Welcome to Faceformer’s Privacy Policy

Privacy Policy

Last updated April 8, 2025

This privacy policy (the “Privacy Policy”) describes the privacy practices of Faceformer in connection with the Faceformer mobile applications (each, an “App” and collectively, the “Apps”).

If you decide not to read this entire Privacy Policy, we want you to walk away with a few key points about Faceformer’s privacy practices:

  • The Apps are AI-powered photo editors that allow users to generate realistic, stylized images of themselves based on a portrait photograph.

  • We do not use photographs you provide when you use the Apps for any reason other than to provide you with the functionality of the Apps.

  • We use third-party cloud providers, specifically, RunPod Services - which utilise data centres located in the US, EU, to process and edit photographs.

  • You only send to the cloud the photographs that you specifically select for editing.

  • All cached files are temporarily stored on cloud servers exclusively for the duration of the editing process and are automatically deleted from the temporary storage directory upon completion of the process.

  • Photographs are not stored in the cloud or on any platform other than your personal device after processing is complete.

  • Facial imagery is temporarily processed solely to apply selected effects and is not stored or retained after the editing task is completed. No facial data is collected, analyzed, or shared at any point.

Here’s more on our privacy practices.

1. Information We Collect

1.1. When You Use the Apps and Provide Photographs or Facial Imagery for Editing , we cache them for processing to render the requested editing service:

  • Facial Imagery: When you use the Apps and select photographs that include human faces for editing, we may temporarily process images that contain face data solely to apply your requested effects and features. We do not collect, store, or retain any face data, biometric identifiers, or biometric information from these photographs. We do not extract or analyze facial features, demographics, or any other biometric characteristics. All processing is conducted automatically on secure cloud servers solely for the purpose of providing the requested editing service. No face data or related information is stored after processing is complete, and no such data is shared with third parties.

  • Photographs: The Apps process only the specific photographs you voluntarily select for editing, whether captured through your device’s camera, chosen from your camera roll (subject to your granting the necessary permissions), or obtained via the in-app internet search functionality. We process only the specific photos you choose to modify using the Apps; we do not collect your photo albums even if you grant us access to them. While we do not require or request any metadata attached to the photographs you select for editing, metadata (including, for example, geotags) may be associated with your photographs by default. We take steps to delete any metadata that may be associated with a photograph you provide when you use the Apps. Photographs only temporarily cached on secure cloud servers during processing and are not retained after the processing request is completed.

1.2. When you use the Apps, we may collect some information, including:

  • Apps usage information and online activity data, such as information about 1) how you use the Apps and interact with them, including the features you use, your preferred language, the date and time when you first installed the Apps and the date and time when you launch the Apps; 2) sources of referrals to the Apps.

  • App-related purchase history, if you choose to purchase an Apps subscription, we will not receive such information as billing address, credit card etc. (as we don’t distribute subscriptions directly), we will only receive confirmation from the relevant application store that you are a paid subscriber to the Apps so we can provide paid services.

  • Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, push tokens, browser type, screen resolution, IP address (and the associated city/country in which you are located).

Generally, all data are associated only with an App Instance ID (assigned to an instance of the Apps installed on your mobile device). Online identifiers such as an IP address and App Instance ID are generally considered as personal data. However, we are not in a position to identify you specifically by name or address on the basis of such identifiers.

This information may be collected through our Apps using cookies, and similar technologies. We may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from the App. For more information, please see our Cookie Policy.

1.3. When you contact us by email, we may also collect:

Contact information, such as your name and email address, and information relating to your communication.

2. How We Use Your Information

2.1. We do not use photographs you provide when you use the Apps for any reason other than to provide you with the editing functionality of the Apps.

2.2. We may use information other than photographs for the following purposes:

To operate and improve the Apps. We use your personal information to operate, maintain, and provide you with the Apps and the Site. In particular, we will use your personal information to perform our contractual obligations under our Terms of Use Agreement, such as to:

  • Enable you to use the Apps’ features.

  • Communicate with you about the Apps, including by sending you announcements, updates, and security alerts, which we may send through a push notification, and responding to your email requests, questions, and feedback.

  • Provide technical support and maintenance for the Apps.

To improve, monitor, and protect our Apps. It is in our legitimate business interests to improve and keep our services safe and secure for our users. We do this by:

  • Performing statistical analysis on aggregated data relating to the use of the Apps (including through the use of third-party services).

  • Troubleshooting, testing, and researching.

To market and to promote our Services. We may use your personal information to understand where our App traffic comes from to improve our marketing strategies and our promotional companies. It helps us to personalize our promotion offers and understand broader our Service audience behavior, offering a tailored experience. Where required under applicable law, we process your personal information based on your consent for these purposes, which you may withdraw at any time. Otherwise, we process your personal information for marketing and promotional purposes where it is in our legitimate interests to do so.

For compliance, fraud prevention, and safety. We may use and disclose the information we collect (such as device data and Apps usage information) where it is in our legitimate business interests to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Apps; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity. We may disclose this information to government authorities and other third parties as required by applicable law. We cannot disclose the photos that have been cached for processing as we do not store the encryption keys.

To create anonymous, aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data where it is in our legitimate business interests, and use and share it with third parties.

