Last modified: March 2023
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.
It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
FOR AI HEADSHOT GENERATOR APP
A small note on how AI Headshot Generator feature works.
AI Headshot Generator uses a Neural Network Model Stable Diffusion that allows users to generate personalized Headshot Avatars (“Avatars”).
- Users upload 10 to 20 photos and select their gender.
- Using these data, a copy of the Stable Diffusion model is retrained to personalize the model
- After the model copy is retrained, it generates the Avatars
- After the Avatars are generated, the copy of the model, along with uploaded photos, are deleted permanently from our servers
- We do not use your Personal Data to generally train and/or create our separate artificial intelligence/products.
We do our best to moderate the parameters of the Stable Diffusion model, however, it is still possible that you may encounter content that you may see as inappropriate for you.
Images uploaded to the app to generate AI Avatars are automatically deleted from our servers after your avatars are created.
We may collect several types of information, including but not limited to Personal Data, from and about you:
- Directly from you when you provide it to us.
- Automatically when you Use AI Headshot Generator. Information collected automatically may include Usage details and internet protocol (“IP”) addresses.
- From third parties, for example, our Service Providers (as defined below).
- Face Data: We train or AI model with the face data that you provide us as photos.
- By using the Face Data, our model is retrained to personalize the model for you.
- We do not share your Face Data with any third parties.
- Your Face Data is not retained in our servers after the model is trained and your avatars are created. Your uploaded photos including the face data, are deleted permanently from our servers.
When you Use AI Headshot Generator, you usually provide to us certain information, including your Personal Data:
- Photos and (or) videos that you upload to AI Headshot Generator, for example to use the Magic Avatars feature. Please note that we always delete all metadata that may be associated with your photos and (or) videos by default (including, for example, geotags) before temporarily storing them to our systems.Some editing features may use TrueDepth API (developed by Apple) technologies that provide information about facial position, orientation, and topology. Such information is used only on-device and is never stored on our servers. For more information about TrueDepth API processing of your photos and videos, you may visit the following link. We can access your photos and videos only after you grant us permission to access your camera or your devices’ photo library. You provide such a permission through the request that appears on your mobile device (it may differ depending on your device operating system). You may revoke permission to access your camera or photo library through the settings on your mobile device, and here’s how to do it.If you use an iOS device:
- On your iPhone or iPad open the Settings app.
- Scroll down and tap “Privacy”.
- Tap “Camera” or “Photos”.
- Next to AI Headshot Generator, toggle the permissions switching on or off.
If you use an Android device:
- On your device open the Settings app.
- Tap “Apps”.
- Tap “AI Headshot Generator”. If you can’t find it, tap “See all apps”. Then, choose AI Headshot Generator.
- Tap “Permissions”.
- To change a permission setting, tap it, then choose “Allow” or “Don’t allow”.
- Information about your gender: When you use our AI Avatars feature, we ask you about your gender. This information is used by the AI model solely to generate the Avatars in accordance with the indicated gender: for example, if you choose to identify your gender as a female, then you will receive conventionally more feminine-like Avatars.
- Your email: When you create an account with AI Headshot Generator, we ask you to provide your email that will be further used for your sign-in process.
- If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other ssers inquiries in relation to AI Headshot Generator.
When you Use AI Headshot Generator, we may automatically collect certain data about you. This data is needed for operation of AI Headshot Generator and, among others, may be used for in-app analytics or marketing purposes. The data we collect automatically includes:
- Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, and mobile network information.
- Usage details: Details of your Use of AI Headshot Generator, including frequency of Use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.
- (If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by AI Headshot Generator, please follow the instructions below.If you use an iOS device:
- Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
- Tap to turn off or turn on permission to track for AI Headshot Generator.
If you use an Android device:
- Open Settings app
- Navigate to “Privacy” > “Ads”
- Tap “Delete Advertising ID”
- Tap it again on the next page to confirm.
- Details about your in-app purchases. This data is used to provide you with the Services and for our in-app analytics.
Such automatically collected data helps us operate AI Headshot Generator and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use AI Headshot Generator and what you like and dislike the most.
