Privacy Policy

1. Introduction

This Privacy Policy describes how the Paparazzi AI iOS application ("Paparazzi AI", the "App", "we", "us", "our") collects, uses, and shares information when you use the App. The App is published by TRY2APP 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. The App has no login, no user profile, and no server-side database of its own.

2. Plain-English Summary

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.

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.

Paparazzi AI 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)

No Account, No Backend

Unlike many apps, Paparazzi AI does not operate its own server or database. There is no sign-up, no login, and no user profile stored anywhere by us. The only state the App keeps is your subscription status, which is managed entirely by Apple's StoreKit and our subscription-management partner, RevenueCat.

Your Photo (Camera or Photo Library)

When you tap Take Photo, the App uses your device's camera through Apple's standard UIImagePickerController framework. When you tap Choose from Photos instead, the App uses Apple's standard PhotosPicker, which only hands the App the single photo you explicitly select — we never get broader access to your Photo Library.

That one photo is held in memory on your device while you choose a paparazzi style. Before it is ever sent anywhere, the App shows you a dedicated, explicit consent screen — separate from this Privacy Policy — that names the third party (fal.ai), states exactly what is sent (the one photo you selected), and explains why. Nothing is transmitted unless you tap "Agree & Continue" on that screen; tapping "Not Now" sends nothing. Once you agree, and only if you also have an active Premium subscription, that one photo is uploaded to our AI provider (fal.ai) over an encrypted TLS connection so it can generate your personalized paparazzi-style photo. The photo is used solely to produce the result you asked for.

• We do not store your photo on our own servers — we don't have any servers of our own to store it on.
• Nothing is sent anywhere until you have both (a) explicitly agreed on the in-app consent screen and (b) have an active subscription — no photo is ever uploaded for a free/non-premium user, and none is ever uploaded before you've agreed.
• We do not use your photos to train any AI model, our own or a third party's.

Generated Images

The AI-generated paparazzi-style image is shown back to you inside the App and saved to a local "My Paparazzi Shots" history on your device only — the App has no server-side history or gallery of its own. The history is capped at your 30 most recent shots (older ones are automatically removed), lives entirely in the App's private on-device storage, and is deleted permanently if you delete an item yourself or uninstall the App. When you tap "Save", iOS additionally writes the image to your own Photo Library (with your permission); in every case, we never store a copy on our own servers.

Subscription and Purchase Data

When you purchase a Premium subscription, Apple processes the transaction entirely. We use RevenueCat to verify and sync your purchase status. The data involved is limited to:

• An anonymous purchase identifier generated by the RevenueCat SDK on your device (not derived from your Apple ID or any personal information)
• The product identifier you purchased (e.g. paparazziweekly, paparazziyearly)
• 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.

6. How We Use Your Information

We use the limited information involved for the following purposes only:

• To provide the paparazzi-style AI photo service you requested
• To validate and track in-app purchases through Apple's StoreKit and RevenueCat
• To prevent fraud, abuse, and violations of our Terms of Service
• To comply with legal obligations

We do not sell your personal information. We do not share it with advertisers. We do not use your photos or generated images 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 personal data (to the limited extent described above) under the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR) — processing necessary to provide the App and fulfill purchases (the photo you submit for the duration of a single generation request, purchase data).
• Legitimate interests (Art. 6(1)(f) GDPR) — processing for 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, handled by Apple/RevenueCat.

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 image generation to create your personalized paparazzi-style photo. Model: fal-ai/nano-banana-2/edit. Data sent: the photo you captured or selected, and generation parameters (prompt, resolution, output format). Sent only after you explicitly agree on the in-app consent screen described above, only once you have an active Premium subscription, and only for the single request you initiated.

fal.ai is contractually and technically required to protect your data to a standard consistent with this Privacy Policy: it does not use your photo to train AI models, does not sell or share it with further third parties, transmits it only over encrypted connections, and retains it only for the limited time technically necessary to serve your request.

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

RevenueCat

Purpose: subscription purchase validation and entitlement management. Data: an anonymous device-generated purchase identifier, Apple transaction identifier, subscription state.

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

Apple

Purpose: App Store distribution, StoreKit billing, on-device Camera and Photos frameworks. Apple processes all payments directly; we never see your payment instrument.

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

9. Data Retention

• Photos you capture or upload: Not stored by us at any point — we have no server to store them on. Transmitted to our AI provider for the duration of generation only. Our provider's retention is governed by their own policy linked above.
• Generated images: Not stored on our own servers. Kept in a local "My Paparazzi Shots" history stored only on your device (capped at your 30 most recent shots, deletable by you at any time, erased entirely on uninstall), and additionally persisted to your own device's Photo Library only if you personally tap "Save".
• Subscription and purchase records: Held by Apple and RevenueCat under their own retention policies. We do not keep a copy of these ourselves.

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 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 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 18.

How to Exercise Your Rights

Because the App has no accounts and no backend of its own, there is generally nothing on our side to look up. For anything related to your subscription, contact us at [email protected] with the subject line "Privacy Request — Paparazzi AI" and we'll assist or point you to Apple/RevenueCat as appropriate. We will respond within the timeframe required by applicable law (typically within 30 days under GDPR/CCPA).

