Privacy Policy

Last Updated: October 1, 2025

1. Information We Collect

1.1 Information You Provide

We collect information you directly provide when using our services:

• Account Information: Username, email address, password (encrypted)
• Profile Information: Optional profile details you choose to share
• Content: Photos, images, AI-generated content, and related metadata
• Payment Information: Processed securely through Stripe (we do not store card details)
• Communications: Messages, feedback, and support requests

1.2 Automatically Collected Information

When you use our service, we automatically collect:

• Usage Data: Pages visited, features used, time spent, interactions
• Location Data: IP address, general geographic location (country/region)
• Cookies and Similar Technologies: See Section 8 for details
• Log Data: Access times, error logs, referral URLs

1.3 Information from Third Parties

• OAuth Providers: When you sign in with Google, we receive basic profile information (name, email, profile picture)
• Payment Processors: Transaction confirmations from Stripe

2. How We Use Your Information

We use your information for the following purposes:

2.1 Service Provision

• Create and manage your account
• Provide access to photos, albums, and AI generation features
• Process your membership and credit purchases
• Store and display your content
• Enable social features (favorites, sharing)

2.2 AI and Machine Learning

• Content Moderation: Automated detection of prohibited content (NSFW, illegal material)
• AI Model Training: Improving AI generation quality (only with anonymized, aggregated data)
• Service Enhancement: Optimizing features and recommendations

Your Rights: You can opt out of AI training by contacting us. Content moderation for safety cannot be opted out.

2.3 Communications

• Send service notifications (account updates, AI generation completion)
• Respond to your inquiries and support requests
• Send marketing communications (with your consent; you can opt out)

2.4 Safety and Security

• Detect and prevent fraud, abuse, and illegal activity
• Enforce our Terms of Service
• Protect our rights and property
• Comply with legal obligations

2.5 Analytics and Improvement

• Analyze usage patterns and trends
• Improve our services and develop new features
• Conduct research and development

3. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), we process your data based on:

• Consent: When you agree to specific data uses (e.g., marketing emails, AI training)
• Contract: To provide services you've requested (account, membership)
• Legal Obligation: To comply with laws (e.g., age verification, reporting illegal content)
• Legitimate Interests: For security, fraud prevention, and service improvement (balanced against your rights)

4. How We Share Your Information

We do NOT sell your personal information. We share data only in these limited circumstances:

4.1 Service Providers

We share data with trusted third parties who help us operate:

• Payment Processing: Stripe (for transactions)
• Content Delivery: BunnyCDN (for image/video hosting)
• Authentication: Google (for OAuth login)

These providers are contractually obligated to protect your data and use it only for specified purposes.

4.2 Public Content

• Content you mark as public or share may be visible to other users
• AI-generated content marked as "recommended" (by admins) may be shown to other users

4.3 Legal Requirements

We may disclose information when required by law or to:

• Comply with legal processes (subpoenas, court orders)
• Enforce our Terms of Service
• Protect rights, property, or safety
• Respond to emergency situations
• Report child sexual abuse material (CSAM) to authorities

4.4 Business Transfers

If we are involved in a merger, acquisition, or sale, your information may be transferred. You will be notified of any such change.

5. Data Retention

We retain your information for as long as necessary to provide services and comply with legal obligations:

• Account Data: Until you delete your account, then 30 days for backups
• Content: Until you delete it or your account is closed
• Transaction Records: 7 years (for tax/legal compliance)
• Logs and Analytics: 90 days to 2 years (aggregated data may be retained indefinitely)
• Legal Holds: Longer if required by law or ongoing investigations

6. Your Privacy Rights

6.1 GDPR Rights (EEA Users)

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate data
• Erasure ("Right to be Forgotten"): Delete your data (subject to legal obligations)
• Restriction: Limit how we use your data
• Data Portability: Receive your data in a machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Revoke consent at any time (doesn't affect prior processing)
• Lodge a Complaint: File a complaint with your local data protection authority

6.2 CCPA Rights (California Users)

California residents have the right to:

• Know: What personal information we collect, use, and share
• Delete: Request deletion of your personal information
• Opt-Out: Opt out of "sales" (we don't sell data, but you can opt out of certain sharing)
• Non-Discrimination: Not be discriminated against for exercising your rights

6.3 How to Exercise Your Rights

To exercise any of these rights:

• Email: muckleoken@gmail.com
• Account Settings: Manage preferences in your account dashboard
• Data Export: Request via email (we'll respond within 30 days)

We will verify your identity before processing requests.

7. Data Security

We implement robust security measures to protect your information:

• Encryption: Data in transit (TLS/SSL) and at rest
• Access Controls: Limited employee access on a need-to-know basis
• Authentication: Secure password hashing (bcrypt), OAuth support
• Infrastructure: Secure servers, regular security audits
• Monitoring: Intrusion detection and logging
• Incident Response: Plan for data breach notification (within 72 hours for GDPR)

However, no system is 100% secure. Please use a strong password and enable two-factor authentication when available.

8. Cookies and Tracking Technologies

8.1 What We Use

• Essential Cookies: Required for login, session management, security (cannot be disabled)
• Functional Cookies: Remember your preferences (language, theme)

8.2 Cookie Management

You can control cookies through:

• Browser settings (most browsers allow cookie blocking)
• Our cookie consent banner (for EU users)
• Third-party opt-out tools

9. International Data Transfers

We operate globally. Your data may be transferred to and processed in countries outside your residence, including the United States.

For EEA Users:

• We use Standard Contractual Clauses (SCCs) approved by the EU Commission
• We ensure adequate safeguards are in place
• You have the right to obtain information about these transfers

10. Children's Privacy

• We do not knowingly collect data from children
• If we discover we have collected data from a child, we will delete it immediately
• Parents/guardians: contact us if you believe your child has provided information

11. Third-Party Links and Services

Our service may contain links to third-party websites, plugins, or services. We are not responsible for their privacy practices. Please review their privacy policies.

12. AI-Specific Privacy Considerations

12.1 AI Generation Data

• Your prompts and generated content are stored to provide the service
• We may use aggregated, anonymized data to improve AI models
• We do NOT share your individual prompts or content with third parties for their purposes

12.2 Content Moderation AI

• We use automated tools to scan uploads for prohibited content
• This scanning is necessary for safety and legal compliance
• Detected violations may be reviewed by human moderators

12.3 Portrait Rights and AI

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the updated policy with a new "Last Updated" date
• Sending an email notification (for significant changes)
• Displaying a notice on our website

Continued use after changes indicates acceptance of the updated policy.

14. Contact Us

For privacy-related questions, requests, or complaints:

• Privacy Email: muckleoken@gmail.com

15. Supervisory Authorities

If you are in the EEA and have concerns about our data practices, you have the right to lodge a complaint with:

• Your local data protection authority
• The lead supervisory authority in Ireland (if we have an EU establishment there)

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