Privacy Policy

Effective Date: April 1, 2025

1. Our Commitment to Your Privacy

AI Headshot Photo Generator ("we", "our", or "us") is dedicated to safeguarding your privacy. This Privacy Policy outlines how your personal information is gathered, utilized, and shared when you interact with AI Headshot Photo Generator.

This policy pertains to our website, including its associated subdomains (collectively referred to as our "Service"), as well as our AI Headshot Photo Generator application. By accessing or utilizing our Service, you acknowledge that you have read, comprehended, and consent to our gathering, retention, application, and sharing of your personal information as detailed in this Privacy Policy and our Terms of Service.

2. Definitions and Key Terms

To ensure clarity in this Privacy Policy, the following terms are strictly defined:

• Cookie: A small piece of data created by a website and stored by your web browser. It's used to recognize your browser, supply analytics, and recall details about you, like language preferences or login credentials.
• Company: When this policy mentions "Company", "we", "us" or "our" it refers to Eltima IBC Inc, located at Office 213, Building 6E-A, Dubai Airport Freezone, Dubai, United Arab Emirates, which is responsible for your information under this Privacy Policy.
• Country: Refers to the location where AI Headshot Photo Generator or its owners/founders are based, currently UAE.
• Customer: Designates the company, organization, or individual that registers to use the AI Headshot Photo Generator Service.
• Device: Any internet-enabled device like a smartphone, tablet, computer, or other machine used to visit AI Headshot Photo Generator and use its services.
• IP address: A unique number assigned to every device connected to the Internet, often used to identify the approximate geographic location from which a device connects.
• Personnel: Refers to individuals employed by AI Headshot Photo Generator or contracted to perform services on our behalf.
• Personal Data: Any information that, directly, indirectly, or in conjunction with other data (including a personal ID number), enables the identification or identifiability of a natural person.
• Service: Denotes the service offered by AI Headshot Photo Generator as described in relevant terms (if available) and on this platform, specifically the generation of AI headshots.
• Third-party service: Includes advertisers, contest organizers, promotional/marketing partners, and others providing content or whose products/services might interest you.
• Website: AI Headshot Photo Generator's site, accessible via https://ai-headshot-photo-generator.app.
• You: A person or entity registered with AI Headshot Photo Generator to utilize the Services.

3. Information Automatically Collected

Certain information-like your Internet Protocol (IP) address and/or browser and device characteristics-is gathered automatically when you access our platform. This data might be used to link your device to the Internet. Other automatically collected details could include login credentials, email address, password (hashed), computer/connection specifics (like browser type/version, plug-ins, time zone), operating system, platform details, purchase history (sometimes aggregated anonymously), the complete Uniform Resource Locator (URL) clickstream data (to, through, and from our Website, including date/time), cookie identifiers, sections of the site you viewed/searched, and any phone number used for customer service. We may employ browser data like cookies, Flash cookies (or Local Shared Objects), or similar tools on parts of our Website for fraud prevention and other needs. During visits, software tools like JavaScript might measure and collect session data, including page load times, download issues, duration of visits to specific pages, page interaction details (scrolling, clicks, mouse movements), and methods used to navigate away. Technical information might also be gathered to aid in device identification for fraud prevention and diagnostics.

When you visit, use, or navigate our platform, we automatically collect certain information. While this data doesn't reveal your specific identity (like name or contact details), it can include device and usage specifics, such as IP address, browser/device type, operating system, language settings, referring URLs, device name, country, location, and technical details about your interaction with our platform. This information is primarily essential for maintaining the security and operation of our Service and for internal analytics and reporting.

4. Collection of Personal Data and Methods

AI Headshot Photo Generator may process your Personal Data for the objectives outlined in this Privacy Policy.

The specific Personal Data of users collected and utilized by AI Headshot Photo Generator includes:

• Identity Information: Your name and surname (if provided, e.g., for account creation or support).
• Contact Information: Email address, phone number (if you contact us directly).
• Visual Data: The photos you upload to the AI Headshot Photo Generator application for processing, and the facial feature data derived from these photos necessary to generate headshots.
• Device & Usage Information: Identifier for Advertisers (IDFA, if permission granted), Identifier for Vendors (IDFV), Internet Protocol (IP) Address, device name, operating system version, app configuration during use, time/date of use, and other usage statistics (Log Data).
• Transaction Information: Details related to any purchases or subscriptions (e.g., order information, in-app purchase history).
• Marketing Preferences: Based on device identifiers (IDFA, IDFV) if applicable and consented to.

