Privacy Policy

App: Face Swap: AI Photo Generator (the "App")
Data Controller: JiaJun Zhang ("we," "us," or "our")
Effective Date: September 28, 2026
Last Updated: September 28, 2026
Contact: 18209279688@163.com

Summary of Key Points

1. Scope of This Policy

This Privacy Policy explains how we collect, use, disclose, retain, and protect information when you use the App. It applies to all features of the App, including:

Please read this Policy carefully before using the App. If you do not agree with it, please do not use the App. Your use of the App is also governed by Apple's Standard End User License Agreement, available at https://www.apple.com/legal/internet-services/itunes/dev/stdeula/.

This Policy is provided in English and is the governing version. Where the App or its store listing presents a translated version, the translation is provided for convenience only.

2. Information We Collect

2.1 Photos and Videos You Select

When you use an AI feature, you choose a photo or video from your device (or capture one using the camera). The App may also let you crop the content locally on your device before it is used. We do not maintain a library of your content on our own servers.

2.2 Face Data

The AI features of the App operate on faces. When you select a photo or video containing a face, the App processes the facial regions of that content in order to produce the effect you requested. Because the files you submit may contain human faces, those files may contain face data.

We do not extract, generate, or store standalone facial feature data such as facial landmarks, biometric templates, or face embeddings, and we do not maintain any database of faces. Any temporary face detection, alignment, or positioning performed on your device is used only to deliver the feature you requested. Section 4 explains our handling of face data in more detail.

2.3 AI-Generated Output

Results generated by the App are delivered to your device, labeled as AI-generated, and stored locally in the App's history so that you can view, save, or delete them. We do not publish your results and we do not use them for any purpose other than delivering them to you.

2.4 Purchase and Subscription Information

In-app purchases and subscriptions are processed by Apple. We do not receive or store your payment card details. We may receive limited transaction-related information, such as subscription status, product identifier, transaction identifier, or purchase event status, in order to unlock paid features, validate entitlements, and measure subscription-related events.

2.5 Diagnostic, Analytics, and Configuration Data

We use Firebase Analytics, Firebase Crashlytics, and Firebase Remote Config. These services may process app usage events, feature interaction events, crash reports and diagnostic information, app instance identifiers, and configuration-related identifiers. This information is used in aggregated or de-identified form to understand app performance, diagnose crashes, and manage feature configuration.

2.6 Advertising, Attribution, and Measurement Data

The App shows advertising and measures the performance of our marketing campaigns. We use Google AdMob (including the Google User Messaging Platform for consent), Adjust, Meta/Facebook (including the Facebook Audience Network SDK), and the TikTok Business SDK. Depending on the permissions you grant, these partners may process device identifiers, advertising identifiers, app events, subscription or purchase-related events, and limited device or usage data for ad delivery, attribution, campaign measurement, and fraud prevention.

2.7 Device Permissions

Depending on the features you use, the App may request access to:

PermissionWhy it is needed
CameraTo capture a photo for face swap.
MicrophoneTo record audio when you capture a video for face swap.
Photo Library (read)To let you choose a photo or video for face swap and other AI features.
Photo Library (add)To save generated results to your device when you ask us to.
Tracking (App Tracking Transparency)To allow advertising and attribution partners to use permitted identifiers for measurement, where you consent.

You can change or revoke any permission at any time in your device Settings. Revoking a permission may disable the corresponding feature.

2.8 Information We Do Not Intentionally Collect

We do not request or collect your precise location, contacts, calendar, SMS messages, call logs, photo library contents in bulk, installed application list, Wi-Fi network name, health data, or financial account credentials.

2.9 No Account Required

The App does not offer or require account registration. We do not create user profiles tied to your identity, and we do not operate a server-side account database about you. We may store a small local usage counter in the device Keychain (for example, to manage trial or free-usage limits); this value stays on your device and is not transmitted to us.

