect any information from third parties.

How do we process your information?

We process your information to generate AI headshots, store your generation history, manage subscriptions, improve our Service, and comply with legal obligations. We only process your information when we have a valid legal reason to do so. Learn more →

In what situations and with which parties do we share personal information?

We share information only with essential service providers: Supabase (cloud storage), RevenueCat (subscription management), Apple/Google (payment processing), and AI processing services. We do NOT sell or share your personal information for marketing purposes. Learn more →

How do we keep your information safe?

We use industry-standard encryption (HTTPS/TLS in transit, encryption at rest), secure cloud storage, access controls, and regular security audits. However, no electronic transmission can be 100% secure. Learn more →

What are your rights?

Depending on your location, you may have rights to access, delete, correct, or export your personal information. You can delete all your data anytime through our in-app deletion feature. Learn more →

How do you exercise your rights?

The easiest way is to use the in-app "Delete All Data" feature in Settings. You can also contact us at nikolai.bora.mindwise@gmail.com. Learn more →

Do we use cookies or tracking technologies?

We use minimal analytics and device storage for app functionality. We do not use cookies or web tracking technologies. Learn more →

TABLE OF CONTENTS

  1. Face Data Disclosure (Apple Policy 2.1)
  2. Introduction
  3. What Information Do We Collect?
  4. How Do We Process Your Information?
  5. What Legal Bases Do We Rely On To Process Your Information?
  6. When and With Whom Do We Share Your Personal Information?
  7. Do We Offer Artificial Intelligence-Based Products?
  8. How Do We Keep Your Information Safe?
  9. How Long Do We Keep Your Information?
  10. What Are Your Privacy Rights?
  11. How Can You Delete Your Data?
  12. Third-Party Services
  13. Do We Use Cookies and Other Tracking Technologies?
  14. Controls For Do-Not-Track Features
  15. Do United States Residents Have Specific Privacy Rights?
  16. International Data Transfers
  17. Do We Collect Information From Minors?
  18. Do We Make Updates To This Policy?
  19. How Can You Contact Us About This Policy?

1. Face Data Disclosure

Specific Disclosure for Apple Policy Compliance:

This section explicitly addresses how we handle face data to comply with Apple's App Store Review Guidelines.

1.1 What Face Data Do We Collect?

We strictly collect only the facial image data provided by you when you upload a photo ("Original Photo") for the specific purpose of generating professional headshots. We do NOT collect facial geometry data, face recognition signatures, biometric identifiers, or depth map data.

1.2 How Do We Use Your Face Data?

The collected face data is used exclusively for one purpose: to act as input for our AI models to generate the professional headshots you requested. We do NOT use your face data for user authentication, identification, tracking, or advertising.

1.3 Will the Data Be Shared with Third Parties?

Yes, but only with necessary service providers for processing and storage:

  • Google Gemini API: For AI image processing (images are processed in-memory and not stored by Google).
  • Supabase: For secure cloud storage of your uploaded photos and generated results.

We do NOT share your face data with data brokers, marketing agencies, or any other third parties.

1.4 Third-Party Face Data Storage Practices

Apple requires us to disclose whether our third-party service providers store your face data. Here is the explicit disclosure:

Google Gemini API (AI Processing):

  • Does Google store your face data? NO. Google Gemini API does NOT store your face data.
  • How is data handled? Your photos are transmitted securely (encrypted via HTTPS/TLS), processed in real-time memory for AI headshot generation, and immediately discarded after processing completes.
  • Retention period: Zero. No face data is retained by Google after the API request is completed.
  • Google's privacy practices: Google processes data in accordance with their Privacy Policy and Data Processing Addendum. The Gemini API is subject to Google's enterprise data handling policies which prohibit using customer data to train AI models.

Supabase (Cloud Storage Provider):

  • Does Supabase store your face data? YES. Supabase stores your uploaded photos and generated headshots on our behalf as our cloud storage provider.
  • Why does Supabase store face data? Supabase acts as our secure cloud infrastructure provider. They store your images solely to enable us to provide the headshot generation service to you, including allowing you to access your generation history and download your headshots.
  • How long does Supabase store face data? Supabase retains your face data until: (a) you delete it using the in-app "Delete All Data" feature, (b) you request deletion via email, or (c) your data becomes inactive for 2 years, after which it may be automatically deleted.
  • Why this retention period? This retention period allows you to access your generated headshots at any time without time pressure. The 2-year inactivity limit ensures data is not stored indefinitely for abandoned accounts while giving active users continuous access to their images.
  • Supabase's privacy practices: Supabase processes data in accordance with their Privacy Policy and Terms of Service. Supabase is SOC 2 Type II compliant, uses encryption at rest and in transit, and operates under strict data protection standards. Supabase does not access, use, or share your stored images for any purpose other than providing storage services to us.
1.5 How Long Is Face Data Retained?