The technologies we use for automatic data collection may include:
We use third-party analytics tools, such as Google Firebase, Meta, AppsFlyer and Amplitude, to help us measure traffic and usage trends for AI Headshot Generator. These tools collect information via third-party analytics software development kits incorporated into AI Headshot Generator, which includes your pseudonymised user ID and the information about AI Headshot Generator web pages you visit when following the links available to you on AI Headshot Generator, your actions in AI Headshot Generatorapplication and basic information about the type of subscription you have. We collect and use this analytics information in an aggregated manner with analytics information from other ssers so that it cannot reasonably be used to identify any particular user. For information on how third party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of AI Headshot Generator.
We care about your privacy. With this in mind, most processing activities occur on your device only. There are, however, two exceptions to it: when you apply Art Styles to your photos and when you generate Avatars, since these functions require sophisticated computing resources to be performed.
- Art Styles. To apply Art Styles, you have to upload your original photo to AI Headshot Generator. At this point, your photo is stored on our servers (provided by Amazon Web Services (USA)). It is needed for your convenience so that you don’t have to re-upload the original photo every time to apply any new Art Style. This also helps you spend less Internet traffic and makes the processing of Art Styled photos faster. We store your original photo on our servers for no longer than 24 hours. After 24 hours your original photo is deleted.
- AI Avatars. In order to generate AI Avatars, you have to upload 10-20 photos to AI AVATAR. At this point, your photos are stored on our servers (provided by Amazon Web Services (USA)). Then, a copy of the Stable Diffusion model is created to be retrained with your photos to personalize the model and to create your Avatars. Immediately after the successful generation of Avatars, your original photos are deleted from our servers. Your purchased Avatars are stored on our servers so that they remain accessible to you in AI AVATAR at any time and from any device until you decide to delete them.
You can also always request us to delete your photos or Avatars by contacting us at [email protected]
- We do not use photos, videos or Avatars to identify any individual user.
- We do not use your photos, videos or Avatars for authentication, advertising, or marketing purposes, or to otherwise target a user in a similar manner.
- We do not use your photos, videos or Avatars to build a user profile, or otherwise attempt, facilitate, or encourage third parties to identify anonymous users or reconstruct user profiles based on your photos, videos or Avatars.
- We do not transfer, share, sell, or otherwise provide your photos, videos or Avatars to advertising platforms, analytics providers, data brokers, information resellers or other such parties.
We use your information other than photos and videos for the following purposes:
- To provide you with support and to respond to your inquiries. If you share your Personal Data (including your name and contact information) to ask a question about AI Headshot Generator, we will use that Personal Data to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users inquiries in relation to AI Headshot Generator. It is our legitimate interest to provide you with high-quality support.
- To notify you about changes to AI Headshot Generator or any products or services we offer or provide through AI Headshot Generator, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our legitimate interest to keep you updated on your use of AI Headshot Generator.
- To present to you and others with AI Headshot Generator and its contents and any other information, products or services that you request from us. We do so to provide you with the services according to our contractual obligation.
- To monitor aggregated metrics such as total number of users, traffic, and demographic patterns (including via Service Providers as specified in Section 7). It is our legitimate interest to make aggregated analytics of our audience as it helps us understand our business metrics and improve our product.
- To provide, improve, test, and monitor the effectiveness of AI Headshot Generator in an aggregated manner. It is our legitimate interest to make analytics of our audience as it helps us understand our product and business metrics.
- When you choose to use the Magic Avatars feature, you provide your gender identification, which is used to retrain the separate copy of the Stable Diffusion model to generate Art based on your particular photos. It is our contractual obligation to ensure that we provide you with the requested service. This data is deleted immediately after the Avatars are successfully generated.
- In order to apply Art Styles, for you to use them faster and more conveniently, we store your original photo for 24 hours. After 24 hours your original photo will be deleted.
- To provide personalized content and information to you in relation to AI Headshot Generator, which could include online ads or other forms of marketing (including via email). We do so upon your explicit consent.
- Upon users’ consent, for marketing purposes in order to find audiences similar to our users. For this processing we share, among others, users’ Use details, device information, and in-app purchase details with our third-party advertising partners.
We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 5 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).
For any new purpose of processing that is not compatible with any of the purposes mentioned above, we will ask for your separate explicit consent.
