# Privacy Policy for Christmas App
Last Updated: November 23, 2024
## Introduction
Limbic Apps Limited Sirketi ("we," "our," or "us") operates the Christmas App (the "App"). This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our App and the choices you have associated with that data.
## Information Collection and Use
### Personal Data
We collect several different types of information for various purposes to provide and improve our App:
- **Account Information**: Email address (if provided)
- **Usage Data**: App features used, credit transactions
- **Device Information**: Device type, operating system version, unique device identifiers
- **Images**: Photos you upload for styling
### Usage of Images
- Images you upload are processed via our sub-processors (replicate.com, fal.ai and Amazon Web Services) solely for the purpose of applying style modifications. We don't store or extract any face information from your selfie photos. You can find our sub-processors privacy policies here https://replicate.com/privacy and https://fal.ai/privacy
- We do not store your original or processed images longer than necessary to provide the service.
- We do not use your images for any purpose other than providing the requested styling service.
### Face Data Policy
• Face data we collect
We use Amazon AWS Rekognition service to detect gender and apply filter accordingly. Amazon Rekognition does not persist any information discovered about the input image. Like all other Amazon Rekognition API operations, no input image bytes are persisted by non-storage API operations.
We process your photos to apply styles to the faces in the photos. We do not collect facial data. After the analysis process, all data will be deleted and no data will be saved.
• Purpose and process of collecting face data
In order to give you the "face swap" effect, we need to find feature points (e.g. eyes, nose, mouth points).
The complete process is: (1) You submit the selected photo to our server in an encrypted way; (2) We send this photo to AWS Rekognition for gender detection (3) We send this photo to our sub-processors fal.ai and replicate.com (4) Their server process your photo and applies it to the template you choose; (5) After the composition is completed, the server returns the final rendering effect to you through the application;(6) The final composite effect returned to user and will be permanently deleted after a certain period of time. After the compositing process is complete, we and our sub-processors will delete the face image you submitted to the server immediately.
• Face data sharing and storage
Nor we or nor our sub-processors store any face information you submit, and the photos you upload will be deleted after the analysis process is complete.
### Data Retention
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Both sub-processors don't store the input data we provide them which is the selfie photos ( face data) in this case.
We don't store your face data on our servers. Our sub-processors' data retention policy is shared below:
Replicate.com's retention policy:
"We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods."
Fal.ai's retention policy:
We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us .
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
## Data Storage and Security
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
## Use of Data
We use the collected data for various purposes:
- To provide and maintain the App
- To notify you about changes to our App
- To provide customer support
- To detect, prevent and address technical issues
- To process your payments through the App Store
## Data Sharing and Disclosure
We do not sell or share your personal data with third parties except:
- As required by law
- To protect our rights
- To process payments through Apple's App Store
- To provide the App's core functionality
- Images you upload are processed via our sub-processors (replicate.com and fal.ai) solely for the purpose of applying style modifications.
## Your Rights
You have the right to:
- Access your personal data
- Request correction of your personal data
- Request deletion of your personal data
- Object to processing of your personal data
- Request data portability
## Children's Privacy
Our App does not address anyone under the age of 13. We do not knowingly collect personal information from children under 13.
## Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
## Analytics and Third-Party Services
We may use third-party Service Providers to:
- Monitor and analyze the use of our App
- Process payments
- Provide technical infrastructure
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
## Data Retention
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
## International Data Transfers
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
## Cookies and Tracking
Our App does not use cookies directly. However, we may use third-party code and libraries that use cookies or similar technologies for collecting usage information and ensuring the best possible user experience.
## Your Consent
By using our App, you consent to our Privacy Policy and agree to its terms.
## Contact Us
If you have any questions about this Privacy Policy, please contact us:
- By email: support@limbicapps.com
- By mail: Limbic Apps Limited Sirketi [Address to be added]
## Legal Requirements
We will disclose your Personal Data where required to do so by law or in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend our rights or property
- Prevent or investigate possible wrongdoing in connection with the App
- Protect the personal safety of users of the App or the public
- Protect against legal liability
## Your Rights Under GDPR and Other Privacy Laws
If you are a resident of the European Economic Area (EEA) or other jurisdictions with comprehensive privacy laws, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.