Original Photos: Retained temporarily in cloud storage to facilitate the generation process and then are subject to deletion. They are not permanently archived.

Generated Headshots: Retained in cloud storage until you choose to delete them via the "Delete All Data" feature in the app settings, or automatically deleted after 2 years of inactivity.

1.6 Data Location

All face data is stored securely in Supabase's cloud infrastructure (US region) and processed via Google's enterprise AI cloud services.

2. Introduction

Welcome to AI Headshot Generator ("we," "us," or "our"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our mobile application and services (collectively, the "Service").

By using AI Headshot Generator, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, do not use the Service.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you have questions, please contact us at nikolai.bora.mindwise@gmail.com.

3. What Information Do We Collect?

2.1 Personal Information You Provide

Photos and Images: When you upload a photo to generate a headshot, we collect and temporarily process your original image. This is the core functionality of our Service.

Generated Headshots: We store the AI-generated headshot images you create using our Service. These images are stored securely in cloud storage (Supabase) and on your device.

Image Metadata: We collect metadata associated with your images, including:

2.2 Automatically Collected Information

We automatically collect certain information when you use the Service:

2.3 Subscription and Payment Information

If you purchase a subscription:

2.4 Categories of Personal Information (California CCPA)

For California residents, we collect the following categories of personal information:

Category Examples Collected
Identifiers Device ID, subscription ID, transaction IDs YES
Commercial Information Purchase history, subscription tier, usage records YES
Internet/Network Activity App usage data, generation history, feature interactions YES
Visual Information Uploaded photos, generated headshots YES
Inferences Style preferences, usage patterns YES
Sensitive Personal Information Facial images (for headshot generation only, NOT for identification) YES

2.5 Information We Do NOT Collect

We do not require or collect:

Important: Facial Image Processing

While we process facial images to generate headshots, we do NOT:

Your facial images are processed temporarily for AI generation and then the processing files are deleted.

4. How Do We Process Your Information?

We process your information for the following purposes:

3.1 Provide Core Service

3.2 Service Improvement and Analytics

3.3 Communication and Support

3.4 Legal and Security

We Do NOT:

We process your personal information based on the following legal grounds:

4.1 Consent

When you consent: By using our Service and uploading photos, you consent to:

You can withdraw consent at any time by deleting your data or uninstalling the app.

4.2 Performance of Contract

To provide our Service: Processing is necessary to:

4.3 Legitimate Interests

For our legitimate business interests: We process data to:

We balance these interests against your privacy rights and do not process data in ways you would not reasonably expect.

4.4 Legal Obligations

To comply with law: We process data when required by:

4.5 For EEA/UK Users

If you are located in the European Economic Area (EEA) or United Kingdom (UK), our legal basis for collecting and using personal information depends on the specific information and context:

6. When and With Whom Do We Share Your Personal Information?

We share your information only in the following limited circumstances:

5.1 Service Providers

We share data with third-party service providers who perform services on our behalf:

These providers are contractually obligated to protect your data and use it only for specified purposes.

5.2 Legal Requirements

We may disclose your information if required by law:

5.3 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

5.4 With Your Consent

We may share your information for other purposes with your explicit consent.

Important: We Do NOT Sell Your Data

We do not sell or rent your personal information to third parties for monetary or other valuable consideration. We do not share your information for cross-context behavioral advertising or marketing purposes. Your photos and generated headshots are never shared with advertisers or data brokers.

7. Do We Offer Artificial Intelligence-Based Products?

Yes. AI Headshot Generator uses artificial intelligence technology as its core functionality. Here's how we use AI and handle your data:

6.1 AI Technology Overview

Our Service uses advanced AI models to:

6.2 How AI Processes Your Images

Processing Workflow:

  1. Upload: You upload a photo from your device
  2. Secure Transmission: Image is encrypted and sent to our AI processing servers
  3. AI Analysis: AI analyzes facial features, pose, lighting, and composition
  4. Generation: AI creates a professional headshot based on your selected options
  5. Storage: Generated headshot is saved to cloud storage and your device
  6. Cleanup: Temporary processing files are immediately deleted from AI servers

6.3 AI Data Usage and Training

Important Disclosure:

6.4 AI Limitations and Disclaimers

You should be aware that AI technology has limitations:

6.5 Third-Party AI Services

We use third-party AI processing services to generate headshots. Your images are:

6.6 AI Decision-Making

Our AI makes automated decisions about:

These decisions are based on AI algorithms and your selected preferences. You have control over inputs (photo selection, style choices) and can regenerate if unsatisfied with results.

