# Privacy Policy
Last updated: 2026-10-19
This policy explains how FaceKit handles personal data when you use the FaceKit app and the facekit.io website. We wrote it to be read, so it says plainly what happens to your photos.
## 1. The short version
- We use your photos only to make the edits you ask for. We never sell them, never use them for advertising, and never use them to identify you.
- To make an edit, we send your photo and your request to our AI provider, OpenAI, or to Google if OpenAI is unavailable or can't read the photo. The app asks your permission before it sends the first photo.
- Neither we nor our AI providers use your photos to train AI models.
- We don't keep the photos you upload. We keep a copy of each result with your account until you delete your account (section 7).
- Your edit history stays on your iPhone.
- We don't show ads and we don't track you across other companies' apps or websites.
- You can delete your account and its data in the app at any time.
## 2. Who we are
FaceKit is run by Vadym Petrychenko, a sole trader registered in Poland:
Vadym Petrychenko (FaceKit)
al. Sikorskiego 3a/53
02-758 Warszawa, Poland
VAT ID: PL8133710549
Email: [support@facekit.io](mailto:support@facekit.io)
We are the "controller" of your personal data under the EU General Data Protection Regulation (GDPR). We have not appointed a data protection officer. For any privacy question or request, write to [support@facekit.io](mailto:support@facekit.io).
## 3. What we collect
### Your account
You sign in with Apple or Google. We receive and store:
- your name and email address (with Sign in with Apple you can hide your email, and we then receive an Apple relay address);
- your profile picture, if you sign in with Google;
- an identifier for your Apple or Google account, and the sign-in tokens that keep you signed in;
- for each signed-in device, the IP address and device type, so we can keep the session secure;
- whether you agreed to receive tips and offers from us.
### Photos, prompts and results
- **Photos you choose.** When you start an edit, the app uploads the photo you picked, and any reference photo (for example a hairstyle, a tattoo design, a garment or a scene), to our server. The app only reads the photos you choose. It does not scan your photo library.
- **Prompts and choices.** The preset you picked and any text you typed.
- **Results.** The edited image the AI provider sends back.
Before uploading, the app shrinks large photos and saves them as a new file. This normally removes information embedded in the original, such as the camera model and the location where it was taken.
### Purchases
Apple handles payment. We never see your card or bank details. We receive and store your subscription status, the plan, the price and currency, your country, store transaction identifiers, and your credit balance and its history. RevenueCat, our subscription provider, links these to a random identifier for your app install and, once you sign in, to your FaceKit account.
### How you use the app
- **Device and app information:** device model, iOS version, app version, language, and a random identifier for your app install.
- **Usage events:** which screens you open and which features you use, whether an edit succeeded or failed and how long it took, and purchase events. For prompts and feedback we record only their length, not the words.
- **Session recordings** of how you move through the app. Recordings hide every photo and every text field. Section 12 explains when analytics and recordings run.
- **Crash and error reports:** what went wrong, technical logs from the app, device and app information, and your account identifier.
- **Server logs:** each request to our server, with your account identifier and app version. Logs can include your email address and the text of your prompts.
### Notifications
If you allow notifications, we store a push token for your device, the app version, and which notifications we sent to it.
### What stays on your iPhone
These never leave your device unless you send them to us:
- your editing session, versions and recent prompts (the last 50);
- results you save, which go to your Photos library;
- your onboarding answers, such as how you heard about FaceKit, your gender, your birth year and your goals. The app uses them only to order the features it suggests.
### When you contact us
If you email us or use the contact form on facekit.io, we receive your email address, your message and anything you attach. Feedback you send from the app includes your account identifier and basic device information.
### On facekit.io
The website stores your cookie choice and your light or dark mode preference in your browser. If you allow analytics, it also records the pages you visit (section 12).
## 4. Your photos and your face
Photos of faces deserve extra care, so here is exactly what happens to them.
- **What the AI does.** An image model reads your photo and draws a new version with the change you asked for, such as a haircut, a beard or an older face. Nothing else happens to the photo.
- **No face recognition.** We don't detect faces on your device, we don't extract face measurements or "faceprints", and we don't use photos to recognize or identify anyone. We don't keep anything that could identify you from a new photo.
- **Only for your edit.** We never use your photos or anything learned from them for advertising, marketing or profiling, and we never sell, rent or trade them.
- **No training.** We don't train AI models on your photos or results, and our AI providers' contracts don't allow them to train on what we send them.
- **Your permission.** Before your first edit, the app explains that your photo will be sent to OpenAI, or to Google when OpenAI is unavailable, and asks for your permission. If you don't give it, you can still browse the app, but you can't make AI edits.
- **Other people's photos.** If a photo shows someone else, you must have their permission to edit it. See our [Acceptable Use Policy](/acceptable-use).
Some laws, such as the GDPR and some US state laws, treat data from a face as biometric data in certain cases. We don't think that what FaceKit does creates biometric data, because nothing in it is used to identify a person. If a law where you live treats it as biometric data anyway, we handle your photos as this section describes, the permission you give in the app is your explicit consent, and the retention periods in section 7 are our schedule for deleting it.
