Privacy Policy

Last updated: September 28, 2026

PhotoRizz ("we", "our", "the app") is an AI-powered photo generation service for dating, professional, and social profiles. Because the app creates realistic images from a photo of a person's face, it processes facial data. This policy explains what data we collect, how we use it, and your rights.

1. Who We Are

PhotoRizz is operated by Stanley Hung, a sole proprietor based in Ontario, Canada, who is the data controller for the personal information described here. For any privacy question or request, contact photorizz@staim.ai.

2. Data We Collect

• Account information - Phone number, email, or social sign-in identifiers used to create your account.
• Photos you upload - Source images you provide for AI generation. These are stored in your private account storage.
• Facial / biometric data - Your uploaded photos contain facial imagery, and the AI analyzes facial features and geometry to preserve your likeness in the generated images. In some jurisdictions this is treated as biometric or special-category data. See "Biometric & Facial Data" below.
• Generated photos - AI-generated images created from your uploads.
• Usage data - App interactions, generation history, and crash reports collected via Firebase Analytics and Crashlytics, tied to a pseudonymous app-instance identifier.
• Advertising & device identifiers - If you use the optional "watch an ad for a free photo" feature, our advertising partner (Google AdMob) collects your device's advertising identifier (Android Advertising ID / Apple IDFA), IP address, and ad-interaction data. See "Advertising" below.
• Purchase data - Transaction records for one-time photo credit purchases, processed by Apple/Google and RevenueCat.

3. How We Use Your Data

• To provide the AI photo generation service.
• If you allow it, to check how closely each generated photo resembles you, so we can show your best match first (see "Likeness check" below).
• To manage your account and photo credits.
• To show rewarded ads when you choose to earn a free photo credit.
• To improve the app through pseudonymized analytics.
• To diagnose crashes and technical issues.

4. Legal Bases

Where the EU/UK GDPR or similar laws apply, we rely on: your explicit consent for processing facial/biometric data (the optional likeness check has its own, separate consent); performance of a contract to provide the service you request; and our legitimate interests (and, where required, your consent) for analytics, crash diagnostics, and advertising. You can withdraw consent at any time (see "Your Rights").

5. AI Processing

Your uploaded photos are sent to a third-party AI image generation service (Google's Gemini image generation API) to produce the generated versions. The AI provider processes the image solely to generate the output and does not retain your photos to train its models after processing is complete.

6. Biometric & Facial Data

PhotoRizz's core function is to generate realistic photos that preserve your likeness, so the AI necessarily analyzes the facial features and geometry in the photos you upload. We want to be explicit about how this works:

• What we process - The facial imagery in your uploaded photos and the facial characteristics the AI reads from them in order to keep the generated photos recognizably you. Only if you turn on the likeness check, we also compute the temporary face measurements described below.
• Consent - Before your first upload you are asked to confirm that the photos are of you (or of an adult who has personally given you permission), that everyone in them is 18 or older, and that you are not uploading photos of public figures or anyone without their consent. By uploading, you provide that consent. Do not upload anyone else's face without their permission.
• Likeness check (optional) - With your permission, after each set is generated we compare each generated photo with the photos you uploaded to check how closely it resembles you, so we can show your best match first. We may also refund a paid photo that clearly does not resemble you. To make the comparison, our software computes a set of numbers describing the face in each photo (a face measurement, sometimes called a face template).
• How face measurements are handled - Face measurements are computed by our own software on the servers we run on Google Cloud (our hosting provider). They exist only in server memory while the check runs and are discarded when it finishes; they are never written to disk, a database, logs, or backups. They are never shared or sold, and never used to identify you in other images or across people. No third party receives them; they are not sent to Google Gemini or to our advertising partner. We keep only the outcome of the comparison (how closely each generated photo matched and which one matched best), saved with that set of generated photos and deleted with your account. That outcome cannot be used to recreate your face or to recognize you. The similarity scores (numbers, not face measurements), and whether a face was detected, are also recorded in our operational logs. Those logs are associated with your account and kept for up to 30 days, including after your account is deleted, and are used only to operate and tune this check.
• Your choice - The likeness check is optional and is requested separately in the app, before any face measurement is made. You can decline it, or withdraw your consent at any time in Settings ("Likeness check"), without losing any feature except the likeness ranking and likeness-based refunds. If you have not agreed, or you withdraw, no face measurements are made.
• No biometric identification - We do not use facial data to identify you or recognize you in other images, build a face-recognition database, or compare your face with anyone else's face or with any external dataset. The only comparison we make is the optional likeness check, between your own uploads and the photos generated from them.
• Retention - Source photos are retained only to power the in-app before/after comparison and may be removed on a routine schedule. All facial and photo data is deleted when you delete your account (see "Your Rights" and "Data Retention").
• No sale or sharing - We never sell facial or biometric data, and we do not share it with our advertising partner. Your photos are shared only with the AI processor (Google Gemini) and our hosting provider (Google Cloud) strictly to operate the service. Likeness-check face measurements are not shared with anyone, including Google Gemini: they exist only in server memory on Google Cloud, and only while the check runs.