6.7 Your Rights Regarding AI Processing

You have the right to:

8. How Do We Keep Your Information Safe?

7.1 Storage Location

Local Device Storage:

Cloud Storage (Supabase):

7.2 Security Measures

We implement industry-standard security measures:

Encryption:

Access Controls:

Security Practices:

7.3 AI Processing Security

During AI generation, your images are:

7.4 Security Limitations

Important: While we implement strong security measures, no electronic transmission or storage can be 100% secure. We cannot guarantee absolute security and are not responsible for:

Please keep your device secure and use strong device passwords.

9. How Long Do We Keep Your Information?

8.1 Generated Headshots

We retain your generated headshots until:

Retention Period: Indefinitely until you request deletion, or 2 years of inactivity.

8.2 Original Photos

Retention Period: Temporarily during AI processing only, then immediately deleted.

Original photos you upload are:

8.3 Usage Data and Analytics

Retention Period: Up to 24 months

8.4 Subscription and Payment Records

Retention Period: 7 years (or as required by law)

8.5 Support Communications

Retention Period: 3 years

8.6 Backup and Archive Retention

When you delete data:

10. What Are Your Privacy Rights?

You have various rights regarding your personal information, depending on your location:

9.1 Universal Rights (All Users)

9.2 EEA/UK Users (GDPR Rights)

If you are in the European Economic Area or United Kingdom, you have additional rights:

9.3 California Users (CCPA/CPRA Rights)

See detailed California rights in Section 14: US Privacy Rights.

9.4 How to Exercise Your Rights

In-App Deletion:

  1. Open Settings in the app
  2. Go to "Data & Privacy"
  3. Tap "Delete All Data"
  4. Confirm deletion

Contact Us:

Response Time: We will respond to your request within 30 days (or as required by law).

9.5 Verification

To protect your privacy, we may verify your identity before processing requests. This may involve:

11. How Can You Delete Your Data?

You have full control over your data and can delete it anytime.

10.1 In-App Data Deletion

Step-by-Step Instructions:

  1. Open AI Headshot Generator app
  2. Tap Settings (⚙️ icon)
  3. Scroll to "Data & Privacy" section
  4. Tap "Delete All Data"
  5. Review what will be deleted
  6. Confirm deletion twice
  7. Wait for deletion to complete

What Gets Deleted:

What Remains:

10.2 Manual Deletion Request

If you cannot access the app, contact us:

Processing Time: We will process manual requests within 30 days.

10.3 Deletion Timeline

For detailed instructions, see our Data Deletion Guide.

12. Third-Party Services

We use the following third-party services to provide and improve our Service:

11.1 Supabase (Cloud Storage)

Purpose: Secure storage of generated headshots

Data Shared: Generated headshot images, metadata (date, style selections), user identifiers

Data Location: Secure cloud data centers

Privacy Policy: https://supabase.com/privacy

Data Retention: Until you delete your data or request removal

11.2 RevenueCat (Subscription Management)

Purpose: Manage in-app subscriptions and purchases

Data Shared: Device ID, subscription status, purchase transactions, app user ID

Privacy Policy: https://www.revenuecat.com/privacy

Data Use: Subscription management and analytics only

11.3 Apple App Store

Purpose: Process payments and manage iOS subscriptions

Data Shared: Apple ID, payment information, purchase history

Privacy Policy: https://www.apple.com/legal/privacy/

Payment Processing: All payment data handled by Apple (we don't access credit card info)

11.4 Google Play Store

Purpose: Process payments and manage Android subscriptions

Data Shared: Google Account ID, payment information, purchase history

Privacy Policy: https://policies.google.com/privacy

Payment Processing: All payment data handled by Google (we don't access credit card info)

11.5 AI Processing Services

Purpose: Generate professional headshots using AI technology

Data Shared: Uploaded photos (temporarily during processing only)

Data Handling:

Security: Contractual agreements require data security and privacy protections

11.6 Third-Party Responsibilities

We are not responsible for:

Please review each third party's privacy policy to understand their data practices.

13. Do We Use Cookies and Other Tracking Technologies?

No, we do not use cookies. As a mobile application, we do not use web cookies or similar web tracking technologies.

12.1 What We Use Instead

We use mobile app equivalents for necessary functionality:

12.2 Analytics

We use minimal analytics to understand app usage:

This data is aggregated and anonymized. We do not track individual user behavior across websites or apps.

12.3 No Cross-Site Tracking

We do NOT:

14. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference.

13.1 Our Position on DNT

We respect Do-Not-Track signals. If your browser or device sends a DNT signal:

13.2 How DNT Applies to Our App

Since we are a mobile app (not a website), DNT signals work differently:

13.3 What We Track Regardless

Even with DNT enabled, we still collect data necessary for Service functionality:

This data is essential for the app to function and cannot be disabled while using the Service.