11. Account and Data Deletion

Paparazzi AI has no account and no server-side database — there is nothing stored on our end to delete. Your original photo is only ever held transiently on your device and, briefly, in transit to our AI provider for a single request; it is never retained by us. Your generated results are kept in a "My Paparazzi Shots" history stored locally on your device (never on our servers) until you delete them yourself or uninstall the App — you're always in control of that local history from within the App.

The only durable record of your relationship with the App is your subscription, held by Apple and RevenueCat. To remove that, cancel your subscription via iOS Settings → Apple ID → Subscriptions. If you'd like us to confirm there's nothing tied to you, email [email protected] with the subject "Paparazzi AI — Delete my data" and we'll confirm within 7 business days.

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, and since the App has no accounts, we have no mechanism to knowingly retain any.

If you are a parent or guardian and have concerns, please contact us at [email protected].

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

13. Face Data (Photos)

Paparazzi AI's core purpose is to restyle a photo of you into a realistic paparazzi-style shot — so nearly every photo processed by the App contains a face. This section explains in detail how we treat images that include faces.

What face data we collect

The App processes your photo as a single image — a collection of pixels. It does not perform any of the following on faces in your photo:

• No facial recognition or face identification
• No biometric face data, face embeddings, or faceprints
• No attempts to link a face to a real-world identity
• No extraction of demographic, emotion, age, or identity signals from faces
• No creation or storage of face templates

The AI model we use (fal-ai/nano-banana-2/edit at fal.ai) treats your photo holistically as an image to edit. It does not output biometric data, does not cross-match faces, and does not maintain any face database. The model is instructed to preserve the photographed person's identity, facial geometry, eyes, nose, lips, skin tone, hairstyle, and apparent age exactly — it only changes lighting, background, and paparazzi camera aesthetic; it does not replace or reshape who is in the photo.

All planned uses of face data

The only purpose for which a photo containing a face is processed is to produce the paparazzi-style result you explicitly requested. No other use is made of the face pixels — not for training, not for analytics, not for advertising, not for demographic profiling.

Sharing with third parties

The photo — which will typically contain a face — is transmitted once, over an encrypted TLS connection, to our AI processing provider fal.ai (operated by Features & Labels, Inc.) to run the generation, and only once you have an active Premium subscription. It is not shared with any other third party. fal.ai is contractually bound not to train on user input and not to retain the photo beyond what is technically necessary to serve the request. Our list of subprocessors is in Section 8.

Storage and retention of face data

• We do not store the original photo on our own servers — we don't operate any.
• fal.ai processes the photo in memory to produce the output and retains it only for the time technically required to serve that individual request. fal.ai does not use input photos as training data.
• The generated result is displayed to you in the App and kept in your on-device "My Paparazzi Shots" history only — never on our servers. If you save the result to your own Photo Library, iOS handles that separate storage too, again without any copy passing through our servers.
• On request (see Section 11) we will confirm within 7 business days that nothing related to you remains anywhere on our side.

Where in this policy face data is addressed

Face data (as part of the broader category of photos that may contain faces) is addressed in: Section 3 ("App Store Privacy Label"), Section 5 ("Your Photo" and "Generated Images"), this Section 13, Section 9 ("Data Retention"), and Section 14 ("AI Processing Disclosure").

Consent before any face-bearing photo is sent

No photo is ever transmitted automatically. Before your very first generation, and before any photo ever leaves your device, the App presents a dedicated consent screen that plainly discloses: what is sent (your selected photo), who it is sent to (fal.ai, our third-party AI provider), and why (to generate your paparazzi-style photo). Sending only happens after you tap "Agree & Continue" on that screen — tapping "Not Now" or closing the screen sends nothing. This is in addition to, not a substitute for, the requirement that you also have an active Premium subscription; non-premium users' photos are never sent anywhere regardless of consent. You can withdraw consent at any time by uninstalling the App, which also erases the on-device consent record.

14. 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 transform a user-supplied photo into a realistic candid paparazzi-style photograph — while preserving the same person's identity, facial geometry, eyes, nose, lips, skin tone, hairstyle, and apparent age. The output is synthetic content generated by an AI system.
• The AI model is fal-ai/nano-banana-2/edit, provided by fal.ai.
• AI generation is initiated only by your explicit action (capturing or picking a photo, choosing a style, explicitly agreeing on the in-app consent screen to send your photo to fal.ai, and being an active Premium subscriber). The App does not generate content automatically.
• Generated images 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 manipulated imagery, or otherwise violate applicable law is prohibited by our Terms.

15. International Data Transfers

Our service providers (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 the limited information described above to these regions for processing.

For transfers of personal data from the European Union or United Kingdom to countries outside the EEA, our processors rely on Standard Contractual Clauses approved by the European Commission and other appropriate safeguards (Art. 46 GDPR).

16. Security

We protect the limited information involved using industry-standard measures:

• TLS 1.2+ encryption for all data in transit
• No server-side database of our own, which minimizes what could ever be exposed in a breach
• Anonymous purchase identifiers — no real-name linkage
• 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.

17. 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.

18. Contact Us

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

Email: [email protected]
Subject: Paparazzi AI — Privacy Inquiry
Data controller: TRY2APP LTD

We typically respond within 7 business days.