Privacy Policy
Last Updated: October 21, 2025
This Privacy Policy describes how AI Headshot Generator ("we", "our", or "the App") collects, uses, and protects your information when you use our mobile application. We are committed to protecting your privacy and handling your data in an open and transparent manner.
Important Notice About Face Data: Our app collects and processes photos containing facial data to generate AI headshots. Please read the "Face Data Collection and Use" section carefully to understand how we handle this sensitive information.
1. Face Data Collection and Use
1.1 What Face Data We Collect
When you use our App, we collect the following face-related data:
- Photographs containing faces: Users voluntarily upload photos that contain their faces or the faces of others (with appropriate consent) to generate AI-powered professional headshots.
- No biometric extraction: We do NOT extract, store, or process any specific facial features, facial recognition data, biometric identifiers, or facial measurements. The images are processed as complete photographs only.
1.2 How We Use Face Data
The face data collected is used exclusively for the following purpose:
- AI Headshot Generation: Your uploaded photos are sent to our third-party AI processing provider (Fal AI using the Nano Banana model) to generate professional AI headshots based on your input image. The AI analyzes the photo to create new, styled headshot images.
- No other uses: We do NOT use your face data for:
- Training or improving AI models
- Marketing or advertising purposes
- Facial recognition or identification
- Analytics or tracking
- Sharing with third parties (except as described in section 1.3)
- Any purpose other than generating your requested headshots
1.3 Face Data Sharing with Third Parties
Third-Party AI Processor: Your uploaded photos are shared with our AI processing provider:
- Provider: Fal AI (https://fal.ai/)
- AI Model: Nano Banana
- Purpose: To process your images and generate AI headshots
- Data Handling: Fal AI processes your images in accordance with their privacy policy and security practices
No Other Third-Party Sharing: Your face data is NOT shared with any other third parties, advertisers, data brokers, or external services. We do not sell, rent, or trade your face data.
1.4 Face Data Storage and Retention
Uploaded Photos (Original Images):
- App Storage: We do NOT store your uploaded photos on our servers or in any cloud storage (including Firebase Storage).
- Temporary Processing: Your uploaded photos are transmitted directly to Fal AI for processing and are not retained by our App.
- AI Provider Retention: Fal AI automatically deletes your uploaded photos from their servers after following processing.
Generated Headshots (AI Output Images):
- Storage Duration: The AI-generated headshot images are stored on our servers for 1 year from the date of generation.
- Automatic Deletion: After 30 days, all generated headshots are automatically and permanently deleted from our systems.
- User-Initiated Deletion: You can request earlier deletion of your generated headshots at any time (see section 1.5).
1.5 Your Rights Regarding Face Data
You have the following rights concerning your face data:
- Access: You can request information about what face data we have processed.
- Deletion: You can request deletion of your uploaded photos and generated headshots at any time by contacting us via email.
- Withdrawal of Consent: You can stop using the App at any time, and no further face data will be collected.
To exercise these rights, please contact us at the email address provided in the "Contact Us" section below.
2. Other Information We Collect
2.1 Account Information
- User ID: A unique identifier for your account
- Gender Selection: Optional gender information to help generate better AI results
- Selected Themes/Styles: Your preferences for headshot styles
2.2 Purchase Information
- Credit Purchases: Information about credit packages you purchase through RevenueCat
- Transaction Data: Handled securely through Apple's App Store (we do not have access to your payment card information)
2.3 Usage Analytics
We collect anonymous usage analytics to improve the App, including:
- Feature usage statistics
- App performance data
- Error logs and crash reports
Important: Our analytics do NOT track or include any face data, images, or personally identifiable information.
3. How We Protect Your Information
We implement appropriate technical and organizational security measures to protect your data:
- Encryption: All data transmitted between the App and our servers uses industry-standard encryption (HTTPS/TLS)
- Secure Storage: Data stored on our servers is protected with appropriate security measures
- Access Controls: Only authorized personnel have access to systems that may contain user data
- Regular Security Reviews: We regularly review and update our security practices
4. Third-Party Services
4.1 AI Processing
- Fal AI: Processes uploaded photos to generate AI headshots. Photos are automatically deleted after 7 days.
4.2 Authentication & Database
- Firebase: Used for user authentication and storing app data (excluding uploaded photos). Google Firebase Privacy Policy applies.
4.3 Payment Processing
- RevenueCat: Manages in-app purchases and subscriptions. RevenueCat Privacy Policy applies.
- Apple App Store: Processes all payments. Apple Privacy Policy applies.
5. Your Privacy Rights
Depending on your location, you may have the following rights:
- Access: Request access to your personal data
- Correction: Request correction of inaccurate data
- Deletion: Request deletion of your data
- Portability: Request a copy of your data in a portable format
- Objection: Object to certain processing of your data
- Restriction: Request restriction of processing in certain circumstances
6. Data Retention Summary
| Data Type |
Retention Period |
| Uploaded Photos (Your Images) |
Not stored by us; Deleted by Fal AI after 7 days |
| Generated Headshots |
1 year (automatically deleted) |
| Account Data |
Until account deletion requested |
| Purchase History |
As required for tax and legal purposes |
| Analytics Data |
Anonymized; Retained for service improvement |
7. International Data Transfers
Your data may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers in compliance with applicable data protection laws.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by:
- Posting the new Privacy Policy in the App
- Updating the "Last Updated" date at the top of this policy
- Sending you a notification through the App (for significant changes)
9. California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
- Right to know what personal information is collected
- Right to know if personal information is sold or disclosed
- Right to say no to the sale of personal information
- Right to access your personal information
- Right to equal service and price
We do not sell your personal information or face data to any third parties.
10. European Privacy Rights (GDPR)
If you are in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR), including:
- Right of access, rectification, and erasure
- Right to restrict or object to processing
- Right to data portability
- Right to lodge a complaint with a supervisory authority
Legal Basis for Processing: We process face data based on your explicit consent, which you provide when uploading photos to generate headshots.