Privacy Policy

Effective Date: July 30, 2026

This Privacy Policy explains how Roman Derenko (“we,” “us,” or “our”) collects, uses, shares, and protects information when you use the Photo AI mobile application (the “App”).

By using the App, you acknowledge the practices described in this Privacy Policy.

1. Information We Process

Photos and Images

The App allows you to upload or select photos and images from your device to create AI-generated images.

The photos and images you provide may contain personal information, including your image, likeness, facial features, or information about other people appearing in the content.

You choose which photos or images to submit to the App. The App does not access your entire photo library without the permissions provided through your device’s operating system.

Generated Content

We process the prompts, settings, reference images, and other instructions you provide to generate AI images.

The resulting AI-generated images may also be processed temporarily so they can be delivered to you through the App.

Technical Information

Our service providers may automatically process limited technical information required to operate, secure, and troubleshoot the App, such as:

• Device and operating system information;
• App version;
• IP address;
• Request timestamps;
• Error and diagnostic information.

We do not use this information to identify you directly unless necessary to prevent fraud, investigate abuse, comply with the law, or protect the App and its users.

2. How We Use Information

We use the information processed through the App to:

• Generate AI images requested by you;
• Send uploaded photos and generation instructions to the AI service provider;
• Deliver generated images to your device;
• Maintain, secure, and troubleshoot the App;
• Detect fraud, misuse, prohibited content, and technical problems;
• Enforce our Terms of Use;
• Comply with applicable legal obligations;
• Protect the rights, safety, and security of users, third parties, and the App.

We do not sell your photos or images.

We do not use your uploaded photos for targeted advertising.

We do not use your uploaded photos to create biometric identification databases.

3. Third-Party AI Processing

To provide image-generation functionality, the App sends the photos, images, prompts, and generation settings you submit to a third-party AI service provider.

The third-party AI provider processes this content on our behalf or as otherwise described in its applicable terms and privacy documentation. Processing may occur on servers located outside your country or region.

We take reasonable steps to work with service providers that offer appropriate privacy and security safeguards. However, third-party providers operate their own systems, and their processing practices may be governed by their own terms, policies, and legal obligations.

You should not upload highly sensitive, confidential, or legally protected images unless you understand and accept the risks associated with online AI processing.

4. Legal Bases for Processing

Where the General Data Protection Regulation, United Kingdom data protection law, or similar legislation applies, we process personal information under one or more of the following legal bases:

Performance of a Contract

We process your photos, prompts, and generation instructions because this processing is necessary to provide the AI image-generation service you request.

Consent

Where required, we rely on your consent to access photos stored on your device. You may withdraw device permissions through your device settings.

Withdrawing permission does not affect processing that occurred before permission was withdrawn.

Legitimate Interests

We may process limited technical and usage information where necessary for our legitimate interests, including:

• Maintaining and securing the App;
• Preventing fraud and abuse;
• Diagnosing technical problems;
• Defending legal claims;
• Improving reliability.

We balance these interests against your privacy rights.

Legal Obligations

We may process or retain information when reasonably necessary to comply with applicable laws, regulations, legal proceedings, or valid governmental requests.

5. Data Retention

Uploaded photos, prompts, generation settings, and generated images may be stored temporarily for the period reasonably necessary to:

• Process your request;
• Return the generated result;
• Maintain service reliability;
• Investigate errors, fraud, or abuse;
• Comply with legal obligations.

We do not intend to retain uploaded photos longer than reasonably necessary for these purposes.

The third-party AI provider may apply its own retention periods. Actual retention may therefore depend partly on the technical and contractual practices of that provider.

Information may be retained for a longer period where required by law, necessary to resolve disputes, prevent abuse, or enforce agreements.

6. Sharing of Information

We may share information in the following circumstances:

Service Providers

We may share photos, prompts, generated content, and limited technical information with service providers that help us:

• Generate AI images;
• Host or deliver App functionality;
• Maintain security;
• Diagnose errors and technical failures.

These providers are permitted to process information only as necessary to provide their services, subject to their contractual and legal obligations.

Legal and Safety Reasons

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with applicable law or a valid legal request;
• Protect the rights, safety, or property of users, third parties, or the public;
• Investigate fraud, abuse, security incidents, or prohibited activity;
• Enforce our Terms of Use;
• Establish, exercise, or defend legal claims.

Business Transfers

If the App or its related business is involved in a merger, acquisition, restructuring, financing, or sale of assets, information may be transferred as part of that transaction, subject to applicable law.

7. International Data Transfers

The App and its third-party service providers may process information in countries other than the country where you live.

These countries may have data protection laws that differ from those in your jurisdiction.

Where required by applicable law, we use or require appropriate safeguards for international data transfers, such as contractual protections or other legally recognized transfer mechanisms.

8. Your Privacy Rights

Depending on where you live, you may have the right to:

• Request access to your personal information;
• Request correction of inaccurate information;
• Request deletion of your personal information;
• Restrict or object to certain processing;
• Request a portable copy of certain information;
• Withdraw consent where processing is based on consent;
• Submit a complaint to a competent data protection authority.

To exercise a privacy right, contact us at rderenko80@gmail.com.

We may need to verify your request before responding. Some rights may be limited where an exception applies, where we cannot reasonably identify the relevant information, or where retention is required by law.

9. Photo Permissions

The App may request permission to access your device’s photo library so you can select an image for AI processing.

You can deny or revoke this permission through your device settings. Certain App features may not function without access to the photos you choose to submit.

The App should only access photos that you select or otherwise authorize through the operating system.

10. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, loss, or misuse.

However, no internet transmission, storage system, or AI service is completely secure. We cannot guarantee absolute security.

You are responsible for avoiding the submission of content that is unnecessarily sensitive or confidential.

11. Children’s Privacy

The App is not directed to children under the age of 13.

We do not knowingly collect personal information from children under 13. If you believe that a child has provided personal information through the App, contact us at rderenko80@gmail.com so that we can review and, where appropriate, delete the information.

Users must also meet any higher minimum age required by the laws of their country.

12. Images of Other People

You must have the necessary permission or other lawful basis before uploading an image of another person.

You must not use the App to create deceptive, exploitative, defamatory, abusive, sexually explicit, or otherwise unlawful images of another person.

You are responsible for the content you submit and for how you use generated images.

13. Automated AI Processing

The App uses automated artificial intelligence systems to create images based on your photos and instructions.

Generated images may be inaccurate, unexpected, offensive, biased, or visually similar to existing content. AI-generated results should not be treated as verified facts or authentic representations of real people or events.

The App does not use automated processing to make legal or similarly significant decisions about you.

14. Do Not Track and Targeted Advertising

The App does not use uploaded photos for cross-context behavioral advertising or targeted advertising.

Because there is no universally accepted standard for responding to browser-based “Do Not Track” signals, the App may not respond to such signals.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we make changes, we will update the effective date at the top of this Privacy Policy. Where required by law, we will provide additional notice or request consent.

Your continued use of the App after an updated Privacy Policy becomes effective means that you acknowledge the updated policy, to the extent permitted by law.

16. Contact Us

For questions, requests, or complaints regarding this Privacy Policy, contact:

Roman Derenko

Email: rderenko80@gmail.com