Privacy Policy
- Introduction
- Plain-English Summary
- App Store Privacy Label (Apple Disclosure)
- App Tracking Transparency (ATT)
- Information We Collect
- How We Use Your Information
- Legal Basis for Processing (GDPR)
- Third-Party SDKs & Service Providers
- Data Retention
- Your Rights
- Account & Data Deletion
- Children's Privacy
- AI Processing Disclosure (EU AI Act)
- International Data Transfers
- Security
- Changes to This Policy
- Contact Us
1. Introduction
This Privacy Policy describes how the AI Face Sticker Maker iOS application ("AI Face Sticker Maker", the "App", "we", "us", "our") collects, uses, and shares information when you use the App. The App is published by TRY2 APP LTD, the data controller for the purposes of this Policy.
We've designed the App to collect as little personal information as possible. You do not need to create an account. We do not ask for your name, email, phone number, or any other personally identifying information.
2. Plain-English Summary
In one paragraph: We don't know who you are. When you tap Generate, the photo you pick is sent to our AI provider over an encrypted connection to produce 9 transparent face stickers, and then it is dropped. We keep an anonymous ID on our backend so the App remembers your credit balance and subscription status. We do not use your photos to train AI, we do not sell data, and we do not track you across other apps or websites.
3. App Store Privacy Label (Apple Disclosure)
Apple requires every app on the App Store to disclose its data collection practices in the "App Privacy" label shown on each app's App Store listing. The table below mirrors the exact disclosures we make to Apple under its three required categories.
Category A — Data Used to Track You
None.
AI Face Sticker Maker does not link any data collected from this app with data from third-party apps or websites for advertising or tracking purposes. We do not share any data with data brokers.
Category B — Data Linked to You
The following data types are linked to your anonymous App installation (not to your real identity):
- Identifiers — User ID. A random anonymous ID generated by Firebase Authentication. Used for App Functionality (to remember your credits, subscription, and history).
- Purchases — Purchase History. The product identifiers and subscription status of purchases made through Apple. Used for App Functionality (to unlock paid features you bought).
- User Content — Photos. The photo you explicitly pick to generate stickers, and the resulting generated sticker URLs. Used for App Functionality only (to produce the stickers you asked for and to let you view it in History).
Category C — Data Not Linked to You
- Diagnostics — Crash Data, Performance Data. Aggregated crash logs and performance metrics used for App Functionality and Analytics. These are anonymized and not tied to your identity.
What we do NOT collect
For full transparency, the following data categories Apple asks about are not collected by AI Face Sticker Maker at all:
- Contact Info (email, name, phone number, physical address, other contact info)
- Health & Fitness
- Financial Info (payment, credit, other financial info)
- Location (precise or coarse)
- Sensitive Info (race, sexual orientation, religion, politics, etc.)
- Contacts
- Browsing History
- Search History
- Identifiers — Device ID (IDFA or similar advertising identifier)
- Usage Data — Product Interaction, Advertising Data, Other Usage Data
- Other Data Types (Customer Support messages you email us are stored by our mail provider for support purposes only)
4. App Tracking Transparency (ATT)
Apple's App Tracking Transparency framework requires apps to request user permission before tracking them across other apps and websites owned by different companies.
AI Face Sticker Maker does not track you across other apps or websites. Because we do not engage in cross-app tracking, we do not present the ATT permission prompt. We do not access or use your Identifier for Advertisers (IDFA), and we do not share any data with advertisers or data brokers.
5. Information We Collect (Detailed)
Anonymous Identifier (Firebase Auth)
When you first open the App, our backend (Google Firebase Authentication) generates a random anonymous user ID for your installation. This ID is not linked to your real identity, your Apple ID, your email, or any other personal information you've shared with Apple. The ID exists so the App can sync your credit balance, subscription status, and generation history across sessions on the same device.
Photos You Upload for Generation
When you tap Generate, you select a single photo from your iOS Photo Library via Apple's standard PHPickerViewController. The selected photo is uploaded to our AI generation provider (fal.ai) over an encrypted TLS connection so the AI model can process it. The photo is used solely to generate the stickers you requested.
- We do not store the photo on our own servers.
