Privacy Policy of “AI Professional Headshot Generator”
Update Date: 31 July 2025
1. Objective and Scope
Limbic Apps Yazilim Ltd Sti. (“Company”, “we”, “us”, or “our”) is committed to protecting the privacy of our users. This Privacy Policy outlines how we collect, use, process, and protect your personal data when you use our “AI Professional Headshot Generator” application (the “App”).
This policy is designed to comply with applicable data protection legislation, including the Turkish Law on Personal Data Protection No. 6698 (“PDP Law”) and, where applicable, the General Data Protection Regulation (GDPR).
By using the App, you agree to the collection and use of information in accordance with this policy.
2. Personal Data We Collect and How We Collect It
We may collect and process the following personal data:
Identity and Contact Information: Such as your name and surname, email address, or phone number if you contact our support channels.
User-Uploaded Content: The photos you voluntarily upload to the App for processing.
Transaction Information: Order information and in-app purchase history if you subscribe to premium features. This data is primarily processed by the respective App Stores (Apple App Store, Google Play App Store), and we receive transaction confirmation data.
Device and Technical Information: Internet Protocol (IP) address, device name and identifier, operating system version, the configuration of the App when you use it, and identifiers for advertisers (IDFA) or vendors (IDVF) if permissions are enabled on your device.
Usage Data: Information about how you use the App, such as features used and the time, frequency, and duration of your activities.
We collect this data directly from you when you upload it to the App, from your device, and from third-party platforms like the App Stores.
3. Face Data Process
Your privacy is our priority. This section details how we handle the photos you upload to power the AI generation process.
Purpose of Processing: Training a Temporary AI Model. To generate personalized headshots, our service uses the photos you upload to train a temporary, single-use AI model. This model learns your facial features from the images provided to create new, stylized photos that look like you. This trained model is created exclusively for your single request and is not used for any other purpose or for any other user.
No Permanent Biometric Profile: We do not collect, store, or create a permanent biometric profile of our users. The AI model trained from your photos is temporary and is not used to identify you outside of your active session.
Strict Data Deletion and Retention: This is our commitment to you: Both the original photos you upload, the temporary AI model trained from them, and the final generated headshots are permanently deleted from our servers and our sub-processor's servers within 24 hours of the images being successfully generated. We do not retain your images or the model created from them for longer than is strictly necessary to provide the service to you.
Sub-processor for AI Generation: We utilize fal.ai as a specialized sub-processor to perform the AI model training and image generation. They are contractually and legally bound to handle your data with strict confidentiality, to use it only for this specific purpose, and to adhere to the same deletion schedule. You can review their privacy policy here: https://fal.ai/privacy
No Improvement of Our General AI Models: We do not use your personal photos or the temporary models trained from them to train, retrain, or improve our general, underlying AI models. Each user's generation process is separate and ephemeral.
4. Purposes and Legal Basis for Processing Personal Data
We process your personal data for the following purposes:
To Provide and Maintain the App's Service: Processing your uploaded images to train a temporary model, generating photos, creating your user account, and managing in-app purchases. (Legal basis: Performance of a contract with you).
To Improve User Experience: Understanding user preferences and customizing our services. (Legal basis: Legitimate interest).
For Communication and Support: Responding to your requests, sending non-promotional push notifications about service updates, and providing customer support. (Legal basis: Performance of a contract and legitimate interest).
For Security and Legal Compliance: Protecting against fraud, complying with legal obligations, and responding to requests from public authorities. (Legal basis: Legal obligation and legitimate interest).
5. Data Transfer to Third Parties
We do not sell your personal data. Your data may be shared with:
Service Providers and Sub-processors: Such as fal.ai for AI model training and image processing, and cloud hosting providers. These parties are authorized to use your data only as necessary to provide these services to us.
App Stores: For processing payments for in-app purchases.
Analytics Providers: Such as Firebase Analytics to understand app usage.
Public and Legal Authorities: If required by law or to protect our rights.
As we use international service providers, your data may be processed in servers outside of your country of residence. In such cases, we ensure that the transfer is protected by appropriate safeguards as required by the PDP Law and GDPR.
6. Your Rights as a Data Subject
Under the PDP Law and GDPR, you have the following rights regarding your personal data:
Right of Access: To learn if your data is being processed and request a copy.
Right to Rectification: To correct inaccurate or incomplete data.
Right to Erasure (Right to be Forgotten): To request the deletion of your personal data.
Right to Restrict Processing: To limit how we use your data.
Right to Data Portability: To receive your data in a machine-readable format.
Right to Object: To object to the processing of your data, especially for marketing purposes.
Rights in Relation to Automated Decision-Making: To not be subject to a decision based solely on automated processing.
To exercise these rights, please contact us by sending the "Data Subject Application Form" to support@limbicapps.com. We will respond to your request within 30 days, free of charge, as required by law.
7. User Responsibilities
You represent and warrant that you have all the necessary rights, licenses, and permissions for any photos you upload to the App and that your content does not infringe on the intellectual property or privacy rights of any third party.
8. Intellectual Property
You retain full ownership and intellectual property rights to the original photos you upload and the final headshot images generated by the App. We claim no ownership over your content. You grant us a temporary, non-exclusive, royalty-free license to use, modify, and process your uploaded photos solely to provide the App's services to you. We and our licensors retain all ownership and rights to the App itself, including all underlying AI models, software, and technology.
9. Disclaimer of Warranties
THE APP AND ITS SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. WE DO NOT GUARANTEE THAT THE RESULTS GENERATED BY THE APP WILL MEET YOUR EXPECTATIONS OR BE ERROR-FREE.
10. Limitation of Liability
TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL LIMBIC APPS YAZILIM LTD STI., ITS AFFILIATES, DIRECTORS, OR EMPLOYEES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR REVENUES, WHETHER INCURRED DIRECTLY OR INDIRECTLY, OR ANY LOSS OF DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, RESULTING FROM (A) YOUR USE OF THE APP; (B) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SERVERS AND/OR ANY PERSONAL INFORMATION STORED THEREIN.
11. Indemnification
You agree to defend, indemnify, and hold harmless Limbic Apps Yazilim Ltd Sti. and its employees, and agents from and against any and all claims, damages, obligations, losses, liabilities, costs, or debt, and expenses (including but not limited to attorney's fees) arising from: (i) your use of and access to the App; (ii) your violation of any term of this Privacy Policy; (iii) your violation of any third-party right, including without limitation any copyright, property, or privacy right.
12. Data Security
We implement appropriate technical and administrative measures, such as encryption and access controls, to protect your personal data against unauthorized access, loss, or destruction. However, no method of transmission over the internet is 100% secure, and we cannot guarantee its absolute security.
13. Governing Law and Dispute Resolution
This Privacy Policy shall be governed and construed in accordance with the laws of the Republic of Turkey, without regard to its conflict of law provisions. You agree to submit to the exclusive jurisdiction of the courts and enforcement offices of Izmir, Turkey to resolve any legal matter arising from this policy.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy in the App. Your continued use of the App after the changes become effective will constitute your acceptance of the revised policy.
15. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:
Company Title: Limbic Apps Yazilim Ltd Sti.
Address: Gülbahçe Mah. Gülbahçe Cd. Kuluçka Merkezi Binası Sit. No: 1 / 45 /21 Urla / İzmir
E-mail: support@limbicapps.com