Privacy Policy

1. The data we process

• Your photos and the images created. The photo you choose is sent to our image-generation providers to create the result. It may show your face and the faces of other people.
• Your requests: the effect or template you chose.
• Subscription data: the transaction identifier signed by Apple, validated through RevenueCat. We never see your card number.
• Technical anti-abuse data: an anonymous identifier generated by the app, and network metadata (such as the IP address) to apply limits and prevent fraud.
• Reports: if you report an image, we keep the type of creation, the reason and the date, never the image itself.
• Support data: your email address and your message if you write to us.

2. What we do not do

We do not sell your data. We do not use your photos to recognize or identify you, and we do not create a “template” of your face. We do not use them for advertising. We do not keep your photo, your result or your request on our servers beyond processing; your creation history stays on your phone.

3. Why we process it and on what basis

• Creating the image you ask for: performance of the contract.
• Managing your subscription and your creations: performance of the contract and legal obligations (accounting).
• Preventing fraud and abuse: legitimate interest.
• Answering your messages: legitimate interest and performance of the contract.
• Photos showing your face: we ask for your consent in the app before the first upload. You can withdraw it at any time by deleting your data.

4. Who we share it with

Only with the providers we need: Apple (payments), RevenueCat (subscriptions), our server host, and our AI image-generation providers, including Google models. They process data on our behalf and under our instructions. Some are located outside the European Union, notably in the United States; in that case the transfer relies on appropriate safeguards (for example the European Commission’s standard contractual clauses). We may also disclose data if the law requires it.

5. How long we keep it

• Photos and results: not kept on our servers beyond processing; history kept on your phone until you delete it.
• Subscription and billing data: for the duration of the subscription, then for the legal retention periods.
• Anti-abuse data: 12 months.
• Support messages: 3 years after the last exchange.

6. Your rights

You can request access to your data, its correction, erasure or portability, restriction of or objection to processing, and withdraw your consent at any time. In the app: Account › “Delete my photos and my account” erases your data. You can also write to us; we reply within one month. If you believe your rights are not respected, you can lodge a complaint with your data protection authority (in France, the CNIL). If you live in the United States (for example in California), you have equivalent rights of access, deletion and to opt out of the sale of data; we do not sell personal data.

7. Security

Exchanges between the app and our servers are encrypted. Our providers’ keys stay on our servers, never in the app. No method is perfectly secure, but we limit the data processed to what is strictly necessary.

8. Children

Pozelle is not intended for children (13 or older in the United States, 16 or older in the EU and the UK, or older depending on your country). If you think a child has given us data, write to us and we will delete it.

9. Changes and contact

We may update this policy; in case of a material change, we will tell you in the app. A question about your data?