To the extent necessary for any of the processing purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 5 (“data minimization principle”).
For the purposes of the GDPR, we are the data controller, unless otherwise stated.
IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE
Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:
- the categories of personal information that is processed;
- the categories of sources from which personal information is obtained;
- the purpose for processing of user personal data;
- the categories of third parties with whom we may share your personal information;
- the specific pieces of personal information that we might have obtained about particular user provided that the data given in the request is reliable enough and allows to identify the user.
All about the categories of information, its sources and purposes of processing
Please mind that according to CCPA personal information does not include de-identified or aggregated consumer information.
How your information can be shared.
Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.
If you don’t want us to process your personal information any more please contact us through the email [email protected]. In most cases there is no way to maintain the App’s further operating without functional data therefore you will be advised to remove the App from your device.
If you don’t want us to share device identifiers and geolocation data with service providers please check your device settings to opt out as described below.
To submit a verifiable consumer request for access, portability or deletion personal data please contact us through the email [email protected]. Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California”.
When submitting a verifiable request, you should be ready to:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.
We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.
Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.
SALE OF DATA
We do not sell any of your personal data to third parties.
There are several categories of information that can be processed.
We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services. What data can be processed:
- Content Information, i.e. photos, pictures and other data - when you upload or create them using the App.
- Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form. We collect, store and process it by our cloud storage provider (Amazon.com, Inc.). We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request.
Information That Is Processed Automatically
When you use the App, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data we may not be able to provide you with all the features of the App.
We use third-party automatic data processing technologies to analyze certain information sent by your device via our App (advertising or analytics tools). Some of them launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time launch the App.
- Device Details. When you use a mobile device (tablet / phone / smartwatch) to access our App, some of details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.
- Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
- Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser.
- Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”).
- Device identifiers: Identity For Advertisers for iOs devices/ Advertising ID or Android ID for Android devices, user identifiers (if they are set up by the App’s developer).
What data can be processed:
- Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analyzes. Some services also record the list of applications and/or processes which are installed or run on your device.
- Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.
- Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
- In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).
Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).
Our e-commerce provider (Apple / Google) is responsible for billing, processing and charging for the in-app purchases, handles your personal information and keeps it absolutely safe and secure. We cannot access or use you credit or debit card information. You may access the applicable “in-app” purchase rules and policies directly from the app stores.
Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:
(a) To make our service available. We use the functional information and information that is processed automatically to provide you with all requested services.
(b) To improve, test and monitor the effectiveness of our App. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.
(c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
(d) To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.
We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.
We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our services:
Analytics service provider
Analytics / ad management service provider
Analytics service provider
Analytics and marketing service provider
Analytics service provider
Analytics / ad management service provider
Analytics service provider
In case you want to learn more about these services and their privacy options (including opt-out) please consult the correspondent websites and privacy policies. We are not responsible for any usage of your personal data by the abovementioned third parties in violation of our instructions.
Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.
We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:
- as required by law;
- when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
We work in the cross-border area and provide our App to our Users around the world.
We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.
This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.
We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.
Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:
- Data Access and Portability. You can request copies of your personal information.
- Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct change, update or rectify your data.
- Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
- Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
To exercise any of the rights described above, you can contact us through [contact form]. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.
Opt-out of marketing tracking
If you don’t want third-party service providers to use to personalize ads on the basis of your interests please follow the instructions below:
- Choose option "Limit Ad Tracking" on your iOs device in Settings/ Privacy/ Advertising, please find additional information here: https://support.apple.com/en-us/HT202074;
- Choose option “Opt out of Ad Personalization” on your Android device in Settings/ Google/ Ads.
You can also visit https://youradchoices.com for the same purpose.
Please mind when you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.
Opt-out of Location Data Processing
If you don’t want third-party service providers to use your precise location data, or street-level location information about you please follow the instructions below:
- iOS 11 or later: turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services”. Then select the applicable App and set the “Share My Location” status to “Never”. Please see additional information here: https://support.apple.com/en-us/HT203033.
- Android 5.0 or later: turn Location off for the applicable Product via the menu “Settings > Apps > [applicable Product] > Permissions > Location”. Then turn off the “Location” button.
The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about security of our App, you can contact us at through the email or contact form displayed below.
Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.
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