3. How We Use Information

We use the information described above only for the following purposes:

PurposeInformation usedLegal basis (where applicable)
To provide the AI feature you requested and return the result to you Selected photo or video (including face data contained in it) Performance of a contract with you; your consent
To show you the required notice and obtain your confirmation before content is sent for AI processing Selected content and your consent choice Your consent; legal obligation
To operate, maintain, troubleshoot, and improve the App Analytics and diagnostic data Our legitimate interests in keeping the App functional and secure
To detect crashes, bugs, abuse, fraud, and security incidents Diagnostic data, device and usage data Our legitimate interests; legal obligation
To deliver advertising and measure marketing and subscription performance Advertising identifiers, attribution data, event data Your consent (where required); our legitimate interests
To validate purchases and provide access to paid features Transaction and subscription status information Performance of a contract with you
To configure features and service behavior remotely Configuration identifiers and app instance data Our legitimate interests
To comply with applicable laws and respond to lawful requests Information required by the request Legal obligation

We do not use your photos, videos, or face data for advertising, marketing, profiling, or any purpose unrelated to the feature you requested.

4. How We Handle Face Data

Face data is the most sensitive category of information the App touches, and we limit our handling of it accordingly.

Our specific commitments:

5. Your Consent and Control

Before your selected content is transmitted to a third-party AI service provider, the App presents a clear in-app notice explaining (a) what data will be sent, (b) with whom it will be shared, and (c) the purpose of the processing, and asks you to confirm. If you do not confirm, the content is not sent and the AI feature is not performed.

You are also asked to confirm that you have the right to use the content you upload, as described in Section 6.

You may at any time:

If you decline a notice or revoke a permission, some features may no longer work. Browsing the App itself does not require any AI processing to take place.

6. Content Standards and Prohibited Uses

You are responsible for the content you submit. By using the App you agree that you will not upload, create, or share content that:

To support these standards, we take the following measures:

The App is not intended for, and must not be used to produce, imagery that depicts a real person in a false, intimate, humiliating, or deceptive situation. Creating or distributing such content may be a criminal offence in your jurisdiction.

7. Third-Party AI Processing and Data Sharing

When you confirm an AI feature, the App transmits the content you selected (a photo, or a video for video features) directly to our third-party AI service provider, in order to perform the effect you requested.

Our current AI service provider is:

We do not separately transmit facial landmark files, biometric templates, or face embeddings to our AI provider. We do not sell your photos, videos, face data, or generated results to anyone.

We may also disclose information where we are required to do so by law, regulation, legal process, or a valid governmental request, or where necessary to protect the rights, property, or safety of our users, the public, or ourselves.

If we are involved in a merger, acquisition, financing, or sale of assets, information we hold may be transferred as part of that transaction. In that case we will continue to protect the information as described in this Policy, and we will provide notice before your information becomes subject to a different privacy policy.

8. Other Third-Party Services

We use the third-party services listed below. Each processes data under its own privacy policy.

ServicePurposeProvider
Firebase AnalyticsApp usage analytics and measurementGoogle
Firebase CrashlyticsCrash reporting and diagnosticsGoogle
Firebase Remote ConfigApp configuration and feature managementGoogle
Google AdMob (with User Messaging Platform)Advertising delivery and consent managementGoogle
AdjustInstall attribution and campaign measurementAdjust GmbH
Meta / Facebook (incl. Audience Network)Attribution and advertising measurementMeta Platforms
TikTok Business SDKAttribution and advertising measurementTikTok
Apple In-App PurchasePayment processing and receipt validationApple
AILab ToolsAI image and video processing you requestAILab Tools

Links to each provider's privacy policy are provided in Section 17. These providers may collect or receive data from the App in accordance with their own policies and the permissions you have granted.

9. Tracking and App Tracking Transparency

The App requests permission through Apple's App Tracking Transparency (ATT) framework before engaging in tracking across apps or websites owned by other companies.

If you allow tracking, our advertising and attribution partners may use permitted identifiers and app event data to attribute installs, measure campaigns, deliver advertising, and prevent fraud. If you do not allow tracking, we do not access the advertising identifier for cross-app tracking purposes; only data permitted by Apple's policies and the permissions you granted will be used, and you may still see non-personalized advertising.

You can change the tracking permission at any time in Settings > Privacy & Security > Tracking on your device.