- We do not access your Photo Library without you explicitly picking a photo — we rely on Apple's picker, which sandboxes selection.
- We do not use your photos to train any AI model, our own or a third party's.
Generated Stickers
The AI-generated sticker URLs are stored in our Firestore database under your anonymous user ID so that you can view them from the History tab. The sticker images are hosted by our AI provider and accessed over HTTPS. You may delete any generated sticker pack at any time.
Subscription and Purchase Data
When you purchase a subscription or credit pack, Apple processes the transaction entirely. We use RevenueCat to verify and sync your purchase status. The data we receive is limited to:
- The anonymous user ID we associate with the purchase
- The product identifier you purchased (e.g.
stickerweek) - Purchase status (active, expired, refunded) and expiration date
We never see your Apple ID, credit card number, billing address, or any other payment information. That data stays with Apple.
Diagnostic & Performance Data
To keep the App stable we may receive aggregated crash logs and performance metrics (such as load times and error rates). This data is not linked to your identity and is used to diagnose issues and improve stability.
Device Signals
For debugging we may log non-identifying signals such as iOS version, device model (e.g. "iPhone 15"), and app version. We do not use the IDFA and we do not run any advertising trackers in the App.
6. How We Use Your Information
We use the limited information we collect for the following purposes only:
- To provide the photo-to-sticker AI generation service you requested
- To sync your subscription, credits, and history across sessions on your device
- To validate and track in-app purchases through Apple's StoreKit
- To prevent fraud, abuse, and violations of our Terms of Service
- To comply with legal obligations
- To improve App stability through aggregated, anonymous diagnostics
We do not sell your personal information. We do not share it with advertisers. We do not use your photos or generated stickers to train AI models.
7. Legal Basis for Processing (GDPR)
If you are in the European Union, United Kingdom, or another jurisdiction with comparable law, we process your personal data under the following legal bases:
- Performance of a contract (Art. 6(1)(b) GDPR) — processing necessary to provide the App and fulfill purchases (anonymous ID, purchase data, photos you submit, generated stickers).
- Legitimate interests (Art. 6(1)(f) GDPR) — processing for App stability, fraud prevention, and security, balanced against your rights and freedoms.
- Legal obligation (Art. 6(1)(c) GDPR) — retention of purchase records for tax and accounting.
- Consent (Art. 6(1)(a) GDPR) — for any processing that requires consent, such as optional future integrations. You can withdraw consent at any time.
8. Third-Party SDKs & Service Providers
The App includes the SDKs listed below. Each publishes a privacy manifest (PrivacyInfo.xcprivacy) as required by Apple, and is bound to the purpose for which we use it.
fal.ai (AI Generation)
Purpose: AI photo-to-sticker generation. Model: fal-ai/nano-banana/edit + fal-ai/birefnet/v2. Data sent: your uploaded photo and generation parameters (prompt, resolution, aspect ratio).
Privacy policy: https://fal.ai/legal/privacy-policy
Google Firebase (Authentication + Firestore)
Purpose: anonymous authentication and storage of your user document, credits, subscription status, and generation history metadata. Operator: Google LLC.
Privacy policy: https://firebase.google.com/support/privacy · Google Privacy Policy
RevenueCat
Purpose: subscription and consumable purchase validation, linking Apple transactions to your anonymous user ID. Data: anonymous user ID, Apple transaction identifier, subscription state.
Privacy policy: https://www.revenuecat.com/privacy
Apple
Purpose: App Store distribution, StoreKit billing, and system services. Apple processes all payments directly; we never see your payment instrument.
Privacy policy: https://www.apple.com/legal/privacy/
9. Data Retention
- Photos you upload: Not stored by us. Transmitted to our AI provider for the duration of generation only.
- Generated sticker URLs: Stored in our database for up to 90 days, after which they are automatically deleted. You can delete them sooner from the History screen.
- Anonymous user ID, credits, and subscription status: Retained while your installation is active. Deleted on request (see Section 11).
- Subscription and purchase records: Retained for the duration of your subscription plus the period required by tax, accounting, and consumer-protection law (typically up to 7 years depending on jurisdiction).
- Crash/diagnostic data: Retained in aggregated form for up to 90 days.