We may gather this data directly from you via electronic or physical means, from your mobile device, or through third-party platforms (like Apple App Store, Google Play Store – collectively "App Stores") used to access our application. This collection serves purposes like legal compliance, service enhancement, managing your use of our services, and enabling you to navigate and enjoy our offerings smoothly.

Log Data generated during your use of our services/applications (via our products or third-party tools) may also be collected. This can include your device's IP address, device name, OS version, app configuration, usage times/dates, and other statistical data.

5. How We Utilize Your Information

We employ your information for various business-related reasons, including delivering our Services, administrative tasks, and marketing our products and Services, as detailed below.

Providing Our Services

We use your information to fulfill our agreement with you and deliver our Services, such as:

• Generating AI headshots based on the photos you provide.
• Managing your account and information.
• Granting access to specific areas and features of our Services.
• Responding to customer service or technical support requests.
• Communicating regarding your account, Service activities, and policy updates.
• Processing financial details and payments for purchased products or Services.

Administrative Purposes

Your information is used for various administrative functions, such as:

• Pursuing legitimate interests like direct marketing, research and development (including market research), network/information security, and fraud prevention.
• Identifying security incidents, safeguarding against malicious, deceptive, fraudulent, or illegal activities, and pursuing those responsible.
• Gauging interest and engagement with our Services.
• Short-term, temporary uses, like contextual ad customization.
• Improving, upgrading, or enhancing our Services.
• Developing new features and Services.
• Ensuring internal quality control and safety.
• Authenticating and verifying user identities.
• Debugging to find and fix errors within our Services.
• Auditing related to interactions, transactions, and compliance activities.
• Enforcing our agreements and policies.
• Adhering to our legal obligations.

Marketing and Advertising

We might use Personal Information to customize and deliver content and advertisements, as permitted by law. Marketing methods could include email campaigns, custom audience advertising, and interest-based or personalized advertising (potentially including cross-device tracking). You can opt out of marketing communications by contacting us (see Section 17).

Other Purposes

We also use your information for other objectives requested by you or allowed by applicable law. For instance, if our Service offers referral tools, we might use information you provide about friends/colleagues to share content or invitations.

6. General Principles for Personal Data Processing

In line with this Privacy Policy, [Your Company Name], acting as the data controller, processes Personal Data according to these core principles: (i) lawfulness, fairness, and transparency; (ii) accuracy and, where needed, keeping data up-to-date; (iii) processing for specified, explicit, and legitimate purposes; (iv) adequacy, relevance, and limitation to what is necessary for the processing purposes (data minimization); and (v) storage for no longer than necessary for the processing purposes or as required by law.

7. Purposes and Legal Bases for Processing Personal Data

Your Personal Data will be processed using automated or non-automated methods for the purposes listed below, based on applicable laws (including relevant articles of GDPR or local data protection laws like PDP Law if applicable), necessity for contract performance, or the legitimate interests of [Your Company Name], provided your fundamental rights and freedoms are protected.

Data Category & Primary Purposes:

• Identity Information: Compliance activities, fulfilling service commitments.
• Contact Information: Communication, business operations/auditing, post-sales support, sales processes, storage/archiving, contract management, information security, audit/ethics, business activity oversight.
• Process Security (IP, Logs, Device Info): Business continuity, providing info to authorities, business operations/auditing, post-sales support.
• Customer Transaction Data: Sales processes, customer satisfaction activities, contract management, compliance activities.
• Visual Data (Uploaded Photos & Derived Features): Core Service Provision (Generating AI Headshots), contract fulfillment (providing the service), storage/archiving, service improvement (e.g., model training on anonymized/aggregated data where permissible), potentially marketing analysis (on aggregated/anonymized usage patterns).
• Marketing Data (IDFA/IDFV): Advertising/campaign/promotion execution.

Legal Bases (Examples - Adapt based on GDPR/local laws):

• Identity, Contact, Visual Data, Transaction Data: Processing is necessary for the performance of a contract with you (providing the headshot service) or to take steps at your request before entering into a contract. Necessary for establishing, exercising, or defending legal claims.
• Process Security Data: Necessary for compliance with a legal obligation. Necessary for our legitimate interests (maintaining security, service operation, fraud prevention).
• Marketing Data: Your explicit consent.