2.3. We will only process personal information on the basis of our legitimate interests where such interests are not overridden by your interests or your fundamental rights and freedoms.

2.4. We use cookies that are essential for Faceformer to function. We would also like to use cookies and similar technologies to store, access and process your information for analytics, troubleshooting, and marketing. With your consent, we and our third-party partners may use additional tracking technologies to enhance your user experience.

3. How We Share Your Information

3.1. We do not disclose user photographs to third parties (with the exception of temporarily caching an encrypted version with our cloud provider, RunPod, to provide the photo editing features of the Apps). We cannot disclose the photos cached for processing as we do not store the encryption keys.

3.2. We do not sell personal information. We may share your non-photograph information in the following circumstances:

Affiliates. We may share information we collect from you with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your information with service providers that perform services on our behalf or help us operate the Apps (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

Third-party platforms and social media networks. You may select to post the edited photograph to your social media account. We do not control any third-party platform’s use of your information, which is governed by that third party’s privacy policy and terms and conditions.

Professional advisors. We may disclose your information to professional advisors, such as lawyers and auditors, where necessary in the course of the professional services that they render to us.

Business transfers. We may also transfer or assign your personal data in the course of corporate divestitures, consolidations, mergers, acquisition, reorganization or other transfers of assets, or in the event of bankruptcy or dissolution.

Compliance with law. We may be required to disclose your information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, or for the compliance, fraud prevention, and safety reasons described above. We do not have any access to your photos as they are cached in encrypted format, and the key resides on the user’s device so we cannot disclose such content.

4. Your Choices

Opt out of push notifications. You may opt out of the push notifications we may send you by changing the settings on your mobile device.

Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera, camera roll, or microphone through the settings on your mobile device.

Cloud processing. All user data is temporarily cached on our cloud servers during processing and is not retained upon completion of the cloud request.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your jurisdiction, you may request the following in relation to your personal information:

  • Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

  • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.

  • Correction of personal information that is inaccurate or out of date.

  • Deletion of personal information that we no longer need to provide the services or for other lawful purposes.

  • Additional rights, such as to object to and request that we restrict our use of your personal information.

To make a request, please email us at contact-us@pensieve-lab.com. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. If you are in Europe, you can find your data protection regulator here. If you are in the United Kingdom, the Information Commissioner’s Office is the competent authority.

Choosing not to share your information. Where we need your information in order to provide the services to you or where we are required by law to collect your information, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Please note that we may require additional information in order to verify your identity and process your request.

5. Other Sites, Mobile Applications, and Services

The Apps may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites, mobile applications, and online services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

6. Security Practices

We use commercially reasonable security practices to help keep the information collected through our services secure. However, Faceformer cannot guarantee the security of any information you provide, as bad actors, for example, may try to access, disclose, alter, or destroy your information.

Please do your part to help us. You are responsible for maintaining the confidentiality of your information, and for controlling access to communications between you and Faceformer, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.

7. Retention

We configure our cloud service, RunPod, to process only the specific photographs you choose to modify using the Apps. These photographs are temporarily cached on secure servers during the editing process and are not retained after the processing request is completed.

With respect to non-photograph formation that we may collect, we will retain such information only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy unless a different retention period is permitted or required by applicable law. You may also ask that we delete your information using the “Request cloud data removal”option in the “Support” section of the Apps settings.

8. Cross-Border Data Transfers

If we transfer your personal information internationally, these countries may not provide the same protections as the data protection laws where you are based. Where we transfer information internationally, we:

  • Make sure the data transfer complies with applicable law; and

  • Make sure that the relevant safeguards are in place to afford adequate protection for your personal information.

We do this using a variety of protections, as appropriate for each data transfer. For example, we use:

  • Standard Contractual Clauses (or an alternative legal tool, such as the UK Government-approved International Data Transfer Agreement or Addendum) to require the third party to protect your data and to provide you with EU- and UK-level rights and protections;

  • Technical protections, such as automated deletion, encryption, and pseudonymization; and

  • Policies and processes to challenge disproportionate or unlawful government authority requests.

Note, our technical support team may also access your information, such as Apps usage information, in locations outside of your state, province, or country.

9. Children

We have a minimum ‘Age Limit.’ Our Apps are not directed at children under the age of 13 years or whose age:

  • Makes it illegal to process their personal data; or

  • Requires parental consent to process their personal data.

We do not consciously collect data from subjects under the Age Limit. Please do not upload photos of children under the Age Limit, unless you are their parent or guardian. If you are under the Age Limit, do not use our Apps. If you are a parent or the guardian of a person under the Age Limit, please do not allow such person to use our Apps.

If you believe that we have received personal data from a child under the Age Limit, please contact us at contact-us@pensieve-lab.com.

10. Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Apps. We may, and if required by law will, provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the Apps.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Apps (or as otherwise indicated at the time of posting). In all cases, your continued use of our services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

11. How to Contact Us

Pensieve Pte. Ltd. is the entity responsible for the processing of your personal information, and is the data controller in respect of such processing.

If you have any questions about Faceformer, or any concerns regarding your privacy, you can contact us at: contact-us@pensieve-lab.com.

You may also write to us via postal mail at:

Pensieve Pte. Ltd.

Attn: Privacy Manager

#07-04, 2 Hougang Street 11, Singapore, 538751