Biometric data retention and destruction policy. This section is our written, publicly available policy for retaining and destroying biometric identifiers and biometric information. We compute likeness-check face measurements only after you have given your express consent in the app, and only for the purpose described above. We permanently destroy them as soon as that purpose is met: they exist only in server memory while the check runs and are discarded when it finishes, and they are never written to disk, a database, logs, or backups. In no case do we keep them longer than that purpose requires or beyond the limits set by applicable law, including the Illinois Biometric Information Privacy Act (no later than three years after your last interaction with us) and the Texas Capture or Use of Biometric Identifier Act (no later than one year after the purpose expires). We do not sell, lease, trade, or otherwise profit from biometric data, and we do not disclose it to anyone.

Where laws such as the Illinois Biometric Information Privacy Act (BIPA), Canada's PIPEDA, or Articles 9 and 22 of the EU/UK GDPR apply, facial data is treated as protected/special-category/sensitive data and is processed on the basis of your explicit consent. You may withdraw it at any time: for the likeness check, by turning it off in Settings; for all facial data, by deleting your account.

7. Advertising

The app offers an optional rewarded-ad feature: you can watch a short video ad to earn a free photo credit. These ads are served by Google AdMob. To serve and measure ads, AdMob collects your device's advertising identifier, IP address, and ad-interaction data. Google's use of this data is described in its partner policy.

• We do not share your photos, facial data, or account details with our advertising partner.
• You can reset or limit your advertising identifier, and opt out of personalized ads, in your device settings (Android: Settings > Privacy > Ads; iOS: Settings > Privacy & Security > Tracking / Apple Advertising).
• On iOS, we do not track you across other companies' apps unless you allow it through Apple's App Tracking Transparency prompt; otherwise you receive non-personalized ads.
• The feature is entirely optional - you never have to watch an ad to use the app.

8. Data Storage & Security

Your data is stored in Firebase (Google Cloud) with encryption at rest and in transit. Photos are stored in private Firebase Storage buckets accessible only to your account and our server-side functions.

9. Data Sharing

We do not sell your personal data. We share data only with:

• Firebase / Google Cloud - Infrastructure (including the servers that run the optional likeness check), analytics, and crash reporting.
• Google Gemini image API - AI photo processing (images only, temporarily).
• Google AdMob - Rewarded ads (device/advertising identifiers only, no photos or facial data).
• RevenueCat - Purchase management.
• Apple / Google - In-app purchase processing.

10. International Transfers

We operate from Canada and use Google Cloud infrastructure, which may process and store your data on servers located in the United States or other countries. Where required, transfers rely on appropriate safeguards (such as the providers' standard contractual clauses).

11. Your Rights

• Delete your account - Use the "Delete Account" option in Settings. This permanently removes all your data, photos, facial data, and account information. Any remaining purchased photo credits are forfeited on deletion.
• Access, correct, or export your data - Contact us to request a copy or correction of your information.
• Withdraw consent - Turn off the likeness check at any time in Settings. Withdraw your consent to all facial-data processing at any time by deleting your account.
• Advertising choices - Limit ad tracking or reset your advertising identifier in device settings (see "Advertising").
• EU/UK (GDPR) - You have rights of access, rectification, erasure, restriction, portability, and objection, and may complain to your local data-protection authority.
• Canada (PIPEDA) - You may request access to or correction of your personal information and may contact the Office of the Privacy Commissioner of Canada.
• California (CCPA/CPRA) - You have rights to know, delete, and correct your personal information, and to opt out of "sale" or "sharing." We do not sell your personal information for money; sharing device/advertising identifiers with Google to serve ads may be considered "sharing" under California law, which you can opt out of by limiting ad tracking in device settings or by not using the rewarded-ad feature.

12. Data Retention

We retain your data as long as your account is active. Source photos may be removed on a routine schedule even while your account is active. When you delete your account, all personal data, facial data, and photos are permanently removed within 30 days. Likeness-check face measurements are never retained: they are discarded when the check that computed them finishes (see "Biometric data retention and destruction policy" above). Likeness-check similarity scores and face-detection results in our operational logs are associated with your account and deleted automatically after 30 days, including after your account is deleted.

13. Children

PhotoRizz is intended for adults. We do not knowingly collect data from anyone under 18, and you must not upload photos of minors.

14. Changes

We may update this policy. Material changes will be communicated via the app.

15. Contact

Questions about this policy? Contact us at photorizz@staim.ai.