Additional Processing Purposes:

• Creating user accounts.
• Personalizing Services, understanding user preferences for enhanced experience.
• Informing about new offerings, promotions (with consent where required).
• Managing digital subscriptions and in-app purchases.
• Handling auto-renewable subscriptions.
• Executing information security processes.
• Conducting activities according to legal requirements.
• Responding to requests from competent authorities.
• Managing finance and accounting transactions.
• Overseeing communication activities.
• Administering contracts.
• Carrying out strategic planning.
• Tracking requests and complaints.

8. Third-Party Websites and Applications

The AI Headshot Photo Generator application may include links to external websites not operated by [Your Company Name] and whose content we do not control. These linked sites might have different terms and privacy policies. [Your Company Name] is not responsible for the use or disclosure of information processed by these external sites. Similarly, we bear no responsibility for links from other sites pointing to the AI Headshot Photo Generator application.

We collect information fairly and lawfully, with your awareness and consent where required. We inform you about the reasons for collection and intended use. You have the right to refuse our request for information, understanding that this might prevent us from providing certain desired services.

9. Push Notifications

[Your Company Name] may occasionally send push notifications via its mobile application regarding updates or service information. You can manage these notifications through your device settings at any time to stop receiving them. Your data will be stored for the duration specified by applicable law, or for a reasonable period until the processing purpose ceases, or during legal limitation periods. [Your Company Name] might retain your Personal Data beyond the expiry of its use purpose if required by other laws or with your separate consent. If consent is given for extended storage, the data will be promptly deleted, destroyed, or anonymized when that period ends or the purpose no longer exists.

10. Technical and Administrative Security Measures

[Your Company Name] stores processed Personal Data according to relevant laws and retention periods. We commit to implementing all necessary technical and administrative measures and exercising due care to ensure the confidentiality, integrity, and security of Personal Data. This includes preventing unlawful processing, unauthorized access, disclosure, alteration, or destruction. Accordingly, [Your Company Name] employs measures such as:

• Anti-virus Protection: Regularly updated anti-virus software on relevant IT infrastructure.
• Firewalls: Protection for servers (potentially in data centers or cloud environments) using updated firewalls controlling network access.
• Secure Access (e.g., VPN): Secure methods for authorized personnel or suppliers to access systems when necessary.
• Access Control: Limiting employee access to systems based on job roles and updating permissions upon role changes.
• Security Monitoring: Systems to detect and manage information security threats and events, allowing for timely responses.
• Encryption: Use of cryptographic methods for storing sensitive data and transferring it through encrypted channels where appropriate; secure key management.
• Logging: Securely logging transactions involving sensitive data.
• Authentication: Employing measures like multi-factor authentication for remote access to sensitive data where applicable.
• Training: Regular employee training on information security awareness.
• Physical Security: Measures to secure physical data (e.g., paper records) and the environments where sensitive data is stored.
• Backup: Periodic data backups using secure mechanisms (e.g., cloud provider facilities, internal solutions) compliant with laws and this policy.
• Confidentiality Agreements: Non-disclosure agreements with Personnel involved in processing sensitive data.
• Secure Data Transfer: Using encrypted methods (e.g., encrypted email, secure file transfer) when transferring sensitive Personal Data electronically.

Should Personal Data be compromised due to an attack on the AI Headshot Photo Generator application or systems despite these measures, or if obtained by unauthorized third parties, [Your Company Name] will promptly notify affected Users and, if required, the relevant data protection authority, taking necessary remediation steps.

11. Transferring Personal Data to Third Parties

Procedures for transferring Personal Data are governed by applicable laws (e.g., GDPR Articles 44-50, local data protection laws). Personal Data may be transferred within your country or abroad, potentially using servers or cloud systems located internationally.

Your Personal Data might be transferred internationally for reasons including:

• Storage and archival activities (using cloud providers).
• Conducting business operations (using international tools/platforms).
• Providing post-sales support services (using global support platforms).
• Managing customer relationship management processes (using global CRM systems).

[Your Company Name] may also transfer your Personal Data to our service providers and third parties integrated into our service (like analytics providers, e.g., Adjust, Firebase Analytics, potentially advertising networks, cloud processing providers) for purposes such as:

• Sharing identity, contact, and security information with authorities for legal compliance, monitoring legal affairs, and informing relevant bodies.
• Sharing identity and contact details for managing post-sales support, business activities, and customer relationships.
• Facilitating user-initiated sharing or integration with third-party applications linked to AI Headshot Photo Generator (with user consent where applicable).
• Processing photos using cloud-based AI infrastructure providers.

