Selfie Anywhere - Privacy Policy

Last Updated: December 4, 2025

Effective Date: December 4, 2025

At a Glance

• We collect only what is needed to operate Selfie Anywhere: account basics, uploaded/base images, location selections, generated images, and essential diagnostics.
• You control your content and can delete uploads and generated images at any time from within the app.
• Payment is processed by Apple; we do not store your card details.
• We do not sell personal data or run third-party advertising.
• You can request access, correction, export, or deletion by emailing support@selfie-anywhere.app.

1. Introduction

Selfie Anywhere (“we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

Who We Are (Data Controller)

Selfie Anywhere, Inc. is the controller for your personal data unless stated otherwise. You can contact us at support@selfie-anywhere.app for privacy questions or rights requests.

Children and Eligibility

• The Service is intended for users 16 years and older.
• If you are 16 or 17, you must have consent from a parent or legal guardian.
• We do not direct the Service to children under 16 and do not knowingly collect their data. If we learn we have collected data from someone under 16, we will delete it. You can request deletion via support@selfie-anywhere.app.

2. Information We Collect

2.1 Information You Provide

2.2 Information Collected Automatically

2.3 Information from Third Parties

• Apple Sign-In: Authentication data (email, user ID)
• App Store: Subscription status, purchase verification

3. How We Use Your Information

3.1 Primary Uses

• Service Delivery: Process your images and generate content
• Account Management: Maintain your account and subscription
• Communication: Send important service updates
• Security: Prevent fraud and abuse
• Improvement: Analyze usage to improve the Service

3.2 AI Processing

Your Base Images are processed by:

Important: Your images may be processed by Google’s AI services subject to their terms. We do not use your images to train AI models, and we contractually restrict providers from using your images for training or fine-tuning.

3.3 We Do NOT

• Sell your personal data
• Share your images publicly without consent
• Use your data for targeted advertising
• Train AI models on your personal images
• Share data with data brokers

3.4 Legal Bases (GDPR/LGPD)

• Contract: To provide the Service you request (processing images, account, payments).
• Legitimate interests: Security, fraud prevention, service improvement (balanced against your rights).
• Consent: Optional analytics cookies on the website (where shown) and any marketing emails (not currently sent).
• Legal obligation: Responding to lawful requests and compliance with financial, tax, and consumer protection laws.

4. Data Sharing

4.1 Service Providers

We share data with trusted service providers:

We update this Privacy Policy when we materially add new categories of service providers that receive personal data.

4.2 Legal Requirements

We may disclose data when required by:

• Valid legal process (subpoena, court order)
• Law enforcement with proper authority
• Protection of our legal rights
• Emergency situations involving safety

4.3 Business Transfers

In case of merger, acquisition, or sale, your data may be transferred to the new entity with equivalent privacy protections.

5. Data Security

5.1 Technical Measures

• Encryption: All data encrypted in transit (TLS 1.3) and at rest
• Access Control: Role-based access, principle of least privilege
• Infrastructure: Enterprise-grade Cloudflare security
• Authentication: Secure token-based authentication

5.2 Organizational Measures

• Regular security reviews
• Employee access logging
• Incident response procedures
• Vendor security assessments

5.3 Your Responsibilities

• Keep your Apple ID secure
• Don’t share your account
• Log out on shared devices
• Report suspicious activity

6. Data Retention

6.1 Deleted Content

When you delete content:

1. Immediately removed from your account
2. Moved to secure archive (90 days)
3. Permanently deleted after archive period

We retain deleted content temporarily for:

• Legal compliance requirements
• Abuse investigation if flagged
• Technical backup recovery

7. Your Rights

7.1 All Users

You have the right to:

• Access: Request a copy of your data
• Correction: Update inaccurate information
• Deletion: Delete your account and data
• Portability: Export your generated images
• Objection: Object to certain processing

7.2 California Residents (CCPA)

Additional rights under CCPA:

• Right to know what data is collected
• Right to know if data is sold (we don’t sell data)
• Right to non-discrimination for exercising rights

We do not “sell” or “share” personal information (including for cross-context behavioral advertising) as defined by the CCPA/CPRA, and we do not use or disclose sensitive personal information (e.g., face images) for purposes other than providing the Service, security, short-term analytics, and other limited uses permitted by law. If these practices change, we will provide required notices and opt-out mechanisms.