## 5. Why we use your data, and our legal basis
The GDPR requires a legal basis for each use of personal data. These are ours:
- **Create and run your account and keep you signed in** (account and session data). Basis: performing our contract with you (Art. 6(1)(b)).
- **Make the edits you ask for, by sending your photo and request to an AI provider** (photos, prompts, results). Basis: performing our contract (Art. 6(1)(b)), and your explicit consent given in the app (Art. 9(2)(a), as far as the photos count as special-category data).
- **Sell and manage subscriptions and credits, and apply usage allowances** (purchase data, account identifier). Basis: performing our contract (Art. 6(1)(b)), and keeping the accounting records the law requires (Art. 6(1)(c)).
- **Keep the service secure and fair**, with rate limits, abuse and fraud checks, and by stopping repeat sign-ups for free credits (IP address, account identifiers, a one-way hash of your sign-in identifier). Basis: our legitimate interest in protecting the service and its users (Art. 6(1)(f)).
- **Find and fix crashes and errors** (crash reports, server logs). Basis: our legitimate interest in a working, secure app (Art. 6(1)(f)).
- **Understand how the app is used and improve it, including session recordings** (usage events, device data, recordings). Basis: in the EU, the EEA, the UK and Switzerland, your consent (Art. 6(1)(a)), which you give on the privacy choices screen when you first open FaceKit and can withdraw in Settings, then Privacy; elsewhere, our legitimate interest in improving FaceKit (Art. 6(1)(f)), and you can turn it off in Settings, then Privacy.
- **Send notifications about your account and edits** (push token). Basis: your consent through the iOS notification permission (Art. 6(1)(a)).
- **Send tips and offers by email or notification** (email, push token). Basis: your consent (Art. 6(1)(a)), which you can withdraw at any time.
- **Answer your messages and handle complaints** (your messages, account data). Basis: performing our contract (Art. 6(1)(b)) and our legitimate interest in helping you (Art. 6(1)(f)).
- **Comply with the law and defend legal claims** (any relevant data). Basis: legal obligation (Art. 6(1)(c)) and our legitimate interest (Art. 6(1)(f)).
Where we rely on legitimate interest, you can object (section 9). We don't make decisions about you based solely on automated processing that have legal or similarly significant effects. Our safety filters, and our providers', automatically block some requests. A blocked request means that edit isn't made, nothing more.
## 6. Who receives your data
We don't sell or rent personal data and we don't share it for advertising. We use the service providers below. They process data on our behalf, under contracts that limit what they may do with it and require them to protect it at least as well as this policy does.
- **OpenAI** (USA) generates edited images and rewrites tattoo prompts. It receives photos, prompts and results, but no name, email or account identifier.
- **Google, Gemini API** (USA and other countries) generates the edit instead when OpenAI is unavailable or can't read the photo. It receives the photo and the prompt, but no name, email or account identifier.
- **Expo, EAS** (global network) hosts our server, delivers app updates and push notifications, and counts app launches. It receives every request to our server, push tokens and notification text, and the app version and install identifier.
- **Neon** (USA) hosts our database: account, purchase, credit and notification data, and results.
- **RevenueCat** (USA) manages subscriptions and purchase receipts. It receives app install and account identifiers and purchase data.
- **Apple** (USA and other countries) provides Sign in with Apple, payments and push notification delivery. It receives what you share with Apple, sign-in tokens and notifications.
- **Google, sign-in** (USA and other countries) provides Sign in with Google and receives sign-in tokens.
- **PostHog** (USA) provides product analytics and session recordings in the app, and analytics on facekit.io (section 12 explains when). It receives usage events, device data, your account identifier and recordings.
- **Vexo** (location not published) provides product analytics in the app, on the same terms as PostHog, while we move to PostHog. It receives usage events and your account identifier.
- **Sentry** (USA) collects crash and error reports, with app logs, device data and your account identifier.
- **Axiom** (USA) stores server logs, which can include your email address and prompts.
- **Cloudflare** (global network) hosts facekit.io and stores the app's catalog images. It sees website requests, including IP addresses.
- **Amazon CloudFront** (global network) delivers some catalog images in the app and sees your device's IP address when an image loads.
- **Google Workspace** (USA and other countries) is our email, and receives the emails you send us.
We may also disclose data if the law requires it, for example to a court or a public authority, to protect the rights and safety of users or others, or to a buyer if the FaceKit business is ever sold, in which case this policy keeps applying to your data.
**What OpenAI keeps.** OpenAI processes your photos and prompts to return the result. Under its terms for developers, it doesn't use this data to train or improve its models. It keeps the data for up to 30 days to detect abuse of its services, then deletes it.
**What Google keeps.** When Google makes an edit, it processes the photo and prompt to return the result. Under its terms for the paid Gemini API, it doesn't use this data to improve its products. It keeps prompts and results for up to 55 days to detect violations of its usage policies, then deletes them.
