Privacy policy

1. Controller

[Legal entity, address, contact for privacy questions, data protection officer or representative if required.]

2. What we process

• Account data: email address, hashed password, billing records.
• Photos you upload and the heads, textures and reports made from them. Face photos and 3D faces can be biometric or otherwise sensitive data under GDPR Article 9 and comparable laws such as Korea's Personal Information Protection Act. [Legal basis, e.g. explicit consent of the person shown, and how it is recorded.]
• Technical data: IP address, request logs, API usage.
• Messages you send through the contact form.

3. Why

To make and deliver heads, run accounts and billing, run the invite programme and prevent its abuse, keep the service secure, and answer messages. [Any other purposes.]

4. Processors and transfers

Making a head involves third-party AI model providers that receive the photos or images derived from them. [List of processors, including the model hosting platform and each model provider, their locations, and the safeguards for transfers outside the EEA.]

Payments. Paddle.com, our reseller and Merchant of Record, takes payments and collects the name, email address, country, payment details and tax information it needs; for that it is responsible itself, under its own privacy notice. Paddle's checkout runs on our checkout page through Paddle.js. From Paddle we receive the order (what was bought, the amounts and taxes), the Paddle customer id and, for card payments, the card brand, last four digits and expiry date, never the card number. We use these for your balance, receipts, refunds and disputes, and keep only keyed hashes of the card details and the Paddle customer id to stop people from inviting themselves.

Invite programme. When you join through someone's invite link, we store that they invited you and a keyed hash of the network you signed up from. The person who invited you sees a masked form of your email address (first letter and domain), when you joined, whether the invitation counts, how many purchases you made and the credits they earned from them; never what you bought or paid.

5. How long we keep it

• [Retention period for photos.]
• [Retention period for heads and files.]
• [Retention period for logs and billing records.]
• You can delete a head and its photos at any time in the Studio or through the API.

6. Your rights

[Access, rectification, erasure, restriction, portability, objection, withdrawal of consent, complaint to a supervisory authority; how to exercise them; rights of people who appear in photos uploaded by someone else.]

7. Security

[Summary of technical and organisational measures.]

8. Cookies

The site uses a session cookie for signing in and stores your colour theme choice in your browser. An invite link sets a cookie (fn_ref) with the inviter's code for 30 days. Paddle.js, which runs the checkout on our checkout page, may set its own cookies there. [Analytics, if any, and consent.]