12. Personnel Information

If you are an applicant or employee of [Your Company Name], we collect information you voluntarily provide. This is used for Human Resources purposes, like administering benefits and screening applicants. You can contact us to update/correct your information, change communication preferences, or request a record of your data. Such changes won't affect information already maintained or shared with third parties prior to the request, as per this policy.

13. Sale of Business

We reserve the right to transfer information to a third party if [Your Company Name] or substantially all its assets (or the relevant Service portion) are sold, merged, or otherwise transferred. This also applies if we cease operations or face bankruptcy/reorganization proceedings, provided the third party agrees to uphold the terms of this Privacy Policy.

14. Affiliates

We may share information (including Personal Data) with our Corporate Affiliates. A "Corporate Affiliate" is any entity that directly or indirectly controls, is controlled by, or is under common control with [Your Company Name]. Any information shared will be treated by affiliates according to this Privacy Policy.

15. Governing Law

This Privacy Policy is governed by the laws of United Arab Emirates, without regard to its conflict of laws principles. You consent to the exclusive jurisdiction of the courts in UAE for any action or dispute arising under this policy, except where individuals have rights under other frameworks (like Privacy Shield, if applicable, or specific local regulations). Your use of the application may also be subject to other local, state, national, or international laws.

Using AI Headshot Photo Generator or contacting us directly signifies your acceptance of this Privacy Policy. If you disagree, do not engage with our website or use our services. Continued use after changes are posted (that don't significantly alter personal information use/disclosure) implies acceptance of those changes.

16. Your Consent

We have updated our Privacy Policy for transparency regarding data collection and usage. By using our app, registering an account, or making a purchase, you consent to this Privacy Policy and its terms.

17. Links to Other Websites

This policy applies only to the AI Headshot Photo Generator Service. The Service might link to other websites not operated or controlled by us. We aren't responsible for the content, accuracy, or opinions on such sites, nor do we investigate or monitor them. When you follow a link from our Service to another website, our Privacy Policy ceases to apply. Your browsing and interaction on any other site are subject to that site's own rules and policies. Third parties may use their own Cookies or methods to collect data.

18. Advertising

Our application may contain third-party advertisements and links to third-party sites. [Your Company Name] does not guarantee the accuracy or suitability of information in those ads or sites and accepts no responsibility for their conduct, content, or offerings. Advertising helps keep AI Headshot Photo Generator potentially free or low-cost. We strive to ensure ads are safe, non-intrusive, and relevant. Third-party ads and links are not endorsements by [Your Company Name]. We are not liable for ad content, promises made, or the quality/reliability of advertised products/services.

19. Cookies for Advertising

These Cookies gather information over time about your online activity within the app and other services to make ads more relevant (interest-based advertising). They also help prevent the same ad from reappearing constantly and ensure proper ad display for advertisers.

20. Cookies

AI Headshot Photo Generator uses "Cookies" to identify visited areas of our website/app. Cookies are small data pieces stored on your device by your browser. We use them to improve performance and functionality, though some are non-essential. Without certain Cookies, features like remembering your login might not work. Most browsers allow disabling Cookies, but doing so might impair access to our website/app functionality. We never store Personally Identifiable Information in Cookies.

21. Blocking and Disabling Cookies

You can set your browser to block Cookies and similar technologies. However, this might block essential Cookies, preventing our website/app from functioning correctly, potentially limiting feature access. Blocking Cookies might also delete saved information (like login details, site preferences). Refer to your browser's help menu for instructions on managing or deleting Cookies.

22. Payment Details

Regarding any credit card or payment details provided, we commit to storing this confidential information securely, typically relying on compliant third-party payment processors who handle the data directly.

23. Children's Privacy

Our Service does not target anyone under the age of 13 (or a higher age if stipulated by local law, e.g., 16 under GDPR in some contexts). We do not knowingly collect personally identifiable information from children under 13. If you are a parent/guardian aware that your child provided Personal Data, please contact us. If we learn we collected Personal Data from anyone under 13 without verified parental consent, we take steps to remove it from our servers.