10. Your Rights
European Union and United Kingdom (GDPR / UK GDPR)
- Right to access the personal data we hold about you
- Right to rectification of inaccurate data
- Right to erasure (the "right to be forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing
- Right not to be subject to solely automated decision-making
- Right to withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal
- Right to lodge a complaint with a supervisory authority (e.g. ICO in the UK, your national DPA in the EU)
California, USA (CCPA / CPRA)
- Right to know what personal information is collected
- Right to delete personal information
- Right to correct inaccurate personal information
- Right to opt out of the sale or sharing of personal information (we do not sell or share)
- Right to limit use of sensitive personal information
- Right to non-discrimination for exercising your privacy rights
Other Jurisdictions
Brazil (LGPD), Canada (PIPEDA), Australia (Privacy Act), and other jurisdictions provide similar rights. You may exercise them through the contact address in Section 17.
How to Exercise Your Rights
To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Request". Because we use anonymous identifiers, please include your anonymous user ID (visible in the App's Settings screen) so we can locate your data. We will respond within the timeframe required by applicable law (typically within 30 days under GDPR/CCPA).
11. Account and Data Deletion
You can delete your anonymous account and all associated data at any time. Because the App does not require an email or real-name account, deletion is handled via email:
- Open the App and go to Settings. Note your anonymous User ID.
- Email [email protected] with the subject "Delete my data" and include your User ID.
- We confirm receipt within 2 business days and complete deletion within 30 days.
Deleted data includes your Firestore user document, generation history, and stored sticker URLs. Apple retains purchase records it is legally required to keep; these are outside our control.
Uninstalling the App alone does not delete server-side data. To have everything removed from our backend, you must email us.
12. Children's Privacy
The App is not intended for children under 13 years of age (or under the minimum digital consent age in your jurisdiction, which may be 14 or 16 in some EU member states). We do not knowingly collect personal information from children.
If you are a parent or guardian and believe a child has provided personal information to us, please contact us at [email protected] and we will delete it promptly.
The App's content rating in the App Store is set in accordance with Apple's age rating guidelines.
13. AI Processing Disclosure (EU AI Act Compliance)
In compliance with Regulation (EU) 2024/1689 (the "EU AI Act") and global best practices for transparent AI, we disclose:
- The App uses generative artificial intelligence to create sticker packs from user-supplied face photos. The output is synthetic content generated by an AI system.
- The AI model is
fal-ai/nano-banana/edit + fal-ai/birefnet/v2, provided by fal.ai. - Generated stickers are clearly identifiable as AI-generated within the App's History screen.
- AI generation is initiated only by your explicit action (tapping "Generate"). The App does not generate content automatically.
- Generated stickers may include provenance markers embedded by the AI provider.
- You are responsible for the lawful use of any content generated by the App. Use to deceive, create non-consensual deepfakes, or otherwise violate applicable law is prohibited by our Terms.
14. International Data Transfers
Our backend services (Google Firebase, RevenueCat, fal.ai) operate from data centers in the United States and the European Union. By using the App, you consent to the transfer of your information to these regions for processing.
For transfers of personal data from the European Union or United Kingdom to countries outside the EEA, we and our processors rely on Standard Contractual Clauses approved by the European Commission and other appropriate safeguards (Art. 46 GDPR).
15. Security
We protect the limited information we collect using industry-standard measures:
- TLS 1.2+ encryption for all data in transit
- Encryption at rest provided by Google Cloud and our other infrastructure providers
- Anonymous identifiers — no real-name linkage
- Firestore security rules that restrict access to each user's own documents
- Limited backend access restricted to authorized personnel
- Regular security review of third-party providers and their privacy manifests
No system is perfectly secure. If you become aware of a security incident affecting your data, please contact us immediately at [email protected]. For incidents that affect personal data of EU/UK users, we will notify the relevant supervisory authority as required by law.
16. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes we will:
- Update the "Last updated" date at the top of this policy
- Notify users via in-app message where appropriate
- For significant changes, provide a plain-language summary of what changed
Continued use of the App after changes are posted constitutes acceptance of the updated policy.
17. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your data, contact us at:
Email: [email protected]
Subject: AI Face Sticker Maker — Privacy Inquiry
Data controller: TRY2 APP LTD
We typically respond within 7 business days.