13.4 Industry Standards

There is no universal standard for recognizing and implementing DNT signals. We follow best practices and respect user privacy preferences whenever technically feasible.

15. Do United States Residents Have Specific Privacy Rights?

Yes. If you are a resident of certain U.S. states, you have specific privacy rights under state law.

14.1 California Residents (CCPA/CPRA)

The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide California residents with specific rights:

Right to Know

You have the right to request disclosure of:

Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal retention requirements).

Right to Correct

You have the right to request correction of inaccurate personal information.

Right to Opt-Out of Sale/Sharing

We do NOT sell or share your personal information. We do not sell personal information for money or other valuable consideration, and we do not share personal information for cross-context behavioral advertising.

Right to Limit Use of Sensitive Personal Information

You have the right to limit our use of sensitive personal information (facial images) to:

We already limit sensitive data use to these purposes only.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA rights. We will not:

Authorized Agent

You may designate an authorized agent to make requests on your behalf. The agent must:

California "Shine the Light" Law

California Civil Code Section 1798.83 allows California residents to request information about disclosure of personal information to third parties for direct marketing. We do not share personal information with third parties for their direct marketing purposes.

14.2 Virginia Residents (VCDPA)

The Virginia Consumer Data Protection Act provides Virginia residents with rights to:

We do not engage in targeted advertising, sale of personal data, or profiling that produces legal or similarly significant effects.

14.3 Colorado Residents (CPA)

The Colorado Privacy Act provides Colorado residents with similar rights:

14.4 Connecticut Residents (CTDPA)

The Connecticut Data Privacy Act provides similar rights to Connecticut residents.

14.5 Utah Residents (UCPA)

The Utah Consumer Privacy Act provides Utah residents with rights to:

14.6 How to Exercise U.S. State Privacy Rights

Submit a Request:

In-App Deletion: Use the "Delete All Data" feature in Settings → Data & Privacy

Response Time: We will respond within 45 days (or as required by applicable state law)

Verification: We may verify your identity to protect your privacy before processing requests.

14.7 Appeals Process

If we decline your request, you may appeal by:

  1. Sending an email to nikolai.bora.mindwise@gmail.com with "Privacy Rights Appeal" in the subject
  2. Explaining why you believe our decision was incorrect
  3. Providing additional information if needed

We will respond to appeals within 45 days (or as required by law). If we deny your appeal, we will provide information about how to contact your state attorney general or data protection authority.

16. International Data Transfers

Your data may be transferred to and processed in countries other than your country of residence, including Bulgaria (where our service is operated) and the United States (where our cloud infrastructure is located).

15.1 EEA/UK Transfers

If you are in the European Economic Area or United Kingdom, we ensure appropriate safeguards for international data transfers:

15.2 Data Protection Standards

Regardless of where your data is processed, we maintain the same level of protection as required by:

15.3 Your Rights Regarding Transfers

You have the right to:

17. Do We Collect Information From Minors?

Age Restrictions:

16.1 Parental Consent

If you are under 18, please obtain parental consent before using the Service. Parents and guardians should supervise their children's use of the app.

16.2 If We Discover Child Data

If we learn that we have collected personal information from a child under the minimum age without parental consent, we will:

16.3 Parental Rights

Parents or guardians who believe their child has provided us with personal information may contact us at nikolai.bora.mindwise@gmail.com to request deletion.

18. Do We Make Updates To This Policy?

Yes. We may update this Privacy Policy from time to time to reflect:

17.1 How We Notify You

When we make material changes, we will notify you by:

17.2 Your Acceptance

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes:

17.3 Review Regularly

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

19. How Can You Contact Us About This Policy?

AI Headshot Generator

Email: nikolai.bora.mindwise@gmail.com

Location: Bulgaria

Support: Contact Support

Data Deletion: Delete Your Data

18.1 Privacy Rights Requests

For requests related to your privacy rights, including:

Please contact us at nikolai.bora.mindwise@gmail.com with "Privacy Rights Request" in the subject line.

Response Time: We will respond to your request within 30 days (or as required by applicable law).

18.2 EEA and UK Users - Supervisory Authority

If you are located in the European Economic Area or United Kingdom, you have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

EU Data Protection Authorities: Find your local authority

UK Information Commissioner's Office: https://ico.org.uk/make-a-complaint/

18.3 California Privacy Rights - Contact the Attorney General

California residents may contact the California Attorney General's office regarding privacy concerns:

California Department of Justice
Privacy Enforcement Section
File a complaint

Your privacy is important to us.
We are committed to protecting your personal information and being transparent about our data practices.

Thank you for trusting AI Headshot Generator with your photos and data.

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