24. Changes to Our Privacy Policy

We may modify our Service and policies, necessitating changes to this Privacy Policy. Unless legally required otherwise, we will notify you (e.g., through the Service) before changes take effect, providing an opportunity for review. Continued use of the Service afterward binds you to the updated policy. If you disagree with the changes, you can delete your account.

25. Third-Party Services

We might display, include, or make available third-party content (data, information, apps, etc.) or link to third-party websites/services ("Third-Party Services"). You agree that [Your Company Name] is not responsible for Third-Party Services, including their accuracy, completeness, timeliness, validity, legality, quality, etc. We assume no liability to you or others for Third-Party Services. They are provided solely for convenience; access and use are entirely at your own risk, subject to the third party's terms and conditions.

26. Information Collected Through Analytics Tools (e.g., Microsoft Clarity, Firebase Analytics, Adjust)

(Adjust this section based on the specific tools you use)

• Types of Data: Our application may use analytics tools like [Microsoft Clarity, Firebase Analytics, Adjust] to process data about user interactions (e.g., screen views, taps, session duration, crash reports, attribution data).
• Handling of Sensitive Data: We configure these tools, where possible, to avoid collecting unnecessary sensitive Personal Data.
• Data Security: We rely on the security measures of these analytics providers and implement appropriate safeguards on our end.
• Use of Data: Data from these tools helps us analyze usage patterns, improve user experience, diagnose issues, and understand marketing effectiveness. Providers may use this data according to their own privacy policies.
• User Rights: You may have rights regarding data collected by these tools (see Sections below on GDPR/CCPA). Opt-out mechanisms might be available through device settings (e.g., limiting ad tracking).

27. Information about General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), we may collect and use your information. This section explains how and why, and how we protect it.

What is GDPR? An EU law regulating the protection and control of EU residents' personal data. It applies globally to companies processing such data. We aim to apply GDPR principles as a baseline standard.

What is Personal Data? Any data relating to an identifiable individual (extending beyond name/email to include things like IP addresses, biometric data derived from photos for processing, etc.).

Data Protection Principles: We strive to adhere to principles like lawful/fair/transparent processing, purpose limitation, data minimization, accuracy, storage limitation, integrity/confidentiality, and accountability.

Why GDPR Matters: It sets requirements for protecting Personal Data and increases compliance stakes. We believe data privacy is crucial and implement robust security/privacy practices.

Individual Data Subject Rights: Under GDPR, you have rights like:

• Access
• Rectification
• Erasure (right to be forgotten)
• Restriction of processing
• Data portability
• The right to object to processing (including for direct marketing)

We are committed to facilitating these rights. We process/store data with vetted, DPA-compliant vendors (e.g., cloud providers). Data (including photos processed) is typically retained as needed to provide the service and for a reasonable period afterward or as legally required (e.g., for potential disputes), after which it is disposed of securely. You can usually manage your data or request deletion via your account settings or by contacting us.

28. California Residents (CCPA/CPRA)

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), requires disclosures about Personal Information categories collected/used, sources, and sharing, as explained above. California residents have specific rights:

• Right to Know/Access: Request information about categories and specific pieces of Personal Information collected, sources, purposes for use, and categories of third parties shared with.
• Right to Delete: Request deletion of your Personal Information, subject to exceptions.
• Right to Correct: Request correction of inaccurate Personal Information.
• Right to Opt-Out of Sale/Sharing: Request that we do not "sell" or "share" (for cross-context behavioral advertising) your Personal Information. We do not sell Personal Information. We may share data with advertising partners as described in the Advertising section, which you may be able to limit via device settings or by contacting us.
• Right to Limit Use of Sensitive Personal Information: Request limitation on the use/disclosure of sensitive Personal Information (like precise geolocation or biometric information derived from photos) only to what's necessary for providing the service or other permitted purposes.
• Right to Equal Service: We won't discriminate against you for exercising privacy rights.

To exercise these rights, please contact us. We have a defined timeframe (typically 45 days, extendable) to respond. We do not sell the Personal Information of users in the traditional sense.

29. California Online Privacy Protection Act (CalOPPA)

CalOPPA also requires disclosures (covered above) and grants rights similar to CCPA (Know, Delete, Non-Discrimination). If you wish to exercise these rights, contact us.

30. Contact Us

If you have any questions about this Privacy Policy, please don't hesitate to contact us via Email: info@ai-headshot-photo-generator.app