Privacy Policy
Effective Date: August 8, 2026
This Privacy Policy explains how Roman Derenko (“we,” “us,” or “our”) collects, uses, shares, and protects information when you use the AI Photo 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.
Your Anonymous Identifier
The App does not have accounts. You do not create a profile, and we never ask for your name, email address, or phone number.
Instead, the first time you launch the App it generates a random identifier and stores it in your device’s keychain. That identifier is sent with each request so that the service can attach your credit balance and purchases to your device. It is not derived from your device’s hardware identifiers, is not shared with advertisers, and cannot by itself be linked to you as a person. It survives reinstalling the App, which is what allows your credits to survive with it.
Purchases and Subscriptions
When you buy a subscription or a credit pack, the purchase itself is made through the App Store. We do not see or receive your payment card, billing address, or Apple ID.
Our purchase provider confirms the transaction with Apple and reports to us the product purchased, the transaction identifier, and the renewal or expiry date, together with the anonymous identifier described above, so that the correct credits can be added to your balance.
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 Google, which operates the Gemini image models used by the App, through our own server infrastructure.
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.
In practice, our own servers do not store the photos you submit or the images produced from them. Your photos pass through our infrastructure to the AI provider and the result is returned to your device, where it is saved in the App’s own library on your phone. What our database keeps is limited to your anonymous identifier, your credit balance and the entries that produced it, the product identifiers of your purchases, and a record of each generation request consisting of the model used, the number of images and a timestamp — with no photo content and no prompt text.
The IP address used to obtain an access token is kept for one hour and then deleted automatically. It is used solely to limit how quickly new identities can be created from a single network, which protects the service from abuse.
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 the service providers below. Each of them acts on our behalf and is permitted to use the information only to provide its service.
- Google LLC — operates the Gemini image models. Receives the photos, prompts and generation settings you submit, and returns the generated image. Subject to Google’s own terms and retention practices for the Gemini API, which include holding request data for a limited period to detect abuse.
- Cloudflare, Inc. — hosts our server, our database of credit balances, and this website. Receives every request the App makes, including the photos in transit, your anonymous identifier and the IP address described above.
- Adapty Tech Inc. — processes purchases and subscription status. Receives your anonymous identifier and the transaction details reported by Apple. Does not receive your photos or prompts.
- Apple Inc. — processes the payment itself and manages your subscription. We receive no payment details from Apple.
We do not use analytics, advertising, attribution or crash-reporting services, and no other company receives your data.
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
Because the App holds no name, email address or account, we can only act on a request if you tell us which anonymous identifier is yours. You will find it at the bottom of the Settings screen in the App, where a single tap copies it. Send it to the address in the “Contact Us” section below and we will delete the record associated with it, including the credit balance and the history of generation requests. Deleting that record also forfeits any credits and any active subscription attached to it, and it cannot be undone.
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 anatoliiremenets@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 anatoliiremenets@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: anatoliiremenets@gmail.com