Privacy Policy

1. Introduction

This Privacy Policy describes how the Mini Cartoon iOS application ("Mini Cartoon", the "App", "we", "us", "our"), operated by TRY2APP LTD, collects, uses, and shares information when you use the App.

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. This document explains exactly what we do collect, why we collect it, and the choices you have.

2. Your Explicit Consent Before Data Sharing

Before any photo leaves your device, the App asks for your permission in two places:

1. First-launch disclosure. When you open the App for the first time, a full-screen "AI Processing Notice" explains that photos you choose will be sent to FAL.ai for AI processing, identifies what data is and is not shared, and requires you to tap "I Agree & Continue" before any feature becomes accessible.
2. Per-action confirmation. Every single time you tap the "Transform" button, a confirmation alert titled "Send photo to fal.ai?" appears before any upload begins. The alert identifies the recipient (FAL.ai), states what is being sent (only the photo you selected), and lists what is not sent (name, email, contacts, location). If you tap Cancel, nothing is uploaded. Only tapping "Send & Generate" causes the photo to be transmitted to FAL.ai.

This two-step consent flow applies on every generation, not only on the first one. You remain in control of each individual upload. You may withdraw your consent at any time by declining the per-action alert, deleting your generation history from the Settings tab, or uninstalling the App.

In addition, a permanent notice directly below the "Transform" button on the Home screen reads: "AI processing powered by fal.ai — your photo is sent to fal.ai when you tap Transform."

3. Information We Collect

Anonymous Identifier

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, or any other personal information you've shared with Apple. The ID exists so the App can sync your subscription status, generation history, and credit balance across sessions on the same device.

Photos You Upload for Generation

When you tap "Transform", you select a single photo from your iOS Photo Library. Because the App is designed to create cartoon illustrations of people, your selected photo will typically contain a human face. The selected photo is uploaded to our AI generation provider (FAL.ai) over an encrypted connection so the AI model can process it. The photo is used solely to generate the requested cartoon illustration.

We do not store the original photo on our own servers. Once the generation is complete, the original photo is no longer accessible to us. Our AI provider's data retention policy is described in their own privacy policy (linked below).

Generated Cartoon Images

The AI-generated cartoon images are stored as URLs in our database (Cloud Firestore) under your anonymous user ID. The image files themselves are hosted by our AI provider for a limited time. You can request deletion of any generation at any time by contacting us.

Subscription and Purchase Data

When you purchase a subscription or a credit pack, the transaction is processed entirely by Apple. We use a service called RevenueCat to verify and sync your subscription status and to deliver the credits you've purchased. We receive only:

• The product identifier you purchased
• The purchase status (active, expired, refunded)
• The expiration date for active subscriptions
• The original purchase date used to detect renewals
• The Apple transaction identifier used to prevent duplicate credit grants

We do not see your Apple ID, your credit card number, your billing address, or any other payment information. All payment processing is handled by Apple.

Technical Telemetry

Our backend infrastructure (Google Firebase) records standard server-side telemetry for reliability and fraud prevention purposes, including request timestamps, IP address (transiently, for rate limiting and abuse detection), and basic device-class information. This data is not joined with your anonymous user ID in any profile and is deleted on a rolling basis.

What We Do Not Collect

For absolute clarity, we do not collect:

• Your name, email address, phone number, or postal address
• Your contacts, calendar, or messages
• Your location or GPS data
• Any photos other than the one you explicitly select for a generation
• Your Apple ID or any account information
• Your IDFA or any advertising tracker data (the App does not display ads)
• Browsing history or activity outside the App

4. How We Use Your Information

We use the limited information we collect for the following purposes only:

• To provide the cartoon-illustration generation service you requested
• To sync your subscription status, credit balance, and generation history across sessions on your device
• To prevent fraud, abuse, and violations of our Terms of Service
• To comply with legal obligations
• To improve App performance and reliability

We do not sell your personal information. We do not share your personal information with advertisers. We do not use your photos to train AI models.

5. Third-Party Services

The App relies on a small number of trusted third-party services. Each is bound by its own privacy policy and the limited purpose for which we use it. For each third party below, we have reviewed their privacy practices and confirmed that they provide the same or equivalent protection to the safeguards described in this Privacy Policy.

FAL.ai (AI Generation)

We use FAL.ai to perform AI-powered image generation. When you create a cartoon, your selected photo is sent to FAL.ai over an encrypted connection for processing. The App uses the following FAL models: fal-ai/nano-banana-pro/edit for cartoon stylization and fal-ai/bria/background/remove for background removal.

Equivalent protection confirmation: Per FAL.ai's published privacy policy, FAL.ai (i) does not train AI models on user-submitted inputs, (ii) does not sell, rent, or share user data with advertisers or data brokers, (iii) retains submitted inputs only transiently for the duration required to return a result, and (iv) transmits data exclusively over TLS-encrypted connections. These practices provide protection equivalent to the safeguards we apply to your data directly.