10. Data Retention

10.1 Our Retention Practices

10.2 Third-Party Retention

Because AI processing is performed by third-party providers, the content you submit may be retained temporarily by them:

If you believe that content of yours is being retained beyond these periods, please contact us and we will raise the matter with the relevant provider.

11. Your Privacy Rights and Choices

11.1 All Users

Regardless of where you live, you may:

11.2 If You Are in the EEA, the UK, or Switzerland

Under the GDPR and equivalent laws, you have the right to:

Where we rely on legitimate interests, we have balanced those interests against your rights and expect the impact on you to be minimal because we do not build profiles based on your photos, videos, or face data.

11.3 If You Are a California Resident

Under the CCPA/CPRA you have the right to:

We do not sell personal information as that term is commonly understood. Certain advertising and analytics activities may be treated as "sharing" for cross-context behavioral advertising under California law; you can limit these by declining tracking and by using the in-app consent options provided by our advertising partner. Because we do not store your photos, videos, or face data, we do not retain sensitive personal information derived from them.

11.4 How to Exercise Your Rights

Email us at 18209279688@163.com. We will respond within the time required by applicable law, generally within 30 days. To protect your privacy, we may ask you to provide enough detail for us to locate any relevant records; because we generally do not hold personal data tied to your identity, we may inform you that we hold no such data.

12. Data Security

We use administrative, technical, and organizational measures designed to protect information, including transmitting content to our AI service provider over encrypted channels (HTTPS/TLS), restricting access to systems and credentials on a need-to-know basis, and keeping user content out of our own server storage.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please keep your device protected with a passcode or biometric lock, and keep your operating system up to date.

13. Children's Privacy

The App is not directed to children. You must be at least 13 years old (or the minimum age of digital consent in your country, if higher) to use the App. If the App is rated for older audiences in your region, that rating applies.

We do not knowingly collect personal information from children, and we do not knowingly process content depicting a minor for any AI feature. If you believe that a child has provided information or content to the App, please contact us immediately at 18209279688@163.com and we will take steps to delete it and to block the relevant content.

14. International Data Transfers

Our service providers may operate in countries other than the one in which you live. When information is transferred internationally, we and our providers rely on appropriate safeguards, such as standard contractual clauses approved by the European Commission or an equivalent mechanism, and apply the protections described in this Policy.

15. Changes to This Policy

We may update this Policy from time to time, for example to reflect changes to the App's features or to legal requirements. When we make material changes, we will update the "Effective Date" and "Last Updated" dates above and, where required, provide additional notice within the App or by other appropriate means. Continued use of the App after an update takes effect means you accept the updated Policy.

VersionDateSummary
2.0September 28, 2026Rewritten for clarity and completeness: added face data commitments, consent flow, content standards and AI labeling, sourcing of video and age/gender features, complete third-party service list, GDPR/CCPA rights, and updated retention disclosures.
1.0April 1, 2026Initial version.

16. Contact Us and Complaints

If you have any question, request, or complaint about this Policy or about how we handle information, please contact us at:

Email: 18209279688@163.com
Data Controller: JiaJun Zhang
App: Face Swap: AI Photo Generator

If you are in the EEA, the UK, or Switzerland and you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. If you are a California resident, you may also contact the California Attorney General's office.

17. Third-Party Service Directory

ProviderPrivacy Policy
AILab Toolshttps://www.ailabtools.com/privacy-policy
AILab Tools (Terms of Service)https://www.ailabtools.com/term-of-use
Akool, Inchttps://akool.com/privacy-policy
Akool, Inc(Terms of Service)https://akool.com/terms-of-service
Google (Firebase, Analytics, Crashlytics, Remote Config, AdMob)https://policies.google.com/privacy
Firebase data practiceshttps://firebase.google.com/support/privacy
Google Ads / AdMob data practiceshttps://policies.google.com/technologies/ads
Adjusthttps://www.adjust.com/terms/privacy-policy/
Meta / Facebookhttps://www.facebook.com/privacy/policy/
TikTokhttps://www.tiktok.com/legal/privacy-policy
Applehttps://www.apple.com/legal/privacy/