Privacy Policy of FaceNova

Welcome to FaceNova (hereinafter referred to as "this Application").

This Privacy Policy clearly describes how we collect, use, store, transmit and protect your personal information, as well as your rights related to your personal data. Important terms are in bold for your focus. In addition to this Privacy Policy, we will supplement the rules of data processing through in-app pop-ups and page prompts for specific functions. Such notices form an integral part of this Privacy Policy and have the same legal effect.

This Policy complies with the General Data Protection Regulation (GDPR) of the European Union, Apple App Store Privacy Requirements and Google Play User Data Policy. By using this Application, you acknowledge that you have read and agree to this Privacy Policy. If you disagree with any clause, please stop using FaceNova immediately.

1. Personal Information We Collect and Use

This Application adopts an anonymous account-free model. No mobile phone number or email registration is required. We follow the principle of data minimization and only collect information when you actively grant permissions and perform manual operations.

1.1 Device Identifiers

For anonymous user identification, session maintenance, risk control and anti-fraud, blocking of violating devices and product activity statistics, we may collect advertising identifiers of your device:

• iOS: Identifier for Advertising (IDFA);
• Android: Advertising ID (ADID);

If you disable ad tracking / Advertising ID permission in your system settings, the Application will generate a random UUID locally on your device as your anonymous identity identifier. This identifier is only used to distinguish anonymous users and cannot be used to identify your real identity.

1.2 Photos, Camera and Media Materials (Core AI Face Swap Function)

We will read media files only after you actively grant camera and album permissions and manually select or capture photos and video materials.

• Purpose: For AI photo and video face swap creation.
• Rules: Materials are only used for this single AI generation task. After AI inference completes, temporarily stored photos, videos and facial biometric data on the server will be automatically deleted and will not be permanently stored.
• This Application uses self-developed AI models. The facial data, photos and videos you upload will not be used for model training or iteration, and will not be shared, sold or provided to any third parties.

1.3 Operation Logs and Basic Device Information

We collect device model, operating system version, application operation logs and interface error information for troubleshooting and improving application stability. Such data cannot identify a natural person.

1.4 Information Related to Advertisements

This Application integrates Google AdMob advertising services.
With your consent, AdMob may access your device advertising identifier (IDFA on iOS / ADID on Android) for ad delivery, advertising performance statistics and ad frequency control.
You may disable ad tracking or reset your Advertising ID in your device system settings at any time. Disabling it will not affect core functions of the Application, but ad relevance may decrease.

1.5 In-app Purchase Order Information

When you purchase points, subscription membership and other value-added services, we obtain order vouchers, order numbers, purchase time and purchased items returned by the app store.

• Purpose: Order verification, issuance of points / membership benefits, after-sales reconciliation.
• Note: Payment processes are handled by App Store / Google Play. We will not obtain sensitive payment information such as bank card numbers or payment passwords.

We only use information for the purposes stated above and will not process data beyond the stated purposes.

2. Data Sharing, Disclosure and Third-party Services

1. We will not share facial data or user media materials. Uploaded photos, videos and facial biometric data are processed in a closed loop, and will not be provided to any third parties or used for model training.
2. Third-party services integrated in this Application:
   • Alibaba Cloud OSS: To receive your uploaded photos and videos; files are only stored temporarily and deleted automatically after the AI task completes.
   • Google AdMob advertising service.
   • In-app purchase services provided by App Store / Google Play.
3. All third parties process data only within the scope agreed in this Policy and shall comply with GDPR, Apple and Google platform privacy requirements.
4. We will disclose relevant information only when legally required or requested by judicial authorities in accordance with the law.

3. Your Rights over Personal Data (GDPR)

You enjoy the following rights, which you may exercise by submitting requests through the in-app customer service channel:

• Right of Access: You may request to query data associated with your device stored by us.
• Right to Erasure: You may request deletion of your relevant data stored on our server.
• Right to Withdraw Consent: You may withdraw your permissions at any time. Corresponding functions will become unavailable after withdrawal.
• Right to Data Portability.
• Right to Object to Processing.
• Right to Rectification.

4. Data Storage and Security Protection

1. Our servers are deployed in Silicon Valley.
2. Media materials are only stored temporarily on the cloud and automatically cleaned after AI generation completes. Facial data and creation materials will not be persistently saved on the server. Generated works are stored locally only on your mobile device.
3. Data is transmitted via encrypted channels. Backend access isolation and permission control are implemented to protect your data against leakage, tampering and loss risks.
4. Local cache: A small amount of cache such as anonymous identifiers and permission status is saved locally on your device. You may clear App cache or uninstall the application in system settings to delete all local data.

5. Minor Protection

FaceNova services are available only for users aged 18 or above. We will not actively collect personal information from minors. If you are under 18 years old, please do not use all AI creation functions of this Application. If we discover data submitted by minors, please contact us via in-app customer service and we will delete such data immediately.

6. Revision of this Privacy Policy

We may update this Privacy Policy according to laws and regulations, product iteration and platform compliance requirements. After update, the new version will be displayed inside the Application. Your continued use of the service constitutes your acceptance of the revised terms. We will provide prominent in-app reminders for material changes.

7. Contact Us (In-app Customer Service)

If you have questions about this Privacy Policy, personal data processing, deletion requests, feedback or violation reports, you may submit tickets through the built-in customer service channel inside FaceNova.
We commit to verifying, processing and replying to your submitted tickets within 14 calendar days upon receipt. Screenshots and text materials submitted during customer service communication will only be used to handle your current request, kept strictly confidential and will not be shared externally.

8. Dispute Resolution

If any dispute arises regarding data processing, both parties shall first resolve it through negotiation via in-app customer service. You also have the right to file a complaint with your local data protection supervisory authority.