FAL.ai privacy policy: https://fal.ai/legal/privacy-policy

Google Firebase

We use Firebase Authentication for anonymous account creation, Cloud Firestore to store your subscription/credit balance and generation history metadata, and associated Google Cloud services for server-side configuration. Firebase is operated by Google LLC.

Google privacy policy: https://policies.google.com/privacy

RevenueCat

We use RevenueCat to handle subscription and consumable in-app purchase validation and synchronization. RevenueCat receives your anonymous user ID and the App Store transaction metadata only.

RevenueCat privacy policy: https://www.revenuecat.com/privacy

Apple

The App is distributed through Apple's App Store. Apple processes all payments and may provide us with basic crash-diagnostic information if you opt into sharing it.

Apple privacy policy: https://www.apple.com/legal/privacy/

6. Data Retention

We retain the limited information we collect for as long as your installation is active, plus a reasonable period thereafter to comply with our legal obligations.

• Photos you upload: Not stored by us. Sent to our AI provider for the duration of generation only. The original file is no longer accessible to us once the generation completes.
• Generated cartoon image URLs: Stored in our database for up to 90 days, after which they are automatically deleted. You can request earlier deletion by contacting us.
• Anonymous user ID, credits, and purchase records: Retained while your installation is active. Subscription records may be retained for the period required by tax and accounting laws (typically up to 7 years).
• Server telemetry: Deleted on a rolling basis, typically within 30 days.

7. Your Rights

Depending on where you live, you may have the following rights regarding your personal information:

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 that produces legal or similarly significant effects
• Right to lodge a complaint with a supervisory authority in your country

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), Turkey (KVKK), and other jurisdictions provide similar rights. You may exercise them through the same channel below.

How to Exercise Your Rights

To exercise any of these rights, contact us at [email protected] with the subject line "Mini Cartoon — Privacy Request". Because we use anonymous identifiers, please include your anonymous user ID (visible in the App's Settings screen under "About") so we can locate your data. We will respond within the timeframe required by applicable law (typically within 30 days for GDPR).

8. 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.

Parents and guardians: if you permit a minor to use the App, please ensure they only upload photos of themselves and not photos of other children without their parents' consent.

The App's content rating in the App Store is set in accordance with Apple's age rating guidelines.

9. 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 following:

• The App uses generative artificial intelligence to create stylized cartoon illustrations from user-supplied photos. The output is synthetic content generated by an AI system.
• Generated cartoon images are clearly presented as AI-generated within the App's history screen.
• The AI models used are fal-ai/nano-banana-pro/edit for illustration and fal-ai/bria/background/remove for background isolation, both provided by FAL.ai.
• The AI generation process is initiated only by your explicit action (tapping "Transform"). The App does not generate content automatically.
• Generated cartoon images may be embedded with technical markers indicating their AI-generated origin.
• You are responsible for the lawful use of any content generated by the App. Use of generated content to deceive others, create deepfakes of real people without consent, impersonate public figures, or otherwise violate applicable law is strictly prohibited by our Terms of Service.
• This App does not fall within the "high-risk AI" categories enumerated in Annex III of the EU AI Act. It is a limited-risk generative system subject to transparency obligations.

10. Biometric and Facial Data Notice

Because the App can process photos that contain human faces, we wish to be explicit about this category of data:

• Your uploaded photo is sent to our AI provider (FAL.ai) solely to render a stylized cartoon illustration. It is not used to extract or store facial geometry, facial recognition templates, biometric identifiers, face embeddings, or any similar biometric data.
• We do not perform facial recognition, face matching, identity verification, emotion inference, age estimation, or any other biometric analysis on your photo.
• We do not maintain a biometric database or link uploaded faces to any identity.
• You must only upload photos of yourself, or photos of other people for whom you have obtained explicit consent (see our Terms of Service, Acceptable Use).

If you are a resident of a jurisdiction with specific biometric laws (such as Illinois BIPA, Texas CUBI, or Washington state), the processing described above is limited-scope image transformation and does not, in our view, constitute "biometric identifier" collection under those statutes. If you have questions, contact us.

11. International Data Transfers

The App's backend services (Google Firebase, RevenueCat, FAL.ai) operate from data centers located 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.

12. Security

We protect the limited information we collect using industry-standard measures, including:

• 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 enforced at the database level so each user can only read and write their own records
• Limited backend access restricted to authorized personnel
• Regular security review of third-party providers

No system is perfectly secure. If you become aware of a security incident affecting your data, please contact us immediately at [email protected].

13. 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 practical
• 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.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your data, contact us at:

TRY2APP LTD
Email: [email protected]
Subject: Mini Cartoon — Privacy Inquiry

We will respond as soon as possible, typically within 7 business days.