## 7. How long we keep your data
| Data | How long |
| --------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Photos you upload for an edit | Not stored by us. Our server holds them only while it makes the edit. OpenAI keeps them for up to 30 days, and Google for up to 55 days, to detect abuse (section 6). |
| Results | Stored on our server with your account until you delete your account. On your iPhone, until you reset the editor, delete the app or delete them from Photos. |
| Account data | Until you delete your account |
| Sign-in sessions | Until you sign out, the session expires or you delete your account |
| Credit balance and subscription status | Until you delete your account |
| Purchase and credit records | Up to 5 years after the year of the purchase, for accounting and to resolve disputes |
| A one-way hash of your Apple or Google account identifier, kept after you delete your account | As long as we offer free welcome credits, so that signing up again with the same account doesn't earn another one. The hash can't be turned back into your identifier, email or name. |
| Push tokens and notification history | Until you delete your account, or until the token stops working |
| Usage events and session recordings | Up to 1 year |
| Crash reports and server logs | Up to 90 days |
| Rate-limit records (with IP address) | A few minutes, until the limit resets |
| Support messages | As long as needed to help you and handle any follow-up, then deleted |
When you delete your account, we delete your account, sessions, sign-in links, results, credit balance, usage allowance and the push devices linked to your account. Records we must keep, listed above, stay for their stated period. Analytics, crash reports and logs are deleted on their regular schedule. See [Delete your account](/delete-account).
## 8. International transfers
We are in the EU, but most of our providers store or process data in the USA. When personal data leaves the European Economic Area, we rely on the EU-US Data Privacy Framework where the provider is certified under it, and otherwise on the European Commission's Standard Contractual Clauses. You can ask us for a copy of the safeguards that apply.
## 9. Your rights
If you are in the EU, the EEA, the UK or Switzerland, you have the right to:
- access your personal data and get a copy;
- correct data that is wrong;
- delete your data;
- restrict how we use it;
- receive the data you gave us in a portable format;
- object to uses based on our legitimate interest;
- withdraw consent at any time, without affecting what we did before; and
- complain to a data protection authority. In Poland that is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa). You can also complain in the country where you live or work.
People in other places, including several US states, have similar rights. We give them to everyone.
**How to use them.** Delete your account in the app (Settings, then Account, then Delete Account), change your analytics choice or withdraw your permission for AI processing in the app (Settings, then Privacy), or email [support@facekit.io](mailto:support@facekit.io) from the address on your account. We reply within one month. If we need to confirm it's you, we'll ask for the minimum we need.
## 10. Children
FaceKit is not for children. You must be at least 13, or older if your country sets a higher age for consenting to the use of your personal data (16 in Poland, for example). We don't knowingly collect data from children under 13 or under that local age, and if you are under 18 you need a parent or guardian's permission to use FaceKit. If you believe a child below the minimum age uses FaceKit, write to [support@facekit.io](mailto:support@facekit.io) and we will delete the account.
Our [Acceptable Use Policy](/acceptable-use) doesn't allow photos of children under 13, or of other people under 18. If such a photo was uploaded to FaceKit, tell us and we will delete what we hold.
## 11. Security
All traffic between the app, our server and our providers is encrypted (HTTPS). Our database provider encrypts stored data. Access to our systems requires individual credentials, and secrets are kept in a dedicated secrets manager. No system is perfectly secure. If a breach puts your rights at risk, we will tell you and the authorities as the law requires.
## 12. Cookies and similar technologies
**On facekit.io.** We use your browser's local storage for two necessary things: remembering your cookie choice and your light or dark mode preference. With your consent, we also use PostHog analytics cookies to count visits and see which pages people use. The banner asks before any analytics load. You can change your choice at any time through "Cookie settings" at the bottom of every page.
**In the app.** The app stores your sign-in session in the iOS Keychain and your settings and privacy choices on your device. In the EU, the EEA, the UK and Switzerland, FaceKit asks when you first open it whether you allow app analytics (including session recordings) and ad measurement; both stay off unless you allow them, and iOS asks about tracking only if you turned ad measurement on. Elsewhere, analytics run unless you turn them off. Either way you can change your choices in Settings, then Privacy. Today we don't use advertising identifiers, we don't show ads, and we don't track you across apps or websites owned by other companies; if that changes, we will update this policy first.
## 13. Notice for US residents
We don't sell personal information, and we don't share it for cross-context behavioral advertising. We use sensitive information, such as photos of your face, only to provide the edits you ask for (section 4). Residents of California and other US states with privacy laws can ask what we collected, ask us to delete or correct it, and appeal a refusal by replying to our answer. We won't treat you differently for using these rights.
## 14. Changes to this policy
We will update this policy when FaceKit changes, for example when we add a feature or a provider. The date at the top shows the latest version. If a change affects how we use data you already gave us, we will tell you in the app or by email before it takes effect, and ask for your consent again where the law requires it.
## 15. Contact
Questions, requests or complaints about privacy: [support@facekit.io](mailto:support@facekit.io), or by post to Vadym Petrychenko (FaceKit), al. Sikorskiego 3a/53, 02-758 Warszawa, Poland.