Privacy Policy

This Privacy Policy explains how PhotoDreams ("PhotoDreams," "we," "us," or "our") collects, uses, discloses, and safeguards your personal data when you access or use our website, mobile applications, and related services (collectively, the "Services"). We are based in Germany and this Policy is designed to comply with applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Please review this Policy carefully.

1. Data Controller and Contact Information

Arne Strickmann
Donauestraße 44
Berlin, Germany

Email: arne.strickmann@googlemail.com

2. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation or set of operations performed on Personal Data, whether automated or manual.
• Services: Our website, mobile applications, and any related services provided by PhotoDreams.
• Service Providers: Third-party companies that help us operate our Services.
• AI Models: Open source image generation tools (e.g., Stable Diffusion and similar models) that we use to create personalized avatars based on your uploaded images.
• Uploaded Images: Photos you provide for the purpose of generating personalized avatars.

3. Data We Collect

A. Data You Provide Directly

• Account Information: Name, email address, gender, and any other information you provide during registration or account creation.
• Uploaded Images: Photos you upload for avatar generation or related features.
• Communications: Any information you provide when contacting our support team or communicating with us for any reason.

B. Data Collected Automatically

• Device and Usage Data: Information about your device (e.g., IP address, device identifiers, browser type, operating system) and details of your usage (e.g., pages visited, features accessed).
• Analytics Information: Data collected via analytics tools to help us understand user behavior and improve our Services.
• Cookies and Tracking Technologies: Information gathered through cookies and similar mechanisms.

4. How We Use Your Data

We use your Personal Data for the following purposes:

Service Provision and Enhancement:

• To operate, personalize, and improve our Services.
• To generate personalized avatars using AI models by processing your uploaded images.
• To maintain a copy of the personalized AI model (derived from your images) for future use—while your original images are deleted immediately after processing.

5. Face Data Processing and Protection

We handle face data with the utmost care and transparency. Here is our detailed policy on face data:

A. Collection and Purpose

• We collect face data solely for the purpose of training personalized AI models to generate custom images.
• Face data collection is limited to the selfies you voluntarily upload.
• We require explicit consent before processing any face data.

B. Storage and Retention

• Explicit Non-Retention Policy: We do not retain face data or selfies after model training.
• Immediate Deletion: All uploaded selfies and face data are automatically and permanently deleted immediately after successful model training is completed.
• Temporary Processing Only: Selfies are only stored during the active training process, which typically takes a few minutes. They are deleted as soon as:
  • The AI model training is completed
  • Your personalized model is generated
  • The initial test image is created

9. Data Retention

• Face Data and Selfies: All uploaded selfies and face data are automatically and permanently deleted immediately after successful model training. We do not retain these images or face data for any period beyond the necessary training time.
• Account and Profile Data: We retain your account information for as long as your account is active or as necessary to fulfill our contractual obligations.
• Generated Content: AI-generated images are stored securely until you choose to delete them or terminate your account.

D. Security Measures

• End-to-end encryption during transmission
• Secure, encrypted storage during the brief retention period
• Automated deletion systems
• Regular security audits
• Access restricted to essential AI processing systems only

6. Data Processing by Third Parties

To deliver our Services, we engage various third-party providers. All our Service Providers are contractually bound to maintain the confidentiality and security of your Personal Data and to process it solely in accordance with our instructions and applicable data protection laws.

7. Image Processing and AI Services

Uploading and Processing:

You are required to upload a set number of photos (typically between 10 to 20) to allow our AI models to generate personalized avatars.

Immediate Deletion of Originals:

Once the avatars are successfully generated, your original images are permanently deleted from our servers.

8. Data Transfers

Your Personal Data may be transferred to and stored in countries outside the European Economic Area (EEA). In such cases, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable laws.

9. Data Retention

• Face Data and Selfies: All face data and uploaded selfies are automatically and permanently deleted within 24 hours after successful model training. We do not retain face data beyond this period under any circumstances.
• Account and Profile Data: We retain your account information for as long as your account is active or as necessary to fulfill our contractual obligations.
• Uploaded Images: Images used for generating avatars are deleted immediately after successful processing.
• Generated Content: Avatars and similar content are stored securely until you choose to delete them or terminate your account.

10. Data Security

We implement industry-standard technical and organizational measures to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction. However, please note that no security system is impenetrable, and we cannot guarantee absolute security.

11. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your Personal Data:

• Right of Access: You may request access to the Personal Data we hold about you.
• Right to Rectification: You may request corrections to any inaccurate or incomplete data.
• Right to Erasure: You may request that your Personal Data be deleted, subject to any legal obligations.
• Right to Restrict Processing: You may request a restriction on how your data is processed.
• Right to Data Portability: You may request your data in a structured, machine-readable format.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and provide personalized content.

13. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Data from minors. If you believe we have inadvertently collected data from a child under 18, please contact us immediately so that we can delete the information.

14. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. The latest version will be posted on our website, and the "Effective Date" will be updated accordingly.

15. Legal Disclaimer

This Privacy Policy is provided for informational purposes only and does not constitute legal advice. We strongly recommend that you consult with legal counsel to ensure that our data practices meet all applicable legal requirements.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us at:

Arne Strickmann
Donauestraße 44
Berlin, Germany
Email: arne.strickmann@googlemail.com