Privacy Policy for SpookifyMe

1. Introduction

Welcome to SpookifyMe ("we," "our," or "us"). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application SpookifyMe (the "App").

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the App.

2. Information We Collect

Photos and Images

We collect photos that you upload or capture using your device camera. These photos may contain images of you or others and are used solely for applying Halloween-themed AI transformations.

Important: We do NOT extract facial features, biometric data, facial recognition information, or facial maps from your photos. We treat photos as standard image files for artistic transformation purposes only.

Account Information

When you create an account, we collect:

• Email address (for authentication)
• Username (optional)
• Full name (optional)
• Password (encrypted and stored securely)

Usage Information

We automatically collect:

• Transformation history (styles applied, dates)
• Credit balance and purchase history
• App usage analytics (non-identifying technical data)

Device Information

We may collect:

• Device type and operating system
• App version
• Network information (for connectivity)

3. How We Use Your Information

Photos and Images

Photos you provide are processed by our third-party AI service (EachLabs) to apply artistic Halloween-themed transformations. The transformation process treats photos as standard images and does NOT perform:

• Facial recognition or identification
• Biometric analysis or face mapping
• Age, gender, or emotion detection
• Demographic analysis
• Individual identification

Your photos are used only for:

1. Creating Halloween-themed transformations
2. Displaying transformations in your private gallery
3. Temporary storage during processing (maximum 24 hours)

Account Information

We use your account information to:

• Authenticate your access to the App
• Manage your transformations and credits
• Communicate important service updates
• Process in-app purchases

4. Sharing Your Information

Third-Party AI Service

We share your photos with EachLabs AI (https://eachlabs.ai), our AI transformation service provider.

What is shared:

• Your uploaded photo via a temporary secure URL (expires after 1 hour)

Purpose:

• To process your photo and apply Halloween-themed transformations

What EachLabs does NOT do:

• Identify individuals from photos
• Extract biometric or facial recognition data
• Use photos for training AI models (according to their service terms)
• Share photos with other parties

Other Third Parties

We do NOT share your photos with:

• Advertising networks
• Data brokers
• Social media platforms
• Analytics services (for photo content analysis)
• Other users
• Any other third parties except EachLabs

RevenueCat (Purchase Processing)

We use RevenueCat for in-app purchase management. RevenueCat receives:

• Purchase transaction information
• User ID (anonymized)

RevenueCat does NOT receive your photos.

Supabase (Infrastructure)

We use Supabase for authentication and data storage. Your information is stored on AWS infrastructure (US region: us-east-1).

5. Data Security

We implement appropriate security measures to protect your information:

• Encryption in transit: HTTPS/TLS for all data transmission
• Encryption at rest: Database and storage encryption
• Secure authentication: Password hashing and secure session management
• Access control: Only you can access your transformations
• Temporary URLs: Photos shared with EachLabs use expiring signed URLs (1-hour validity)

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

Photos

Account Data

• Account information is retained until you delete your account
• Purchase records are retained for accounting and refund purposes (minimum 7 years as required by law)

Automatic Cleanup

• Original uploaded photos are automatically deleted within 24 hours
• Temporary processing files are cleaned up after transformation completes

7. Your Rights and Choices

Delete Transformations

You can delete individual transformations at any time from the gallery view.

Delete Account

You have the right to permanently delete your account and all associated data:

How to delete your account:

1. Open the App
2. Go to Profile tab
3. Scroll to "Danger Zone"
4. Tap "Delete Account"
5. Confirm deletion (requires typing "DELETE")

What gets deleted:

• All photos (originals and transformations)
• All transformation records
• Credit balance and purchase history
• Profile information
• Account credentials

Note: Photos stored on EachLabs servers (Google Cloud Storage) are not deleted as they are outside our control. However, these are stored with anonymized identifiers and are not linked to your account after deletion.

Access Your Data

You can view all your data within the App:

• Profile information: Profile tab
• Transformations: Gallery tab
• Credits and purchases: Credits tab

Data Portability

To request a copy of your data, contact us at omer@kayralabs.com.

8. Children's Privacy

Our App is not intended for users under the age of 13. We do not knowingly collect photos or personal information from children under 13.

If you believe a child under 13 has provided us with personal information or photos, please contact us immediately at omer@kayralabs.com, and we will delete such information promptly.

9. International Data Transfers

Your information may be transferred to and stored on servers located in the United States (AWS us-east-1 region via Supabase). By using the App, you consent to this transfer.

Photos sent to EachLabs may be processed on Google Cloud Storage infrastructure.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

• Updating the "Last Updated" date
• Posting the new Privacy Policy in the App
• Sending an email notification (for material changes)

Your continued use of the App after changes become effective constitutes acceptance of the revised Privacy Policy.

11. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights:

• Right to Know: Request information about data we collect and how we use it
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt out of sale of personal information (we do NOT sell personal information)
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise these rights, contact us at omer@kayralabs.com.

12. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), you have rights under GDPR:

• Right to Access: Request access to your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restrict Processing: Request limitation of data processing
• Right to Data Portability: Request transfer of your data
• Right to Object: Object to processing of your data
• Right to Withdraw Consent: Withdraw consent at any time

Legal Basis for Processing:

• Consent: Processing photos for transformations
• Contract: Providing the App service
• Legitimate Interest: App functionality and security

To exercise your rights, contact us at omer@kayralabs.com.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

• Email: omer@kayralabs.com
• Developer: KayraLabs
• App: SpookifyMe

Response Time: We aim to respond to all privacy inquiries within 48 hours.

14. Summary - Face Data Handling

For clarity on how we handle photos containing faces:

✅ We DO:

• Process photos for artistic Halloween transformations
• Store photos securely with encryption
• Share photos with EachLabs (AI service) for processing only
• Delete original uploads automatically within 24 hours
• Allow you to delete transformations and account anytime
• Protect your privacy and data security

❌ We DO NOT:

• Extract facial features or biometric data
• Perform facial recognition or identification
• Create face maps or facial templates
• Analyze demographics, age, gender, or emotions
• Use photos to train AI models
• Sell or share photos with advertisers
• Share photos with other users or social networks
• Use Face ID or biometric authentication

Photos are treated as standard image files for artistic purposes only, not as biometric or facial recognition data.