7.3 European Residents (GDPR)

Additional rights under GDPR:

• Right to restrict processing
• Right to withdraw consent
• Right to lodge complaint with supervisory authority

7.4 Brazil (LGPD)

Additional rights under LGPD:

• Confirmation of processing and access to data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking, or deletion of unnecessary or excessive data
• Portability to another provider where applicable
• Deletion of data processed with consent
• Information about public and private entities with which we share data
• Revocation of consent and review of automated decisions where legally required

7.5 Exercising Your Rights

1. Email support@selfie-anywhere.app from the address linked to your account.
2. Specify which rights you want to exercise (access, correction, deletion, portability, or objection).
3. We will verify your identity via your account email and, if needed, a follow-up confirmation.
4. We will respond within 30 days (GDPR) or 45 days (CCPA), and tell you if more time is required.

If we deny your request, you may appeal by replying to our response. If you are unsatisfied after appeal, you may contact your local data protection authority.

8. International Transfers

Your data may be processed in:

• United States (Cloudflare, Google)
• European Union (Cloudflare)
• Other regions (Cloudflare edge locations)

We ensure adequate protection through:

• Standard Contractual Clauses
• Data Privacy Framework or other applicable adequacy decisions (where available)
• Vendor privacy certifications

For transfers from the EEA, UK, and Brazil, we rely on Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework or equivalent safeguards. You can request a copy of applicable transfer safeguards (with confidential terms redacted) by emailing support@selfie-anywhere.app.

9. AI-Specific Privacy

9.1 AI Processing Transparency

When you use our Service:

1. Your Base Image is sent to Google Gemini AI
2. AI generates a new synthetic image
3. Original and generated images are stored in our systems
4. Google may process data per their Privacy Policy

9.2 AI Training

• We do not use your images to train our own AI models.
• We contractually require Google and other AI providers not to use your images for training or fine-tuning.
• You can request deletion of all your data at any time.

9.3 AI Output Ownership

• Generated images are derivative works
• You have a license to use them per our Terms
• Copyright status varies by jurisdiction

10. Cookies and Tracking

10.1 Mobile App

Our mobile app uses:

• Local storage: App preferences, authentication tokens
• Analytics: Anonymized usage metrics
• No third-party advertising trackers

10.2 Website (if applicable)

Our website may use:

• Essential cookies (functionality)
• Analytics cookies (with consent)
• No advertising or tracking cookies

11. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be communicated via:

• In-app notification
• Email to registered users
• Updated “Last Modified” date

Continued use after changes constitutes acceptance.

12. Contact Us

Privacy Inquiries

Email: support@selfie-anywhere.app

Data Protection Officer

Email: support@selfie-anywhere.app

General Support

Email: support@selfie-anywhere.app

Mailing Address

Selfie Anywhere, Inc. (mailing address available upon request via support@selfie-anywhere.app)

13. Additional Disclosures

13.1 Do Not Track

We do not respond to “Do Not Track” browser signals as there is no industry standard for compliance.

13.2 Third-Party Links

Our Service may contain links to third-party services. We are not responsible for their privacy practices.

13.3 Data Breach Notification

In case of a data breach affecting your personal data, we will:

• Notify affected users within 72 hours (GDPR requirement)
• Notify relevant authorities as required by law
• Provide information about protective measures

Where other laws apply (e.g., U.S. state laws, Brazil’s LGPD), we will follow those notification timelines and requirements.

This Privacy Policy is designed to comply with GDPR, CCPA, and Apple’s App Store guidelines. For questions about specific regional requirements, contact our Data Protection Officer.